July 16, 2020
As an individual investor, I am AGAINST raising the reporting threshold. Individual investors are already at a disadvantage when it comes to talking to company management. Reducing the access we have to institutional holdings data puts us at an even further disadvantage. This rule results in LESS transparency, and LESS data which does not benefit anyone.
The justification of reducing the cost burden on money managers does not hold water. I used to work for a smaller RIA and helped compile our 13F filing. It is really not that difficult to create a list of holdings within 45 days of quarter end. The proposed cost "savings" seem grossly overstated.