July 30, 2020
I am an investment advisor serving individual investors and I think this proposal does a huge disservice to these average investors. The SEC should be increasing transparency with things like increased disclosure around short positions rather than decreasing transparency by making the threshold for 13F disclosure so high. This proposal saves a trivial amount of money and puts individual investors at a major disadvantage because of the reduced transparency and I strongly exhort the Commission to not make this change (and, if anything, to increase disclosure around short positions).