Subject: File No. S7-08-20
From: Dale A Wark, CPA
Affiliation: AICPA, PICPA and CFMA, retired and inactive

July 27, 2020

I don't see this rule change as "increasing transparency", which I thought both the SEC and President Trump were stressing these days. Further, this almost removes and certainly weakens a tool that many retired, individual investors use to gauge their investments. Wall Street and large institutional investors already have tremendous advantages over small investors like myself - and my investing results determine our financial well-being. My wife and I cannot afford investment losses that Wall Street banks, investment firms, and institutional investors can absorb.

My preference would be to leave the rules as they presently exist.

Best regards,

Dale Wark