April 12, 2022
I have been a compliance professional for several decades. While I support transparency, the SEC is proposing sweeping changes in these proposed rules and the comment period overlaps during the first quarter of the calendar year when investment advisers are pre-occupied with audits, preparing K-1 for private fund investors and filing Form ADV. I urge the Commission to extend the comment period so that those impacted have proper time to review and comment. I've reviewed the majority of the comments published and they appear to be largely from unsophisticated retail investors, who are not the investors that can invest in hedge funds and private equity. We are a small investment adviser that has one hedge fund, which is audited, and an offshore feeder fund, which will also be audited. Our investors receive monthly statements from our administrator. Adding quarterly statements will likely increase fund administration expenses, which will be passed along to investors. I believe we are transparent to our investors. I also feel providing historical net investment performance information is unnecessary especially in light of the Commission's new marketing rules. In our specific circumstances, we provide net composite performance information in our marketing material, which is more meaningful that providing net performance just the fund level since the fund did not have outside investors and did not charge fees for several years after inception of the fund. I have not had the time to review other parts of the proposed rules and again iterate that the Commission extend the comment period.