August 11, 2020
I do not think the threshold should be increased. Below are some comments:
a) The time required and associated cost to file this form is trivial to managers. All they need to do is consolidate their brokerage statements and submit the form. They already do need to consolidate this information to update their clients quarterly and the additional work to file the form is close to zero.
b) The 13F filing threshold was not modified in 45 years. So, one has to wonder why there is now a proposal for the increase from $100M to a whopping $3.5B in one step. Who is to benefit from doing this? As the regulatory requirements are minimal for hedge funds, an argument can be made that the threshold should be lowered so that this minimal regulation applies to more managers.
c) As part of the 13F regulation is aimed at protecting the American public from risks associated with hedge funds, any modification in the filing threshold should be done in conjunction with several other minimums associated with the 1933, 1934, and 1940 Securities and Investment Company Registration Acts. For example, if the threshold is to be increased 35-times from $100M to $3.5B, the "accredited investor" minimum should also be increased from $1M to $35M.