0001462180-12-000001.txt : 20120113 0001462180-12-000001.hdr.sgml : 20120113 20120113160107 ACCESSION NUMBER: 0001462180-12-000001 CONFORMED SUBMISSION TYPE: SC 13D PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20120113 DATE AS OF CHANGE: 20120113 GROUP MEMBERS: ANDREW DAKOS GROUP MEMBERS: BROOKLYN CAPITAL MANAGEMENT GROUP MEMBERS: BULLDOG INVESTORS GROUP MEMBERS: PHILLIP GOLDSTEIN SUBJECT COMPANY: COMPANY DATA: COMPANY CONFORMED NAME: DIAMOND HILL FINANCIAL TRENDS FUND, INC CENTRAL INDEX KEY: 0000852954 IRS NUMBER: 000000000 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SC 13D SEC ACT: 1934 Act SEC FILE NUMBER: 005-41158 FILM NUMBER: 12526663 BUSINESS ADDRESS: STREET 1: C/O DIAMOND HILL CAPITAL MANAGEMENT, INC STREET 2: 325 JOHN H MCCONNELL BLVD, SUITE 200 CITY: COLUMBUS STATE: OH ZIP: 43215 BUSINESS PHONE: 614-255-3333 MAIL ADDRESS: STREET 1: C/O DIAMOND HILL CAPITAL MANAGEMENT, INC STREET 2: 325 JOHN H MCCONNELL BLVD, SUITE 200 CITY: COLUMBUS STATE: OH ZIP: 43215 FORMER COMPANY: FORMER CONFORMED NAME: FINANCIAL TRENDS FUND, INC DATE OF NAME CHANGE: 20071120 FORMER COMPANY: FORMER CONFORMED NAME: JOHN HANCOCK FINANCIAL TRENDS FUNDS INC DATE OF NAME CHANGE: 20010717 FORMER COMPANY: FORMER CONFORMED NAME: SOUTHEASTERN THRIFT & BANK FUND INC DATE OF NAME CHANGE: 19920703 FILED BY: COMPANY DATA: COMPANY CONFORMED NAME: Bulldog Investors CENTRAL INDEX KEY: 0001462180 IRS NUMBER: 000000000 FILING VALUES: FORM TYPE: SC 13D BUSINESS ADDRESS: STREET 1: PARK 80 WEST PLAZA TWO STREET 2: SUITE 750 CITY: SADDLE BROOK STATE: NJ ZIP: 07663 BUSINESS PHONE: 201 556-0092 MAIL ADDRESS: STREET 1: PARK 80 WEST PLAZA TWO STREET 2: SUITE 750 CITY: SADDLE BROOK STATE: NJ ZIP: 07663 SC 13D 1 third.txt SCHEDULE 13D DATE OF EVENT WHICH REQUIRES FILING OF THIS STATEMENT 1/3/12 1. NAME OF REPORTING PERSON Bulldog Investors, Brooklyn Capital Management, Phillip Goldstein and Andrew Dakos 2. CHECK THE BOX IF MEMBER OF A GROUP a[X] b[] 3. SEC USE ONLY 4. SOURCE OF FUNDS WC 5. CHECK BOX IF DISCLOSURE OF LEGAL PROCEEDINGS IS REQUIRED PURSUANT TO ITEMS 2(d) AND 2(e) [] 6. CITIZENSHIP OR PLACE OF ORGANIZATION USA ___________________________________________________________ 7. SOLE VOTING POWER 279,536 8. SHARED VOTING POWER 69,976 9. SOLE DISPOSITIVE POWER 349,512 _______________________________________________________ 10. SHARED DISPOSITIVE POWER 0 11. AGGREGATE AMOUNT OWNED BY EACH REPORTING PERSON 349,512 12. CHECK IF THE AGGREGATE AMOUNT EXCLUDES CERTAIN SHARES [] ___________________________________________________________ 13. PERCENT OF CLASS REPRESENTED BY ROW 11 8.81% 14. TYPE OF REPORTING PERSON IA _______________________________________________________ Item 1. SECURITY AND ISSUER This Schedule 13D relates to the shares of Common Stock of Diamond Hill Financial Trends Fund, Inc. ("DHFT" or the "Issuer"). The principal executive offices of EQS are located at C/O Diamond Hill Capital Management Inc. 325 John H. Mcconnell Blvd Suite 200 Columbus, OH 43215 Item 2. IDENTITY AND BACKGROUND This statement is filed on behalf of Bulldog Investors, Brooklyn Capital Mangement, Phillip Goldstein, 60 Heritage Drive Pleasantville, NY 10570 a principal of Bulldog Investors and Andrew Dakos, Park 80 West,Saddle Brook, NJ 07663, also a principal of Bulldog Investors. Mr.Goldstein and Mr. Dakos are self-employed investment advisors. On January 31, 2007 the Acting Director of the Securities Division of the Massachusetts Secretary of State filed a complaint against Bulldog Investors, Messrs.Goldstein, Dakos and Samuels and certain related parties (the Bulldog Parties) alleging that they violated Massachusetts law by operating a website containing information about certain unregistered investments and by sending an e-mail about such investments to an individual who requested it. On March 23, 2007 the Bulldog Parties filed a lawsuit in the Massachusetts Superior Court against the Secretary alleging that his enforcement action violated 42 U.S.C. ss 1983 because, among other things, the Secretary did not have personal jurisdiction over them and it violated their First Amendment rights. On October 17, 2007 the Secretary issued an "obey the law" cease and desist order (the Order) and fined the Bulldog Parties $25,000. On November 15, 2007 the Bulldog Parties filed an appeal of the Order in the Massachusetts Superior Court which subsequently upheld the Order. The Bulldog Parties further appealed the Order to the Massachusetts Appeals Court. On October 21, 2009 the Massachusetts Supreme Judicial Court (the SJC) unilaterally transferred the case to itself and on July 2, 2010 upheld the Order except for the Bulldog Parties' First Amendment claim which it ruled must be decided in the appeal of the aforementioned ss 1983 lawsuit. In the ss 1983 lawsuit, the Secretary stipulated that the website and email in question did not concern an illegal transaction and were not misleading. Nevertheless, on September 26, 2009, the Superior Court ruled that the Secretary's enforcement action did not violate the Bulldog Parties' First Amendment rights. The Bulldog Parties filed an appeal of the Superior Court's ruling in the Massachusetts Appeals Court. On July 23, 2010, the SJC unilaterally transferred the appeal of the ss 1983 lawsuit to itself. On September 22, 2011 the SJC affirmed the Superior Court's ruling and declined to reconsider the Bulldog Parties' personal jurisdiction claim. On November 3, 2011 the United States House of Representatives by a vote of 413 to 11 approved H.R. 2140, the access to Capital for Job Creators Act, which would permit privately held companies like Bulldog Investors to use advertisements and websites to solicit accredited investors for private offerings. If H.R. 2140 is enacted into aw, the Bulldog Parties intend to seek to vacate the order. The Bulldog Parties also intend to file a petition for certiorari with the United States Supreme Court. ITEM 3. SOURCE AND AMOUNT OF FUNDS AND OTHER CONSIDERATIONS Shares of the Issuer have been accumulated on behalf of managed accounts. ITEM 4. PURPOSE OF TRANSACTION The filing persons are concerned about the Fund's persistent double-digit discount to net asset value. They have communicated with the Fund's management and board of directors about this matter. ITEM 5. INTEREST IN SECURITIES OF THE ISSUER As per the N-CSRS filed on September 7, 2011 there were 3,968,124 shares of common stock outstanding as of 06/30/2011 The percentage set forth in item 5 was derived using such number. Bulldog Investors, Brooklyn Capital Management, Phillip Goldstein and Andrew Dakos beneficially own an aggregate of 349,512 shares of DHFT or 8.81% of the outstanding shares.Power to dispose of and vote securities resides either with Mr. Goldstein, Mr. Dakos or with clients. c) As of January 12, 2012 and during the past 60 days the following shares of DHFT were purchased: Date: Shares: Price: 11/17/11 4,900 8.0094 12/01/11 500 8.0051 12/02/11 8,853 8.2910 12/05/11 3,800 8.3582 12/07/11 11,910 8.4676 12/09/11 6,632 8.3555 12/12/11 1,700 8.2140 12/13/11 13,700 8.2971 12/14/11 9,721 8.1398 12/16/11 9,500 8.1246 12/20/11 600 8.2372 12/21/11 18,714 8.2363 12/23/11 1,300 8.3992 12/28/11 1,500 8.3000 01/03/12 28,381 8.5855 01/04/12 26,090 8.6582 01/05/12 16,735 8.7852 01/09/12 32,955 8.8292 01/10/12 24,614 8.9938 01/11/12 7,273 9.0792 01/12/12 13,802 9.1530 01/12/12 1,350 9.0600 d) Beneficiaries of managed accounts are entitled to receive any dividends or sales proceeds. e) NA ITEM 6. CONTRACTS,ARRANGEMENTS,UNDERSTANDINGS OR RELATIONSHIPS WITH RESPECT TO SECURITIES OF THE ISSUER. None. ITEM 7. MATERIAL TO BE FILED AS EXHIBITS None. After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete and correct. Dated: 01/13/2012 By: /s/ Phillip Goldstein Name: Phillip Goldstein By: /S/ Andrew Dakos Name: Andrew Dakos