Subject: File No. S7-08-20
From: Julie Davis

July 23, 2020

I strongly disagree with the change in threshold to $3.5 billion dollars. While $100 million might be too low, in accordance with inflation and other adjustments, the threshold should be $400 million. Raising it to over $3 billion leaves out too great a pool of investors free to do what they want with no oversight or transparency.