Subject: File No. 4-626
From: Stephen McMenamin
Affiliation: Executive Director, Greenwich Roundtable Inc.

May 2, 2011

Stephen McMenamin
Executive Director, Greenwich Roundtable, Inc.
Cos Cob, Connecticut



Dear Elizabeth Murphy,

We are pleased to offer comments on Section 917 (a)(5) of the Dodd-Frank Act. It is my belief that investor education is one of the greatest needs in the marketplace. The Great Credit Crisis of 2008 happened for several reasons. One of the biggest culprits was complexity. The size of the investor offered no refuge for the lack of understanding on complexity at both the instrument level or the strategy level. The Greenwich Roundtable is currently surveying the smartest investors in the world to publish "Best Practices in Alternative Investing: Understanding Complexity".

The qualified purchaser has little protection outside of the fraud statutes and the primary defense is rigorous due diligence. Investors, limited partners, performing due diligence on managers, general partners, are the clearing mechanism for the marketplace. Trillions of dollars are at stake as well as the trust and reputation of the US capital markets.

1. For over 15 years The Greenwich Roundtable organizes monthly symposiums at the Bruce Museum in Greenwich Connecticut for the benefit of its members, all qualified purchasers. Each symposium is attended by limited partners from the endowment, pension fund, family office, foundation, private bank, and fund of funds communities. This interdisciplinary group receives education from a panel of speakers that is usually composed of a hedge fund, a private equity fund and a knowledgeable expert. The speakers are asked to follow a format that avoids marketing pitches and examines the risks, the opportunities and the outlook on the strategy being discussed. Each symposium is held for 2 hours in front of 100 investors. Those who could not attend are sent an abstract of the session as well as a digital audio transcript that is hosted on The goal of the session is to make investors more aware of the risks and a judgment on the probability for success of any given strategy. Our curriculum is focused on non-traditional investing, on inefficient pricing, and on strategies where the manager is able to influence the outcome of the investment (legally and ethically of course).

2. The most effective characteristic of any investor education program is a basic understanding of the definition of a strategy and most importantly of its risks. What can go wrong? Programs that are most effective are those that i) outline the principles of investing, and ii) those that keep definitions simple, but no more than feasible. Some concepts are complicated.

3. In our world we view the Commonfund Institute's programs as highly effective. Their "Forum" and "Endowment Institute" seem to be the only rigorous curricula for chief investment officers. The GR symposia are also effective in this regard.

5. The membership of the Greenwich Roundtable is international but the symposia are local. The program is expandable but it currently lacks the funding to do so.

6. Investor education programs should focus on the role of emotions on the decision making process. This is second only to a clear understanding of the definitions and the workings of the instruments/strategies. The foundation of the above assumes a thorough knowledge of the principles of investing.

7. The Greenwich Roundtable is a not-for-profit 501(c)3 membership organization whose mission is to educate sophisticated investors and to create a code of Best Practices for the investor community around the world. Details of our mission, our Form 990 and our work are available at

8. Authentic investor education is scarce. Marketing literature disguised as educational material seems to be the most common media.

Retail and institutional investors are all vulnerable to the growing demands that complexity is placing on anyone taking risk in the global marketplace today. We are please to answer any questions you may have.

Stephen McMenamin
Executive Director
The Greenwich Roundtable
One River Road, Garden Level
Cos Cob, Connecticut 06807 USA

+1 203 862 0410

The Greenwich Roundtable is a group of sophisticated private and institutional investors who collectively represent over $4.3 trillion in assets under management. This group largely influences the investment preferences for the alternative investment community. The purpose of the Greenwich Roundtable (GR) is to provide a forum for the leading practitioners of wealth creation and investment philosophy to express their point of view. Since 1995, the GR has hosted scores the most influential hedge funds, policy makers, scientists and venture capitalists. Attendance is by invitation and attendees are all qualified purchasers. The Greenwich Roundtable is a non-profit research and education group. It is intellectually driven by the preferences of its members. The content and direction of the Greenwich Roundtable is largely determined by its Board of Trustees and its Programming Committee. The Education Committee of the Greenwich Roundtable publishes the "Best Practices in Alternative Investing" studies that focus on due diligence, portfolio construction and understanding complexity.

(Attached File #1: 4626-19a.pdf) (Attached File #2: 4626-19b.pdf) (Attached File #3: 4626-19c.pdf)