1/ 6.The public has helpfully weighed in regarding the impact of substantially reducing 13F reporting. It turns out the impact may not be as slight as the proposal contemplated:
2/ 6.The comment file is filled with letters from retail investors who rely on 13F data for their own investment decisions and to better understand the investment activities of institutional asset managers: https://www.sec.gov/comments/s7-08-20/s70820.htm
3/6.The benefits to the public of transparency were a primary motivating factor for Congress in adopting the 13F requirement: https://www.sec.gov/comments/s7-08-20/s70820-7777971-223451.pdf
4/6.Hundreds of issuers also rely heavily on this data to communicate with their shareholders, and the proposal would disproportionately affect small- and micro-cap issuers: https://www.sec.gov/comments/s7-08-20/s70820-7709057-222930.pdf
5/6.And research shows that this proposal will allow as much as 86% of activist investors to stop disclosing their holdings: https://ihsmarkit.com/research-analysis/secs-13f-proposal--issuer-and-investor-analysis.html
6/ 6.I look forward to ongoing discussion and analysis as the Commission considers the wisdom of this proposal.
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