July 23, 2020
With everything else going on in the world with the economy and markets, this is not the time to implement an outrageous rule change that would make the market a lot less transparent. The current quarterly disclosure requirement gives the public a look where big funds are investing, and the supposed benefit of reducing compliance costs for smaller managers is not worth sacrificing transparency and public accountability. I do not consider the manager of a 3.4 billion dollar hedge fund to be 'small'
The SEC is supposed to fight for and enforce transparency. This is not the time to change.