July 17, 2020
This proposal will seriously reduce transparency of SEC filings , something that goes against the direction of travel in the world generally.
It will mean that large investment firms and insiders can trade with each other without disclosure making the market very murky.
It will undoubtedly make retail investors lose confidence in the system and markets generally because they will rightly surmise that the stock market is for insiders and large funds only.
Ultimately this will depress the retail public's appetite for investment in the broad markets and risks becoming an own goal for the SEC.
If the SEC wishes to reduce the administrative burdens of the smaller 13F Filers it would be far wiser to reduce or eliminate the reporting requirements of the bottom 10% and monitor how this affects the broad markets, rather than eliminate 90 % of filers in one go and unnecessarily risk denting or eliminating retail investor confidence.
Confidence is all too easily lost and very hard to regain.