January 16, 2007
Re: SEC proposal re: hedge funds' net worth or income test
Proposal would unnecessarily overregulate and cripple startup and small hedge funds.
Solution: exempt hedge funds with less than $100 million assets which 1) use no more leverage than an individual investors' margin account (Reg. T margin of 50%, which is max. 2:1 leverage), and 2) have annual reports audited by an independent accountant.