August 11, 2020
This proposed rule change is destructive to the SEC's mission of protecting investors and the integrity of capital markets.
Raising the reporting threshold is an unnecessary reduction in transparency without benefit to investors or capital markets. By the SEC's own admission, the rule change would eliminate the vast majority of filings, implying the rule is meant to benefit filers at the expense of non-institutional investors.
13-F filings contain valuable information for investor research and their availability on the SEC's website serves a public good of verification to materials provided by the institutions. Removing these filings is patently inconsistent with promoting transparency.
Additionally, the rationales for the proposed rule change are unconvincing. Namely, the true compliance burden this causes to managers and the mere possibility of front running are dubious given the 45-day delay that which filing is required and disclosed.