July 14, 2020
I believe increasing the threshold to 3.5 billion or greater reduces much needed transparency and confidence to investors and am
strongly against it. If the spirit of the rule is to reduce unnecessary filing costs for smaller managers perhaps increasing the threshold to a more reasonable level of 500 million or so
Is a happy medium. Not disclosing this data eliminates the ability for broad based future investment research, provides less transparency for investors and money managers. Understanding who are the largest owners of a given stock provides much needed information. This rule has been in effect for many years and has only added value and with todays technology tools, compliance reporting costs are going down not up. It would be a shame to reduce transparency as markets are getting larger and more widely owned.