Subject: File No. S7-08-20
From: LARRY A KOEHLER, KOEHLER

July 28, 2020

Exactly WHO do you (SEC) think believes your supposition that increasing a sensible $100M benchmark to a $3.5Billion one to Report 13F Holdings would increase TRANSPARENCY?? That is BLATANT misrepresentation and where misrepresentation is found, dishonesty and malfeasance are promoting it. Why wouldn't the average citizen, not to mention the average investor, connect all those dots and the "corruption" light bulb not shine bright? It is time the SEC Commissioners be replaced. In this stark historical time of impending financial crisis or worse, disaster, from the Covid-19 virus, this is a particularly vulgar proposed rule change to the current 13F guidelines and expectations.