Subject: File No. S7-08-20
From: David Simons

July 27, 2020

The rule change which allows 90% of asset managers to avoid delayed publication of their holdings in public equities is not in the interest of all participants in the financial markets.

The only party who benefits is the asset manager itself which can secretly trade in and out of equities. Secrecy is bad for price discovery and can thus lead to less trading and wider spreads. This hurts amongst others the lay man who invests for his or her pension, either via a 401K, IRA or corporate pension fund.

The cost for asset managers to comply is negligible as it is automated. As a percentage of the total cost of compliance, it can not be more than 1% - this is not material.

Concluding: the benefit to society strongly outweighs the negligible cost to comply with the reporting requirement.