Subject: File No. S7-08-20
From: Johnny Wurf, Attorney

September 7, 2020

The world looks to United States as role model for transparency and governance.

Could you imagine China opening to the world with such transparency and scrutiny with this level of assurance.

This drastic rule change with an astonishing lift in the threshold may be designed to 'protect' a privileged minority, however, it would further undermine American leadership in the world, this time in people's confidence and conviction.