July 14, 2020
The proposed changes are questionable and will undoubtedly have a negative effect for the investment community. There is a marginal, if any, benefit to reducing the filing requirements and notably a number of managers with AUM over $100m at present have access to a wide net of investors who rely on the filing information.
The proposed changes can only increase the dominance of a few select firms with access to management of filers, and as a result reduce competitiveness, to the detriment of investors and firms.
Additionally this decision would be a move away from the harmonisation to European reporting requirements and international standards of best practice.
I feel that this change to reporting requirements is against the grain and the trend towards improving the transparency and access of information, as well as being a poor decision overall for the investment community. It would appear that the lessons from the Global Financial Crises were not learnt.