August 26, 2020
I am opposed to this regulation change.
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 smaller investor is looking for more disclosure, not less. Now this data is also used by millions of small investors to improve their investing results.
The 13f filings rule as it stands is an incredible benefit to the smaller investor who uses it to reduce the cost and time put into stock research by being able to evaluate professional portfolios in a timely way.
To be able to see what percentage of the pro's portfolio went to that stock ... and at what price ... is an incredible benefit to the smaller investors that the SEC is hoping to serve.
Millions of small investors are becoming financially literate because of a revolution of financial information disclosure on the internet. Please do not remove one of the best sources of information about what the best institutional investors in the world are doing.
Increasing the minimum to $3.5 billion will eliminate most of the pro investors we follow - great investors who intentionally limit the size of their investment portolios - pros like Guy Spier, Mohnesh Pabrai and Allan Meecham, all of whom will be excused from filing by this change. We 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.
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.
Sincerely,
Melissa Cogdill