August 29, 2020
Dear Sir/Madam,
I'm writing to express my strong opposition to the proposed rule change S7-08-20 that would significantly raise the minimum reporting threshold for investment managers.
13F filings are a key source of information for many investors around the world. They provide transparency and increase trust in the US capital markets, the largest and most important in the world. Furthermore, research has demonstrated that such filings improve market efficiency and price discovery, helping to direct capital flows to the most productive investment opportunities.
Raising the reporting threshold would significantly reduce the level of information available from smaller funds, which are some of the most important as they can invest smaller amounts of capital in smaller/mid sized companies that are the innovators and leaders of tomorrow.
I am strongly opposed the proposed rule change and urge the SEC to retain the current $100M threshold for reporting to ensure that the American capital markets remain the largest, most transparent, and most productive in the world.
Thank you for your consideration.