July 22, 2020
I disagree with the proposed rule but agree with the sentiment to update quantitative rules over time. Reporting of holdings is not a complex reporting problem. Every investor has a close watch on their holdings so reporting them is not a burden. The current rule should be expanded to report long and short positions so it is a more complete picture. Consider instead adjusting the threshold for inflation (approximately $400M) or the percentage of funds covered by the original rule being maintained in the current total number of available funds instead. The new $3.5B limit is more than necessary to reset the threshold to current equivalency. It is disproportionate and the reporting will overly reduce transparency for extremely marginal reduction in reporting burden.