Subject: File No. S7-08-20
From: Michelle H Rand
Affiliation: CFA Institute, member

September 3, 2020

We support the increase in the reporting limit for the 13F filing, to which we are subject. We believe that our asset size is not material given the size of the markets today, and frankly, the publication of our 13F only provokes multiple contacts from vendors wanting to sell us services that we do not want or need.

Our clients are able to access our holdings by simply asking us for lists of securities we have purchased or sold, at any time.

The opportunity to shed this requirement would free our staff up for other duties, including investment management, other regulatory duties, client contact, and so forth.

Thank you.