February 14, 2007
Your proposed rules are arbitrary and a poor proxy to your goals.
This rule mainly just punishes small managers like myself, increases barriers to entry (as a regulator you have been captured as usual) and benefits the elite in our society.
If you really cared about the little guy you would also prevent pension funds from investing in hedge funds. I am very troubled that our pension funds are now being marketed "portable alpha" which is just another way of saying our pension funds should leverage themselves. This is grossly irresponsible. But this is OK with you because you lack moral perspective. Had you prevented pension funds from investing in hedge funds as well, I could respect your concern for the individual.
Instead, you decided to punish the small managers and individuals as a worthless proxy for risk reduction and suitability. I am sure that the MFA is patting you on the back calling you "brilliant". What a shame.