Subject: File No. S7-08-20
From: Dennis George

July 27, 2020

The new rule proposes that the $100 million threshold be raised to $3.5 billion.
Buffett, Icahn and Ackman would still be required to file, as they are giants in the industry. But 90% of other institutions would not.
In the first quarter of 2020, 5,293 institutions filed 13Fs. Under the new proposal, that number would have dropped to 549.
It's not just a matter of seeing which individual star money managers bought and sold stock. Knowing if institutions are collectively buying or selling certain stocks is important information - and it's useful for companies to know who their shareholders are as well.
The strange thing is that the SEC claims it wants to increase transparency in the market, yet this rule will do exactly the opposite...
It will hide the transactions and holdings of all but the very largest institutions, keeping average investors in the dark about what the "smart money" is buying and selling.
Daniel Collins of WhaleWisdom says...
Many managers are known to talk among themselves, sharing ideas and information. They have access to company management that small investors don't.
Given the SEC's emphasis on a level fair playing field, this rule change makes no sense.
I completely agree.