Subject: File No. S7-08-20
From: Richard Kunz

August 3, 2020

This rule change should not be adopted. The threshold for reporting is far too high and would only have negative effects on normal investors. I agree that the standard threshold should evolve, but not anywhere near the level of this possible change. The burden of reporting is not in any way onerous and helps keep firms' actions open and visible to the public which is as it should be. Either keep the existing threshold or index it directly to inflation, not blow it up to an incredibly large figure.