Jul. 16, 2020
SEC, The proposal S7-08-20 would be a drastic step in the wrong direction and I vehemently oppose this proposal. This action would obscure over $2 TRILLION in investment holdings and casts a large shadow over the small-to-micro-cap investments. In those markets, $3.5 billion in investments can mean tens of billions in shares which can cause massive swings in stock prices and be devastating to the individual investor. This action moves in the opposite direction of what should be the norm in financial markets - transparency and availability of key data. As someone who works daily with massive amounts of data, I have an appreciation for simplifying down to relevant data. However, just because a data set isn't 100% relevant 100% of the time doesn't mean it should be completely excluded or ignored. With modern technology, quantity of data is less of a problem because data management tools are available to reduce the burden of gathering, organizing and digesting data. The argument that the number of filers has increased from roughly 1000 in 1979 to roughly 5000 present day is a poor justification for increasing the threshold. The American population (per census data from 1980 and estimates for 2020) has increased by roughly 110 million people in the same time, so the number of filers should increase. Additionally, the increase in market value of publicly traded equities is a flawed argument. Based on the graph provided in the proposal on market value (pg. 11, Fig 2), the market value has increased roughly $20 trillion since 2006. This is heavily weighted by several of the top-valued companies in the US. For example, since 2006, Microsoft (MSFT) and Apple (AAPL) combined represent approximately $3 trillion of that increase. That's just two companies! Add in several of the other largest cap companies and you'll quickly get to $10 trillion with just a handful of businesses. I urge you to strongly reconsider this proposal and decline enacting this policy. The detriment to the common investor will be vast and drive more of the large investment business into obscurity. Regards, Eric I, a concerned investor