Subject: File No. S7-08-20
From: Duane Leonhardt

July 30, 2020

Raising the threshold for institutional investors does not serve the greater good for the majority of the investors now in the market.
While this limit would seem out of reason based on the original value in the regulation from so long ago, the market is a very different place now. There are many times more small investors both trading and also invested in many mid range institutions. Having the information on what these institutions are doing helps monitor the actions of their
fund and investment managers.
Transparency is key to keeping the market open, competitive
and trustworthy. This means knowing what institutions (managers)are doing and how their large trading power might affect their accounts.

if there is a logical reason for institutional managers to report at all, certainly raising the threshold to reduce the amount of reports by 80%+ only serves to restrict the market competition and confidence

Duane Leonhardt