Subject: File No. S7-08-20
From: Charles T Cassidy

July 30, 2020

I am a retired financial services executive. I worked in the institutional financial services industry for over 40 years with organizations like State Street and Cambridge Associates. I ran securities operations businesses in the U.S. and globally and dealt with clients including central banks, pension funds, mutual funds, hedge funds, foundations, and endowments. I was a contributor to the Principles and Practices for Hedge Fund Investors and Managers of the President's Working Group on Financial Markets Investors' Committee of the U.S. Treasury in 2008/09.

As a major allocator to hedge funds I watched and discussed with numerous industry participants the efforts to effectively respond to 13-F. It was not an easy exercise for the industry. There were many, many industry groups and significant efforts to ensure that the reporting was accomplished accurately. The administrators, auditors, custodians and prime brokers were all involved in these efforts. Ultimately workable and efficient solutions were developed and apparently have worked smoothly since. As a result investors have access to better information to be able to evaluate, monitor, and ultimately understand and verify the activities of investment managers.

To eliminate this useful and valuable tool would do a disservice to investors while not providing any meaningful benefits to the industry as a whole. Readily available, accurate, regulatory mandated and monitored data is an incredibly useful tool in the arsenal of investors as they monitor investment managers.

Charles Cassidy