September 8, 2020
I am opposed to this regulation change.
The 13f filings rule as it stands is an important source of information to the average investor who is trying to learn how to responsibly invest in stocks. The professionals who currently are required to file 13f filings have access to more elite business people, business meetings, more education, and other experienced professionals than the average investor. The 13f filing requirement helps to narrow the gap between the average person and investors who have attended expensive, elite business schools. These pros, who already have access to lots of capital, not only had access to a costly education but also were able to build up networks to gain more information. The 13f filings help broaden this information to more than an elite few. Being able to see what percentage a pro bought a stock, in a price range, gives the average person access to information that would come up in professional conversations in elite circles that have restricted access just by virtue of who you know.
If you care about the wealth divide getting larger, please do not remove one of rules that helps to make access to information more equitable, information about what the best institutional investors in the world are doing.
Increasing the minimum to $3.5 billion will eliminate most of the pro investors I follow, such as Guy Spier and Mohnesh Pabrai, both of whom will be excused from filing by this change. Because I do not have access to a highly successful investor to learn about the stock market, I rely on small institutional investors for the best sort of guidance in the stock market.
Sincerely,
Erin S Edwards, PhD