July 24, 2020
As a small investment firm looking to increase the use of ETFs in client accounts, the reporting requirements under form 13-f are onerous and a possible reason to not use these securities in client accounts. Any trading activity by our firm has no impact on the investment markets given our small relative size. With small firms like ours, the cost of filing form 13-f would be significant either by requiring our principles to dedicate the time to complete or to hire an outside firm at a significant cost (relative to our revenue).
As a CFA Charterholder I fully support as much transparency as possible, but I also firmly believe smaller firms who are already at a disadvantage to Wall Street firms are significantly more disadvantaged by the very low threshold currently for form 13-f filings.
We as a firm fully support the proposed changes as a way to decrease costs to smaller advisors so they can better help under-served investors.