From: JOEL TORRANCE [jstorran2@yahoo.com]
Sent: Thursday, June 17, 2004 2:38 PM
To: rule-comments@sec.gov
Subject: Proposed Rule: FOF Investments (s7-18-03)

Hi,

My name is Joel Torrance, I was an employee of GAM USA Inc from 1994 through 
2003., an investment advisor offering a series of fund-of-fund investment 
vehicles via registered SEC products that invest primarily in thematic hedge 
funds.

My comment on the proposed rule amendment is strongly in favour of it.  I 
believe the current set up does the investing public a disservice.  For example, 
GAM launched a technology FOF vehicle named GAM Avalon Multi Technology LLC.  
It's explicit fee's within the PPM were circa 3.5%, however because of the small 
size at launch (a few million), the implicit fees from cummulative expenses 
shouldered by the vehicle (offering, administrative, legal, accounting, etc.) 
amounted to another 10.0% + on top of the explicit fees.

This example demonstrates the need to have more detailed information available 
to the investing public, perhaps a "hypothetical" all-in load based upon various 
permutations of asset size in advance of launch, followed by more explicit 
details made available following each year-end.

I'd welcome the opportunity to discuss further, and can be reached via this 
e-mail address or at 917 653 8574.

My best,

Joel Torrance


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