Subject: File No. S7-30-04
From: erik d hals
Affiliation: amaranth llc

September 15, 2004

I oppose the SECs proposal to require direct oversight of hedge fund managers. While the SEC has pointed to the prevention of fraud as a principal goal of the proposed rule, the SECs own report on the hedge fund industry indicates that fraud is no more prevalent in the hedge fund industry than in other contexts. Moreover, the dissent filed by Commissioners Glassman and Atkins demonstrates that of the 40 hedge fund fraud cases cited by the SEC, only 8 would actually be affected by the proposed registration requirement. This evidence does not suggest to me that any expansion of regulation is warranted.