July 27, 2020
I am commenting personally and do not represent the interests or opinions of Zurich.
I do not agree with your proposal to increase the limits for institutions from 100 million to 3.5 billion. Simply put, more information for the public and more transparency is always better. This proposal would eliminate the reporting requirement for roughly 90% of institutional managers that are currently required to report their purchases quarterly. Please do not change the reporting threshold.