July 22, 2020
I am in favor of raising the $ amount in this proposed rule, however, I believe the $3.5 billion amount proposed is too high. I would suggest using an inflation index to determine how much the $100 limit should be increased. I think a limit of $500 million would be more reasonable.
I disagree with the premise that we should look at how much the value of the equity markets have increased in the last 30 years and apply that rate of return to the $100 million limit. I think that results in too high of a limit.
There are a significant amount of smaller money managers and it is important to retain public disclosure rules for those managers. They have processes in place to ensure compliance with the rules and I would imagine their fee structures charged to clients consider those compliance fees. If you were to remove the filing requirements for those money managers than it's likely they eliminate workers or keep additional profits for themselves which results in the rich getting richer.
I am in support of raising the limit and I strongly suggest the SEC consider an amount lower than $3.5 billion.
Regards,
Spencer Gilason, CPA