Subject: File No. S7-08-20
From: Marc Lichtenfeld
Affiliation: Cheif Investment Strategist

July 23, 2020

This is as bad a proposal as I've seen in a while. It will save little money for institutions yet provide much less transparency for individual investors. Since when is less information better? The tiny benefits don't come close to outweighing the cost.

Please do not pass this rule.