Subject: File No. S7-08-20
From: Joe Ledbetter, PhD
Affiliation: Professor

July 22, 2020

There is no reason to raise the limit on quarterly reporting for institutional investors from accounts valued over $100 million to $3.5 billion. The reporting burden on these funds is insignificant compared to the improved transparency as a result of current requirements. There is no right to privacy in a true market that demands transparency for information on which buyers and sellers depend. Otherwise, you are disguising insider trading rather than providing regulations through transparency. In fact, why not require real time reporting of every transaction so that the public is aware of how these large investors move markets? Any investor should be able to see exactly who the buyer and seller is on financial transactions exceeding $1 million in any SEC sanctioned market. The information is already available - just make it public