July 26, 2020
Hello,
As a retail investor, I strongly oppose the amendments to update Form 13F for Institutional Investment Managers. This change is unnecessary as there is no financial "burden" on small to medium hedge fund managers in filing these quarterly forms given the average profits of hedge funds. Also, the idea that it will reduce "copycatters" is invalid since fund managers are allowed to wait 45 days until filing so short-term strategies are safe. To add, fund managers are only reporting long positions, shorts are not included. President Roosevelt and Congress created the SEC to increase transparency and investor confidence, not reduce it. This proposed change can also encourage activist hedge funds to "go dark" and make it more difficult to determine who owns stake in a company. If we want to account for inflation, the $100 million threshold could be increased to $400 million or less, not $3.5 billion. Bottom line, this change will only help hedge funds (who don't need the help) and hurt individual retail investors. The public deserves to know who owns what, as it has been for over 40 years.
Kind regards,
Jason Miller