November 11, 2020
I wish to be Anonymous because it does not matter who I am but rather what I do that defines me. Going from a threshold of 100 million to 3.5 billion is to large. I understand the reasons behind why 13f was created in the first place, I understand why the small manager has compliance costs and why they would want to be rid of them. However the aforementioned increase is to large, perhaps a middle ground compromise is in order. The uses of the 13f have evolved as the data points increased and this has had many unintended positive consequences. To eliminate so many small managers from the data points would eliminate all those positive consequences and findings. I understand the simple fix yet hard decision would be to raise the gate, but the question you pose is more complicated than that. That is why I propose amending 13f as you have stated while creating another separate filing that can cover the smaller dollar figures and smaller managers. A separate filing that can be much simpler, less comprehensive and less expensive. Certainly if the SEC can amend the forms then certainly they do not need congress to create a new one for them. The new filing could be called form \"13s\" homage to the 13f with the \"s\" standing for \"small\". Thank you for reading.