July 22, 2020
Raising the reporting threshold to such a high number will severely limit future academic research on markets, investing and securities.
Raising the reporting threshold to such a high number will reduce public companies' opportunity to know more about who their shareholders are.
Many managers are known to talk among themselves, sharing ideas and information. They have access to company management that small investors don't. Given the SEC's emphasis on a level fair playing field, this rule change makes no sense. When is less transparency and less data ever a good thing for the small investor?
Some investors may want to avoid over-owned stocks, believing they have a high level of risk. This rule change greatly reduces individual investors ability to reduce their risk.
When Congress first adopted Section 13(f) it did so to stimulate a higher degree of confidence among all investors in the integrity of the US securities markets. Taking this data away will have the opposite effect. Transparency is what gives investors confidence in US markets.