August 6, 2020
Hello, I am a small investor. Congress passed the 13-f rule to better maintain a fair market for all investors. By raising the limits on this rule from $100M to $3.5B, you are defeating the purpose of the rule, and you are giving yet another huge edge to investment managers over the small retail investors. The costs for these money managers to file these reports are minuscule compared to the amount of money they are managing--they do not need relief--this is not a burden to them. Large money managers already have a huge advantage over small investors, and this will hurt market transparency. This will just create more wealth inequality in our society allowing the rich to get richer. Given this limit was instituted over 40 years ago, however, I would be in support of a more modest increase in line with the rise in inflation over this period, to $400M. At the same time, I would suggest you reduce the window for filing these reports from 45 days to 30 days, and change the frequency to a monthly basis vs. a quarterly basis. Given all the advances in computer technology over the last 40+ years, these money managers should be able to provide more timely reports to the public and at a much lower cost than they were 40+ years ago.