June 7, 2011
I am writing in the hope that you will reconsider the proposal seeking to raise the accredited investor minimum to $2 million. I have a small hedge fund with roughly $870,000 in assets under management. It is very much a "friends and family" fund that I hope to grow into a sustainable business. Before I am able to attract "institutional" investors, I need to secure additional smaller investors in order to get to a higher asset level (roughly $5 million or so). I invested my own money in getting this fund set up and it is very much a small business in the same way a local dry cleaner is in my mind. I intend for this business to be the means by which I put my 3 kids through college and ultimately retire. Contrary to so much public misperception regarding hedge funds, I am not a reckless gunslinger or insider trading monger. I am simply a stock picker, combining the trading and analytical skills I have developed over my career.
If the accredited investor threshhold is raised, it will make it that much harder for me to raise money for my fund and believe me, even as it is that is an extremely difficult proposition. As cases such as the Madoff scheme show, having significant assets at one's disposal is no guarantee that one will perform the necessary due diligence on an investment nor make prudent invesment allocation decisions (such as putting all one's eggs in one basket).
In fact, this rule will only hurt small business owners like myself by putting unnecessary barriers in the way of my path to success. I respectfully urge you to leave the accredited investor threshhold as it is.
Jeremy Hellman, CFA
Avenue T Fund LP