Security and Exchange Commission, 13F Reporting - S7-08-20, request for withdrawal

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US Securities and Exchange Commission is proposing to increase the reporting threshold by 35 times for institutional investment managers that must report equity holdings on Form 13F, thus eliminating visibility into portfolios controlling $2.3 trillion in assets.

Greater transparency “is of particular concern to smaller issuers that cannot afford to pay for stock surveillance firms that analyze trading patterns and try to determine which investors are buying or selling shares” (National Investor Relations Institute)

Raising the reporting threshold to such a high number will severely limit future academic research on markets, investing and securities and reduce public companies' opportunity to know more about who their shareholders are.

Furthermore, it looks like Congress set a statutory reporting threshold at $100 million, and the Commission has the authority to lower it, not to increase it.

For the above reasons, as small investors, we kindly ask SEC to withdraw S7-08-20.

(Special thanks to Allison Herren Lee, Commissioner -

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