July 14, 2020
Increasing the reporting thresholds is a very bad idea. This reduces transparency and provides less data to the general public about the holdings.
The reasoning behind the proposed change is the possible reduction in costs and burdens to smaller managers. This justification is nonsense. Several managers that file say it is a highly automated process that effectively costs nothing. The claimed cost savings are completely inaccurate.
This seems like an attempt to "hide" from the public. This proposal should not be rejected.