July 29, 2020
Please do not change Rule requiring institutional money manager with more than $100 million in assets under management to file a 13F document detailing their holdings.
The proposed Rule Change would reduce 13F document filing to only a handful of institutional investors with $3.5 billion in assets under managment. The proposed rule-change will greatly reduce information transparency which is detrimental to the public interest in knowing how institutional investors are investing. In fact, the proposed rule-change would reduce the number of institutional investors filing 13F from 5,290 to 549. That is a 90% drop in 13F filings which, in turn, means 90% less information available to the public. That huge loss of information would create more uncertainty and make it more difficult for the public to invest wisely.