IMPORTANT: Proposed SEC filing changes that will affect you

by mikebcity

If you use 13F filing data in your investing research then please take a few minutes to read this important message. You may have already seen the SEC proposal www.sec.gov/rules/proposed.shtml?__s=cvwgmhfkxsnsnrbvs6py to dramatically raise the required reporting threshold for 13F filings.

This proposal would change the AUM threshold that investment managers must meet every quarter from $100 million to $3.5 billion!

To put it in perspective, for the most recent quarter, that would reduce the number of funds that disclosed their holdings to the public from 5,283 to 549 or almost 90% of all filers.  $2.3 trillion in investment holdings would no longer be disclosed to the public resulting in loss of transparency and valuable insight.  When Congress first adopted Section 13(f) it did so to “stimulate a higher degree of confidence among all investors in the integrity of [the US] securities markets.”  Taking this data away will have the opposite effect.  Transparency is what gives investors confidence in US markets.

One SEC commissioner, Allison Heren Lee, has already voiced her opposition to this proposal.  www.sec.gov/news/public-statement/lee-13f-reporting-2020-07-10 The proposed rule change would be a loss for all of us – it would enable more corruption and opaqueness.

The SEC should be pushing for more disclosure and transparency and not rolling back existing rules. This can only hurt small trades/investors and provides little to no benefit or savings.

Comments are already pouring into the SEC.  I am urging everyone to please post a comment on the proposal to the SEC site linked below.  Why should we care?  How are we impacted by this?  Below are some issues to raise.  Please mention them in your comments to the SEC and to your representative in Congress: Raising the reporting threshold to such a high number will reduce public companies’ opportunity to know more about who their shareholders are.

  • The “justification” for the rule change is highly questionable.
  • When is less transparency and less data ever a good thing for the small investor
  • Some investors may want to avoid over-owned stocks, believing they have a high level of risk. This rule change greatly reduces individual investors ability to reduce their risk.
  • In the event of a significant correction the number of reporting managers would be diminished even further.  The S&P suffered a 56.4% decline during the 2007-2009 financial crisis.  A similar event using the most recent quarter as an example, would have reduced the number of funds by another 31% at a time when such data is needed even more.

SEC Comment Page:  www.sec.gov/rules/proposed.shtml.  Click on “Submit comments on S7-08-20”

Or you can send an email to [rule-comments@sec.gov](mailto:rule-comments@sec.gov).  Include the file number S7-08-20 in the subject. Instructions are at www.sec.gov/rules/submitcomments.htm

Full SEC Proposed Rule Change:  www.sec.gov/rules/proposed/2020/34-89290.pdf

TLDR: Write in and tell the SEC “Hell No!” to these disclosure changes. For example: this would mean MRNA insiders would continue to sell before their regular pump and dumps and nobody would be the wiser.

 

 

Disclaimer: This information is only for educational purposes. Do not make any investment decisions based on the information in this article. Do you own due diligence.