August 13, 2020
Members of the SEC,
I understand you are considering raising the threshold for 13F reporting from $100M to $3.5B. I believe this is not in the best interest of the SEC or individual stockholders. My understanding is that this will effectively reduce 13F submissions by about 90% - how does this fit with making the SEC and investing activity more transparent when suddenly 90% of the visible activity would be hidden if this is passed?
As an individual investor, I rely mostly on some investment advisory services to analyze stocks and make recommendations, but review their research myself to better understand how the process works. By removing 90% of these large market movers it will negatively affect my investment decisions and that of a host of other smaller individual investors trying to make wise choices in a sometimes chaotic market.
I also understand that the 90% of the market movers that would be removed from the 13F filing requirement have access to company managers and would be able to obtain information that us smaller investors would not have. To do this at a time when many are protesting over the have elites verses the no have little guys would seem to me like trying to put out a fire with gasoline. You would only make things worse by doing so.
The purpose of government is to help keep the process honest and transparent to the maximum extent possible. This rule change would do the opposite of that. Once faith is lost in an institution, it is extremely difficult to gain it back. I therefore urge you to drop this consideration for if nothing else maintaining the integrity of the SEC as a fair arbiter of the market and its participants – regardless of the wealth level.
Thank you for your consideration of my opinion on the matter.