Sep. 30, 2020
Subject: File No. S7-08-20 From: Ankur Modi -------------------------- September 30, 2020 This proposal would result in a terrible loss of market transparency for individual investors like me. How could you even be considering reducing disclosures by large investors with the potential to move markets? Compliance costs to file a 13F are negligible to a $100 million fund, which is the minimum size required to report. 13F's are a critical source of information to market participants on the holdings of the largest investment managers that provide insight impacting my individual portfolios. They do not put funds at any disadvantage given the 45 day period that elapses before filing 13-F's after the end of each quarter. Instead, you are seeking to remove important information from individual investors and academics at a time when you should be seeking to improve transparency to protect individual investors. I strongly encourage you to keep the current rules intact and not adopt rules that reduce disclosures by key market participants.