August 24, 2020
I am opposed to this regulation change.
The 13F filings provide incredible value to small investors who the SEC is hoping to serve. Financial literacy is growing exponentially due to transparency of financial disclosure and digital accessibility. The 13F filings help investors conduct their market research. Increasing the minimum to $3.5 billion will eliminate most of the professional investors that I follow - great investors who intentionally limit the size of their investment portfolios. If this change is implemented, professional investors like Guy Spier, Mohnish Pabrai and Allan Mecham would all be excused. It is an immense boost of confidence to individual investors to see that several professionals bought a stock that they are interested in. I rely on small institutional investors for the best sort of guidance in the stock market and would sorely miss this information.
As an indication of how beloved these filings are, entire websites are dedicated to these 13F filings like Gurufocus.com, Dataroma.com and WhaleWisdom.com. Gurufocus.com alone has over 500,000 unique visitors a month seeking this information.
In the 1970's when this regulation was put in effect, the purpose was to disclose portfolios that could move the market to the benefit of other large investors. Today, things have changed. The little guy is looking for more disclosure (and transparency), not less.
Now this data is also used by millions of small investors to improve their investing results. The 13F data for portfolios between $100 million and $3.5 billion is the sweet spot for small investors and we hope you will see the value in keeping this requirement in place.