August 19, 2020
I am very opposed to this regulation change.
The 13f filings rule as it stands provides invaluable assistance to the little investor (me) who uses it to reduce the cost and time put into stock research. Being able to evaluate professional portfolios in a timely way allows depth and breadth to my research not otherwise available to me given my time and resources. I do not have a staff of trained researchers just me.
It affords confidence to me (and many other small investors) to see that several highly regarded professionals bought a stock that I am interested in. To be able to see the percentage of the pro's portfolio that went to a stock and at what price is an incredible benefit to me – and to small investors the SEC is hoping to serve.
Millions of small investors are becoming financially literate because of the revolution in financial information disclosure available on the internet. Please do not remove one of my best sources of information about what the best institutional investors in the world are doing.
Increasing the minimum to $3.5 billion will eliminate many of the pro investors I follow - accomplished investors who intentionally limit the size of their investment portfolios. Pros like Guy Spier, Mohnesh Pabrai and Allan Meecham, all of whose data will be lost to me (and other small investors) by this change. I rely on small institutional investors for the most applicable guidance in the stock market and would sorely miss this information. As an indication of how necessary these filings are, entire websites are dedicated to these 13f filings. Examples are Gurufocus.com, Dataroma.com and WhaleWisdom.com. Gurufocus.com by itself has over 500,000 visitors a month seeking this information. I use one or more of them multiple times every month.
The purpose this regulation when it was put into effect, was to disclose, for the benefit of other large investors, portfolios that could move the market. Today this data is also used by me and millions of small investors to improve investing results. I (the little guy) am looking for more disclosure, not less. The 13f data for portfolios between $100 million and $3.5 billion is the sweet spot for myself and many other small investors, and I hope you will see the value in keeping this requirement in place.
Respectfully
Don Smith