August 2, 2020
This rule should be rejected. More transparency not less is essential for the markets to function.
$100 mm threshold was arbitrarily set at the time to include as many firms as possible without overburdening smaller firms. To index it to $3.5 billion is inconsistent with the original intent and spirit of the rule.
Reporting should be more frequent, since funds are valued more often. Data should be more complete data on holdings than what is required today. Technology is vastly better and can be done at lower cost than at time of original rule.
More transparency enables a better view of market activities and peer comparisons by investors. This is a matter of serving investors properly. They pay the freight for services and should be able to expect transparency.
Smaller firms tend to have more problems and more disclosures are warranted to protect investors.
I can't imagine any argument that could justify less transparency. It is a shame this is even up for discussion.