July 23, 2020
To whom it may concern,
This proposed rule change which removes the necessity for all but the largest investment managers to report their holdings to the public serves absolutely no benefit towards improving market transparency and benefiting the investment community as a whole. The filing requirements for investment firms is hardly onerous at all and the processes for doing so are highly automated. The proposed rule change makes little to no sense when considering the small benefits to some smaller managers when compared to the massive detriments to the investing community as a whole.
If anything, reporting of such firms should be more frequent and more detailed. Moving in the opposite direction is a regressive move which should be removed from consideration immediately.
Regards,
James Steiger