ICBA filed a comment letter opposing the Securities and Exchange Commission's proposal to raise the threshold over which institutional investment managers are required to file quarterly Form 13F reports.

The Securities Exchange Act requires managers that exercise investment discretion over securities worth at least $100 million to submit these reports. The SEC is proposing to raise the threshold to $3.5 billion.

In its comment letter, ICBA said raising the threshold would limit the ability of many publicly held community banks to identify and engage shareholders, outweighing the modest cost savings for some investment managers.