August 3, 2020
The proposed amendment to update Form 13F is not appropriate.
Keeping things transparent is "extremely" important to smaller investors and is not a burden to smaller money managers if adjusted for inflation to a $400,000 threshold instead of the proposed 35 fold increase of the stock market which would be completely unfair to smaller investors, especially without strong justification which has not been presented to the public.
This proposal is arbitrary and capricious and should not be implemented without soliciting comments from potentially impacted smaller investors and completing more robust studies to determine the appropriate cutoff point for the small money manager and impact to the ability of smaller investors to make informed investment decisions without this critical supporting information.
I sincerely hope this is not a big business plan (i.e. hedge fund mangers) to handicap smaller investors.
Thank you