July 16, 2020
Raising this reporting threshold dramatically hurts the retail investor by reducing transparency into holdings (90% fewer funds will have to report). This only serves to benefit mid-size institutional investors at the expense of the everyday retail investor. Especially in a time of economic uncertainty, such as this global pandemic, the market is undergoing unprecedented volatility. By reducing transparency into 90% of currently-reported funds holdings, this only serves to increase that volatility. These institutional investors can drive the price of securities up, dump their holdings, and leave the retail investor holding the bag. I urge you to reconsider this ruling.