July 28, 2020
The proposed rule change will exempt almost 90% of institutions currently required to file Form 13F. This move is 180 degrees opposite the SEC stated objective to increase transparency into markets.
Institutional funds trade in quantities that move markets in ways that have a huge impact on small investors. Institutional money managers have access to executive management, and company data, not available to small investors. Eliminating reporting for the vast majority will severely harm small investors insight into he market.
Please leave the reporting threshold unchanged.