July 31, 2020
Dear SEC Commissioners:
I believe it is unnecessary to raise the reporting threshold for institutional money managers. Such a change would reduce the money managers' trading transparency without significantly reducing the cost of the reporting. The institutional money managers have legions of MBAs and accountants with computers who can easily do this reporting so it seems to me a risible argument that the current reporting requirements are burdensome and costly. The reduced reporting would only tend to encourage managers to make even more high frequency trades and engage in a larger number of speculative investments thus amplifying market volatility.
The bottom line: A bad rule will be bad for the markets. Please reconsider abandoning this proposed rule change.
Thank you for your consideration.