July 23, 2020
From the SEC.gov website, the mission of the SEC is to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation, but in the discussion of the proposed rule to raise the filing threshold for Form 13F, there was almost no discussion of the value of Form 13F for investors, in providing transparency regarding investment vehicles. Transparency is important to protect investors. The need for public disclosure of holdings for medium-size fund managers is to enable investors to evaluate investment alternatives. Raising the filing threshold to $3.5 Billion would eliminate the filing requirement for three-quarters of currently-filing fund managers, leaving investors without this important disclosure to evaluate the majority of their investment alternatives. It is hard to see how this action protects investors.
If the burden of Form 13F filing is perceived to be a burden to small fund managers, raising the filing threshold to $350 million, in line with inflation since the previous threshold was set in 1975, could be justified, rather than elevating the reporting threshold to the proposed $3.5 Billion and effectively eliminating this requirement for the vast majority of managers.