July 14, 2020
I am writing to express my opposition to this proposed rule change. As I was learning about markets and investing my savings before eventually entering the financial industry, access to filings of holdings from various investors was an invaluable tool for me to develop my own understanding of markets. Giving small investors access to this information helps to level the playing field in markets by allowing them to see where the smart money is and reverse-engineer the theses driving these investments. This helped me a lot early in my career, and continues to be an important tool for many individuals who play the markets. Cutting this out reduces transparency in an industry that is already short in that department, for a minimal cost savings. I could see raising the threshold slightly, say to $100mm, but raising to $3.5Bn would exclude a huge number of sizable and important firms from this requirement and should not be done.