Subject: File No. S7-08-20
From: Robert H. Lewis, Esquire

July 27, 2020

The proposed rule 13F is typical of what government agencies do when it is looking for something to do. It adds to changes limiting the public's information relative to public investing. Seriously, what is this proposed rule do which is good for the public investors? It seems it does exactly opposite of ruling for transparency which is what the Commission should be doing. It takes away valuable information to individual investors. Does the Commission want to do that? Why take away anything which may be of help to the American public. It the Commission was trying to cover up some of its rules or actions, it would be understandable. That's what governmental agencies do but not here. It serves no purpose for the Commission.

Who asks you to invoke this rule change? Why was the request made? How does someone profit from it? If no one made the request, from where did the proposed rule come? Why pass the rule change? It does nothing but cut drastically the public's access to information which is beneficial to it. Speaking bluntly, it makes no sense and harms the American investor. Is it just another example of bureaucrats making a decision which is harmful to the public investor and but make the Commission appear its doing something beneficial to a rule when very few people even know about the rule or a change to it?

Unless the proposer(s) can give a definitive reason for passage, it should be discarded unanimously.