Investor Protection

SEC 13F Proposal to Reduce Transparency is Not Backed By Evidence

CFA Director of Investor Protection Barbara Roper submitted a letter to the Securities and Exchange Commission opposing the agency’s proposal to increase the reporting threshold under Section 13(f) of the Exchange Act from $100 million to $35 billion. Citing the lack of any evidence to support the proposal, the letter calls on the SEC to withdraw the proposal in order to conduct a more thorough and balanced analysis that takes into account the considerable negative impact the proposed increase in the reporting threshold would have of the many users of 13F data. It further urges the Commission, if it determines that an increase in the reporting threshold is both warranted and permitted under the statute, to include any such increase as part of a balanced package of reforms designed to improve the informational value of the 13F reports. In particular, the letter argues that it is imperative that the list of 13F securities be updated to reflect market developments since the reporting requirement was adopted, and it urges the Commission to work with Congress to achieve that goal.