February 12, 2022
The proposed abbreviated time frames in which to submit reports, and the associated requirements, would pose an undue burden on small firms. There should be a AUM hurdle for the shortened time frames, particularly for the 13D. the fact that my firm, for example, holds $50K of a NYSE stock is a total irrelevance to the market. Perhaps the new time frames should apply only to firms with over $5 billion in assets.
Like all government agencies, you are good at requiring things of your unwilling \"customers\" that you are unable or unwilling to do in return. When was the last time the SEC (or the IRS etc.) responded to a \"customer\" in 5 days? Equally, requirements for special filing technologies is a burden on small firms that are trying to devote their energies to serving their clients.