July 14, 2020
Proposed rule change S7-08-20 is a stunning and farcical attempt to change reporting requirements that have served public market investors adequately since inception. To eliminate 90% of required fillings would undoubtedly hinder broad market transparency and oversight of individual managers, all at a seemingly nominal (if at all) cost savings to managers and the SEC, and with zero reasonably estimable and direct benefit to investors/clients. This proposal DIRECTLY contradicts SEC mandates to inform and protect investors, ultimately inhibits ability to enforce security laws, and significantly reduces data available to "Main Street" investors. When and on what planet is less data a positive for market participants, particularly American households which, according to the SEC, own $29 trillion of equities, or 58% of the market? Simply put, the proposal is a structural failure on the part of the SEC to protect market integrity for investors.
The proposal must be withdrawn.