July 14, 2020
I think this rule is submitted to harm small investors with little or no value to fund managers.
1. It will reduce the chance for people to find raising fund managers
2. It will limit academic research and reduce market overall efficiencies.
3. It will reduce insights to public firms.
4. The rule is totally not fair to smaller investors.
5. The justification makes no sense. The saving is too small for an automated process that costs next to nothing.
6. Less data and less transparency are never good for the market and will lead to terrible outcomes.
Thanks
Roy