August 5, 2020
I applaud the agencys desire to create efficiencies for investors that is behind the proposed rule to increase from $100 million to $3.5 billion the investment above which Form 13F would be required (S7-08-20). However, from management and an issuers perspective, this would eliminate an important accountability on investors.
As manager of a well performing bank with a thinly traded stock, we have to make decisions for the good of shareholders and customers over the long term that could be easily influenced by investors with individual motivations due to our lack of liquidity and large base of retail investors. Knowing our institutional investors and keeping them in the loop as we pursue and update strategy is critical to our shareholder relations program. The vast majority, if not all, of our current institutional investors find this relationship helpful.
Perhaps an increase to the current $100 million limit is appropriate due the passage of time, but please continue reporting requirements so that the majority of Form 13F reporters today continue to have this accountability and relationship with small company issuers in the future. Thank you.