July 23, 2020
To whom it may concern:
I am a small, individual investor. I recently became aware of the proposal to alter the reporting threshold for money managers to report their various long positions.
As an ordinary citizen with no special contacts, access to sophisticated computer algorithms, high tech software to analyze the market, or a dedicated staff of personnel to assist me, I rely heavily on ANY publicly available information I can access.
Furthermore, as a singular citizen with little to no influence on multi-million dollar firms and such, many like me depend on the SEC to provide full and complete transparency of any firm who manages money on behalf of us citizens. Anything that reduces such transparency is, in my view, inherently bad.
Having read the well written commentary by Commissioner Allison Herren Lee and her rationale for opposing this proposal, I can summarily say that the one and only justification held by firms requesting this change is around the cost of reporting and how burdensome it is. And while I can't express my views as eloquently as Commissioner Lee, what I can say is abundantly clear is this:
If these $100 million money managers were faced with figuring out a far better way to manage the funds they were entrusted with, they would put all measures of effort into maximizing gains, even IF that meant a slightly larger burden on reporting. In other words, the argument that said reporting is too cost burdensome and for better or worse, is not a valid reason for depriving the general public of the safety, transparency, and core checks and balances that us EVEN SMALLER investors rely on for all manner of reasons.
I will further state that instead of pursuing a reduction in the 13-F rules, we should EXPAND this rule to include both long AND short positions held, we as any other notable instruments that can serve as a proxy for stocks / equities. I say this because I'm simply not very knowledgeable in this area. But I've been around long enough to know that if a firm wants to hide their actions and stocks don't offer that, they are very adept and creative at finding other ways to evade monitoring and detection.
Thank you in advance for taking the time to read my comments. I realize they probably differ substantially from what you are accustomed to get. As a singular, everyday citizen however - I felt that if my voice could be heard, I would be remiss if I didn't take a few minutes to share my thoughts and ask for your consideration.
If you desire, you may contact me via the provided email address and I would be happy to share anything I can to contribute to your process.
Sincerely,
Eric and Lisa Fontaine
Spring, TX