July 21, 2020
This proposal is a travesty for transparency. The Commissions should be encouraging increased disclosure of short positions, not reducing disclosure of long positions. The Proposal will make it difficult for Companies to verify that Investment Advisors (such as myself) are actually shareholders of the Company which means access to management will become even more challenging. The disclosure requirements are not particularly onerous. I would also like to see increased disclosure around short positions so that investors can understand which investors are incentivized to push a company's stock down.