Sep. 29, 2020
Subject: File No. S7-08-20 From: Christiano Gallo -------------------------- September 29, 2020 There are quite a few reasons why the reporting threshold should not be changed: - 13F filing costs for managers are negligible - It's hard to front-run someone 6 weeks later - It will become harder to understand what smaller managers are doing - Drastically reduces transparency and limits future academic research - Investors and companies won't know the shareholder base - Proposal goes against original 13F goals SEC's own mission to protect investors maintain fair, orderly, and efficient markets and facilitate capital formation. In short, the negatives far outweigh the positives.