March 8, 2007
To Whom It May Concern:
I would like to comment on the grandfathering of current accredited investors. Although I do not support the current proposal, should the Commission approve the adjustment of new accredited natural person standard it should grandfather investors for those which they are currently invested as of the proposal decision date. Forcing investors to withdraw funds from hedge funds by a certain date to currently accredited investors may cause undue harm to those individual in the form of early withdrawal fees or higher fees for early exists. In addition, investors may be forced out of SEC compliance by a fund in case there is long time restriction on withdrawal. Lastly, if the fund is small $10 - $50 million in AUM fund and focused on relatively small investors, then this can cause a run on the fund to unfavorably exit its positions.
I therefore suggest that grandfathering on current investors be effective as of the Commissions decision date. Please note that I am neither advocating for or against maintaining the status of such investors for future investments, only for current investments in place as of the Commissions decision date.
Thank you for your time and consideration of this comment,
Ayal Rosenthal