Aug. 24, 2020
From: Albert Gutierrez Date: Monday, August 24, 2020 at 8:11 AM To: "rule-comments@sec.gov" Subject: File Number S7-08-20 Raising the minimum AUM for managers to file Form 13F from $100mm to $3.5B is WAY OVERDUE. Capital Markets have drastically changed since the rule was put in place in 1975. Trading has become far more efficient, there are more market makers, and volumes are enormous. We manage less than $1B and all of our transactions within the context of 1 penny bid/ask. Any prudent manager our size that has diversified holdings for their clients results in aggregate holding for one stock that is miniscule within the scope of the marketplace. We support the need for disclosure and transparency, but asset managers of our size have almost no impact on market liquidity or percentages of Large Capitalization corporate stock ownership. I recommend the Commission adopt such a change. Thank you. Albert Gutierrez, CFA Partner - Atlas Capital Advisors LLC 38 Keyes Ave, Suite 200 San Francisco, CA 94129 w: 415.494.8358, c: 415.846.3397 f: 972.466.5157 bert@atlasca.com Opinions and statements of financial market trends that are based on current market conditions constitute our judgment and are subject to change without notice. We believe the information provided here is reliable but should not be assumed to be accurate or complete. The views and strategies described may not be suitable for all investors. If you are not the intended recipient of this electronic message, please do not disseminate, copy or take any action in reliance on it. Unless specifically indicated, this e-mail is not an offer to buy or sell or a solicitation to buy or sell any securities, investment products or other financial product or service. All e-mail sent to or from the Atlas Capital Advisors LLC e-mail system is subject to archiving, monitoring and review by regulators or Atlas personnel.