July 14, 2020
In relation to the proposed revisions of reporting requirements, it strikes me that the rationale being put forth for this change makes little sense. As a former employee of an asset manager that filed 13Fs, I can tell you that the cost burden is completely inconsequential.
Further, as an instutional investor that invests with various investment managers that offer varying levels of transparency, I can state for certain that we would no longer be able to diligence our managers nearly as well without the use of 13F data. There is simply no other source of information that provides us the ability to rigorously screen our investment managers' activity.
Regards,
Chris James