September 4, 2020
Ingredion opposes the Form 13F reporting proposal changing the reporting threshold from $100 million in equity assets to $3.5 billion in equity assets.
The change in reporting threshold would result in a decrease of market transparency, which is critical in our ability to effectively manage our investment community. Similar to many others, we utilize the current reporting results to identify prospective investors, as well as opportunities to engage further with long-term investors. As a company, we depend on the quarterly 13F reports and they have become an integral part of our Investor Relations program. The movement of ownership between quarters has proven to be fruitful in our analysis of shareholders. With the proposed change, the reporting limitations and reduced transparency would conflict with our objective(s) of effectively engaging with existing and potential shareholders. As a result, we oppose the changes in the Form 13F reporting proposal.