August 3, 2020
I consider this proposal a backwards step for the Financial Services Industry in the US as well as detrimental to the end consumer.
As CEO of a company that deals with 96 financial regulators from around the globe on a daily basis, it is to be pointed out that this proposal is also in the exact opposite direction of travel of other financial regulators.
On the 16th March ESMA lowered its notification threshold for short selling from 0.2% to 0.1%. Shortly thereafter the Italian Regulator CONSOB, lowered the minimum disclosure threshold from 5% to 3% of total shares for SMEs and from 3% to 1% for large companies.
As to the point from your proposal:
"We believe that increasing the reporting threshold would provide meaningful regulatory relief for smaller managers ... in terms of a reduction in direct compliance costs and indirect costs"
Technology has come a long way since 1975 and there are now off-the-shelf solutions available which support the automated creation and filing of the 13F report in a few mouse clicks. So to suggest that saving a few hours a year would be "meaningful" when combined with the detrimental loss of transparency is spurious at best.
Supreme Court Justice Louis Brandeis proclaimed "Sunlight is said to be the best of disinfectants" and therefore any decrease in transparency must be considered a step in the wrong direction.