Subject: File No. S7-08-20
From: Michael Shorenstein
Affiliation: Investment Advisor

July 23, 2020

The costs for funds to comply with this are relatively trivial compared to the vital transparency the current threshold provides. Furthermore, funds should begin to disclose short positions with 13Fs. There is no incremental expense or burden to disclose these positions. Transparency is critical to the functioning of markets and reducing that is a terrible idea.