August 15, 2020
Increasing the AUM threshold will negatively impact smaller market capitalization public companies. As a CFO of a small cap company, I would review 13F filings each quarter to understand the makeup of our company's shareholder base, which was dominated by firms with far less than $3.5 billion AUM. This information was tremendously helpful for investor communications and, ultimately, helped the company raise capital to grow the business. Increasing the threshold to $3.5 billion AUM would greatly reduce information available to public company CFOs, who rely on reporting by smaller investment managers for shareholder communications and fundraising.
If you insist on raising the minimum reporting threshold, then I would strongly advise taking a smaller step, such as $500 million AUM. Any investment firm with this level of assets would have sufficient resources to meet the reporting requirements, which are not particularly burdensome in any case.