July 27, 2020
I agree with modernizing the forms to current reporting standards and technology capabilities.
I disagree with raising the minimum from $100 million to $3.5 billion. More information is better and more transparent than 90% fewer managers reporting
I understand the "financial burden" placed on filing 13F reports for managers, especially for the smaller managers.
By doubling the limit to $200 million, you will be providing a 38% reduction in the number of managers that have to file form 13F. This is a significant reduction of filers and will provide relief to those smaller firms you appear to be concerned about.
The modernization of the form should also provide relief on the costs of filing the form for the remaining 62% of managers.
Give the modernization of the form time to work and learn how much cost savings are actually produced before making any further changes to the limits above $200 million.
Thank you for your time and attention to this comment.