July 22, 2020
Raising the threshold form 100 million to 3.5billion will render the reporting effective useless. A large number of hedge funds are under the 3.5billion threshold and therefore small and individual investors such as me will no longer get information on who owns what.
Secondly, for an organization or institution that raises and invests / manages billions or even several hundred million dollars, quarterly reporting should not pose any significant cost or burden.
Thirdly the proposal does not quantify how much the cost savings and expense reduction on the SEC side will be at what threshold. For example, at thresholds of 200M / 300M/....1Billion and so on, the potential reduction in SEC costs including number of jobs that will be reduced, should be published to enable an objective decision on this.
Finally, if an institution does not have appropriate technology and controls implemented to be able to file the required quarterly reports, whether 100M or 3.5B the threshold be, that institution is not fit to be in business. The proposed change will shield such instiutions.
SEC MUST strive for more transparency in order to regulate and protect the investors. The proposed change reduces the transparency as described and therefore should not be approved.