Commentary on the SEC's Proposed Reporting Threshold for Institutional Investment Managers

6 Pages Posted: 15 Dec 2020

See all articles by Mary E. Barth

Mary E. Barth

Stanford University - Graduate School of Business

Travis Dyer

Brigham Young University

Wayne R. Landsman

University of North Carolina Kenan-Flagler Business School

Daniel J. Taylor

The Wharton School, University of Pennsylvania

Date Written: September 16, 2020

Abstract

We comment on the Securities and Exchange Commission’s proposed Reporting Threshold for Institutional Investment Managers (“Proposal”). We estimate the cost savings from the Proposal are economically small, and amount to 0.004% (0.008%) of assets under management for the average (median) affected filer, and 0.02% of assets for the smallest filer. This small cost savings needs to be weighed against the potentially large costs to investors and others created by eliminating a public disclosure that they heavily use. We believe the analysis in Section II of the Proposal is incomplete for two reasons. First, the Proposal does not contain any formal economic analysis. Second, it does not attempt to quantify either the extent of use of Form 13F or the benefits that it provides to investors and other stakeholders. To help fill this void, we analyze the usage patterns of the EDGAR system, and specifically the frequency of Form 13F downloads from EDGAR. Our analysis suggests the investing public and other stakeholders are strongly interested in the information in Form 13F filings, particularly those of affected filers, and that exempting such institutions from filing Form 13F would deprive the market of this information.

Suggested Citation

Barth, Mary E. and Dyer, Travis and Landsman, Wayne R. and Taylor, Daniel, Commentary on the SEC's Proposed Reporting Threshold for Institutional Investment Managers (September 16, 2020). Available at SSRN: https://ssrn.com/abstract=3714221 or http://dx.doi.org/10.2139/ssrn.3714221

Mary E. Barth

Stanford University - Graduate School of Business ( email )

655 Knight Way
Stanford, CA 94305-5015
United States
650-723-9040 (Phone)
650-725-0468 (Fax)

Travis Dyer

Brigham Young University ( email )

Provo, UT 84602
United States

Wayne R. Landsman

University of North Carolina Kenan-Flagler Business School ( email )

McColl Building
Chapel Hill, NC 27599-3490
United States
919-962-3221 (Phone)
919-962-4727 (Fax)

Daniel Taylor (Contact Author)

The Wharton School, University of Pennsylvania ( email )

3641 Locust Walk
Philadelphia, PA 19104-6365
United States

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