May 11, 2011
Subject: Public Notice 2011-109
One important value proposition of our firm is that we enable hedge fund access to investors that might be excluded from investing in larger funds. That is an important service to these investors who are financially sophisticated but are otherwise excluded by an arbitrary guideline. As such, we believe it is not fair to those investors to further raise the net worth threshold for performance fee eligibility.
Additionally, raising the threshold would also have a meaningful negative impact on our business and on other businesses like ours.
We urge the Commission:
1) Not to raise the thresholds as proposed in the notice.
2) If you do raise the thresholds, you should allow existing investors to be grandfathered i.e. to not be subject to the new rule
Thank you for considering my comments. Sincerely,
Crescat Portfolio Management LLC