Jul. 30, 2020
I would like to voice my opposition to the new rule proposal to increase the 13F minimum filing requirement to $3.5 billion. Our primary business is investing in hedge funds with assets under management of less than $1 billion. 13Fs currently provide us with a regular way to track the long holdings of our managers on a quarterly basis. While most hedge fund assets reside in large managers with AUM greater than $3.5 billion, the overwhelming number of hedge funds have AUM under $1 billion. The transparency available to hedge fund investors has increased meaningfully since the 2008-2009 period to the benefit of our clients and this would be a meaningful step backwards in our ability to source and track the best smaller and newer managers on their behalf. Thank your for your consideration. R. Ruffin King Principal Granville Capital, Inc. One Boar’s Head Pointe, Suite 108 Charlottesville, VA 22903