July 15, 2020
The proposed changes to increase the reporting threshold goes against the spirit of increasing transparency and trust in capital markets. In the CFA handbook, the text notes that "In order for capital markets to be efficient, investors must be able to trust that the markets are fair and transparent and offer them the opportunity to be rewarded for the risk they choose to take. Laws, regulations, and enforcement play a vital role but are insufficient alone to guarantee fair and transparent markets." This change would be a significant weakening in the vital role that laws and regulations play in increasing transparency. The book further describes, "Society ultimately benefits from efficient markets where capital can freely flow to the most productive or innovative destination." To go through with this change will be of great detriment to market transparency, and thus deleterious to society.