Subject: File No. S7-08-20
From: Daniel Palmer

August 17, 2020

The proposed rule change would limit transparency in a world where most can agree that more transparency is better.

A higher threshold could potentially increase the number of reporting periods that lapse before an investor has to file as a position is built. The delay in reporting leaves the opportunity for a manager to gain significant influence over a company in the dark to the public for an extended period of time.