August 21, 2020
This is a terrible proposal. The Commission should be focused on increasing disclosure, not decreasing it. Funds would save a relatively trivial amount of money but small time investors and Advisors like myself would be substantially disadvantaged. I find it can be very helpful to know what sort of investors I am investing alongside with when I buy stock in a company and this proposal eviscerates that. The Hedge Fund community will still be able to talk amongst itself about positions they are involved in but everyday investors like myself will be out in the cold. If anything, the Commission should be increasing transparency by reducing the AUM threshold and mandating disclosure for short exposure. The current proposal is the exact opposite of what they should be considering.