July 14, 2020
I am writing to express my view that a $3.5 billion reporting threshold is far too high. Although I can appreciate a $100mm threshold might be burdensome for small managers, by the time a manager reaches even $500mm of assets, that manager is typically quite profitable and quite capable of adhering to quarterly filing requirements.
To raise the reporting threshold to $3.5 billion deprives individual investors like me the opportunity to see which types of investors are driving stocks up and down. Institutional investors are able to get color from broker-dealers, but individual investors have to rely on freely available data, such as SEC filings. A much higher reporting threshold only serves to increase the information asymmetry between institutional and individual investors.