September 19, 2020
To whom it may concern:
I run a small financial advisory business. If this rule is enacted it will hurt my small business and I'm sure many others.
The 13F is a great way to do additional due diligence on possible investment managers. For instance, if I'm interested in investing with a manager but their stated performance is dramatically different than what the 13F would seem to indicate, it creates a reason to dig even deeper into the manager. It also allows me to verify (at least in a small way) their overall performance and to make sure there isn't things like style drift. It also allows me to understand their investment process better so that I can make better decisions.
I am very against this change as it makes the market less transparent and will have an adverse effect on small advisory businesses.