Subject: File No. S7-07-12
From: Christine M. Erickson

September 1, 2012

It's clear that the SEC now works for the flailing hedge fund industry. Small investors be damned, full speed ahead for advertising without disclosure. You might as well close your doors and save the taxpayers a bit of money. Strike the last about saving tax dollars if you are now fully funded by the various Wall Street enterprises whose goal is to disarm all regulation.

Copywriters are already at work mocking SEC-compliant hedge fund ads. Now the industry wants to go after those who happen to have a million or more intact with ads like the following mock-ad, written on

Is An Index Hedge Fund Right For You?

If you are an Ultrahigh Net Worth Individual (UHNWI), you know the advantages of index funds. But you may have held off, because there was never a hedge fund solution tailored to your needs. Or you may have compromised by investing in the same index mutual funds available to the mass affluent. (Don't be fooled by fancy names like "Admiral" and "Flagship"--these are just window dressing on the same funds anyone can buy).

But now, at last, there is a true hedge fund solution: the Nisiprius Mary Rose Fundament-Based Index Fund. The world's first and only Index Hedge Fund. Named for the famous battleship Mary Rose--one of the first to serve in the British Navy--the Mary Rose Fund follows a secret index using our proprietary crap-weighted methodology, which we call "fundament-based," because at bottom it rests on its assets. For competitive reasons we will not disclose the composition of the index, but rest assured we will publish the index value often, so you will be able to see how well the Fund tracks it.

And the Mary Rose Fund is not just an index hedge fund, it is a low-cost index hedge fund, charging only 1% of assets under management and 10% of the rich profits management hopes it will garner. One and ten, just half the cost of the competition.

But the Mary Rose Fund is not for just anyone. You must be a qualified applicant. This means you must click a checkbox on a real stringent online web page saying that you have $1 million in investible assets, that your body mass index is less than 25, and that you are listed in the Social Register. Of course all we actually care about is that you click the checkbox. Or just call, and we will send a concierge to your home to click the checkbox for you.

The Nisiprius Mary Rose Fundament-Based Index Fund. Call us today and we'll tell you whether you should buy it. From Nisiprius Investments, Ltd., "Where Your Investments Create Profit."

"On this ship, excellence is the standard"--Captain Queeg in The Caine Mutiny
Mary Rose: Historians have been unable to explain the mysterious Mary Rose disaster. The ship capsized and sank very close to land during a battle with the French.