August 19, 2020
I do not support this regulation change as this change affects small investors who uses these information to reduce the cost and time put into stock research. Many small investors like me are becoming financially literate because of the revolution of financial information disclosure on the internet. Increasing the minimum to $3.5 billion will remove most of the great investors that small investors follow such as Mohnish Pabrai etc. whom limit their size of portfolios as part of their investing strategy.
When this regulation was put in effect, it was to disclose portfolios that could move the market to the benefit of other large investors. However things have changed and small investors use this information as part of their research to improve their investing results. The 13f data for portfolios between $100 million and $3.5 billion is the sweet spot for small investors due to the size and we hope SEC will see the value in having no change to the current regulation.
I sincerely appeal SEC to re-consider the need to change this regulation. Thank you very much.