Feb. 22, 2021
Dear Madam Chairwoman, My name is Charles Morris, and I have been in the investment business for over 30 years. My career has spanned large investment firms (T. Rowe Price), venture firms (Integral Capital Partners), and hedge funds (Greenhouse Funds). During the 1990s, I managed the largest technology mutual fund in the world, the T. Rowe Price Science & Technology Fund. I would like the Commission to consider making two changes in the required filings for 13G/As and Form 4s. With respect to 13G/As, could we please add a line item in the filing that clearly indicates the change in ownership since the last filing? Beyond the initial filing, every 13G/A requires the investor to review prior filings or ownership levels to determine if the investing party is increasing or decreasing their position. That seems like an unnecessary step. With respect to From 4s, could we please somehow designate outright purchases – purchases made with discretionary money by insiders (statement purchase) – from stock acquired via compensation plans? Additionally, could we please somehow designate outright sales from 10b5-1 transactions. Stock acquired via employee compensation plans and 10b5-1 sales are information-light and serve only to distract investors. Outright Purchases and Outright Sales are highly insightful. It would be helpful to all investors if the noise of stock compensation and 10b5-1 plans was removed from the Form 4 filing process. I am not suggesting eliminating the requirement to file a Form 4 due to stock compensation plan purchases or 10b5-1 sales, but rather that we somehow designate the insightful transactions – maybe Form 4/I, for “insightful” – from those that are simply distractions. Small changes with big potential impact. Respectfully submitted, Charles A. Morris Charles A. (“Chip”) Morris, CFA Partner / Chief Operating Officer Greenhouse Funds LLLP