September 15, 2009
Dear SEC Chairman and Board Members:
For many years, investment bankers/placement agents have played a value-added role in the private equity investment management business and thus, the SECs proposed ban of their entire professional industry should not go into effect for the following reasons:
1. Public pension funds represent a majority of all the capital invested in the private equity investment management business and eliminating access to this magnitude of capital will devastate the placement agent business
2. The vast majority of emerging, small and middle-market investment managers rely extensively on placement agents to gain access to pension fund capital. Without these services, many of these companies will simply not survive or be forced to operate at a disadvantage
3. Pension funds will be unnecessarily harmed because without placement agents, there will be a dramatic reduction in their access to potential opportunities from emerging, small and middle-market investment managers
4. Pension funds will no longer be able to use placement agents to help them identify, pre-screen and evaluate potential investment manager candidates
5. And last, but not least, the placement agent and investment management industry will incur dramatic job losses
Thank you for your consideration of this comment.
Sincerely,
Venera Kurmanaliyeva