September 25, 2020
As an active retail trader and a business owner, I find current requirements for institutional traders with account values over $100M to report their holdings on a quarterly basis invaluable to my investment decision making. Forms 13F have been consistently included in my research and decision-making process.
The SEC's proposal to change this rule in an effort to lessen administrative burden on smaller managers would be a mistake. Fund managers holding between $100M and $3.5B in assets under management are not "small" as the SEC call them. I am a small trader and a small business manager.
These funds have plentiful resources to prepare such forms. And preparing them is just the cost of doing business. If every American has to pay taxes or be "burdened" to file his or her tax return, then fund managers in charge of $100M and more certainly should be required to report their holdings.
This is not about administrative burden or costs. It is more about accountability and transparency. I believe there should be more transparency - not less. Traders and investors from all over the world want to participate in our financial markets because of the transparency and plentiful information about public companies or funds available to them for research via the SEC. Please keep it that way.