July 15, 2020
Raising the reporting threshold from $100 million to $3.5 billion is going to severely limit transparency and as a result impact price discovery and further lead to market mispricing and irrationality.
Lack of transparency will most affect individual investors who, at times, look at "smart money" institutional flows as part of their due diligence. Removing this will contribute to further the divide between "haves" and "have nots".
One of the SEC missions is to protect investors. This rule does the opposite, especially for the self directed retail investor.