Subject: File No. S7-08-20
From: Shelley Gould
Affiliation: Accionet LLC

September 28, 2020

raising the threshold to $3.5B does NOT help with the market transparency that is sorely needed in our markets. You have much more retail investor participation and this bias'es the market in favor of the institutions vs. the retail investor. Why are you making it less transparent? If the workload is so great, why aren't you instead investing in machine learning/AI so you can auto-flag the red flags in these reports? That's all progammable and that's where SEC resources should be dedicated to.

If anything just raise it to $300M or $500M. But please, not $3.5B. PLUS -why are they given a quarter before having to report? ARK ETFs are reporting daily their trades to anyone who signs up. Why isn't that a mandatory requirement across all institutions?

Regards,
Shelley