Subject: File No. S7-08-20
From: Mark Pedroli, Esq.
Affiliation: Pedroli Law

August 30, 2020

The United States has been a proponent of transparency in international capital markets for decades. This proposed rule change represents backsliding and a disconcerting drive for more opacity.

Transparency in capital markets is more important than ever, particularly as it involves the interplay between financial investment, government and lobbying. Transparency in capital markets, most importantly, can reveal potential conflicts of interests both domestically and internationally. Capital pools can take equity positions and then lobby government/s to advance their positions through regulatory change, enforcement against competitors, trade deals, foreign policy and even war. Hedge funds in the United State already have a well known track record of lobbying governments to affect their investments.

Americans should know the motives, and particularly the financial motives, of all financial influencers.

Capital funds can also lobby foreign governments and, importantly, lobby the United States on behalf of foreign governments. Americans, the governments themselves, and the capital markets will operate more efficiently when these motives cannot be hidden from public view.

Mark Pedroli, Esq.