HFMWEEK S P E C I A L R E P O R T HOW TO START A HEDGE FUND IN THE US 2014 INFRASTRUCTURE Choosing the right controls and service providers DUE DILIGENCE Establishing a quality investor identification process REGULATION Adapting to a challenging and changing landscape FEATURING Anchin, Block & Anchin LLP // Arthur Bell // Concept Capital Markets LLC // EisnerAmper LLP // Ernst & Young // Sadis & Goldberg // US Bancorp // UMB Fund Services The Science Behind Your Success We do more than simply react to changes in the market. Tried by more than 45 years as an industry leader, our business model synthesizes superior services with leading edge technology. Let our expertise help yield your success. Global Hedge Fund Administration Made Simple Administration & Accounting Legal Administration & Compliance Tax Support Custody Services Middle Ofﬁce Services Technology Investor Services Registered Ofﬁce Services Treasury Services usbfs.com 1.800.300.3863 H O W T O S TA R T A H E D G E F U N D I N T H E U S 2 0 1 4 T aking the leap into hedge funds can be a daunting task for even the most passionate start-up manager. While the struggle to raise capital remains as tough as ever, it is not the only challenge facing the contemporary launch, with barriers to entry creeping up across a range of metrics. In the lingering shadow of the financial crisis, and as managers try to attract institutional investors, start-ups have to work diligently to build a robust infrastructure. Only the right internal controls and service providers, as well as sufficient levels of transparency, will keep potential investors interested. In the US, the legislative landscape continues to evolve, with Fatca and Dodd-Frank presenting challenges for the industry as a whole. The burdensome expectations from regulators and investors alike mean managers face a significant strain on resources. For most start-ups, hiring enough staff to cover the demands in legal and administrative remits is proving difficult. The need for outsourced services and third-party administrators has become more important than ever before. New managers also face the challenge of deciding what kind of structure is right for their potential investors, as well as the challenges associated with setting up a fund onshore or offshore, from Ucits and ’40 Act offerings, to AIFs and beyond. With these factors in mind, it is little surprise than many industry observers have declared the launch environment as challenging as ever. In this, the How to Start a Hedge Fund in the US Report 2014, we speak to several key service providers to get the latest advice on how to achieve start-up success. Alexis Burris Report editor Published by Pageant Media Ltd LONDON Third Floor, Thavies Inn House, 3-4 Holborn Circus, London, EC1N 2HA T +44 (0) 20 7832 6500 NEW YORK 1441 Broadway, Suite 3024, New York , NY 10018 T +1 (212) 268 4919 REPORT EDITOR Alexis Burris T: +44 (0) 20 7832 6656 [email protected] REPORT EDITOR Karolina Kaminska T: +44 (0) 20 7832 6654 [email protected] HFMWEEK HEAD OF CONTENT Tony Grifﬁths T: +44 (0) 20 7832 6622 t.grifﬁ[email protected] HEAD OF PRODUCTION Claudia Honerjager SUB-EDITORS Rachel Kurzﬁeld, Eleanor Stanley, Luke Tuchscherer CEO Charlie Kerr GROUP COMMERCIAL MANAGER Lucy Churchill T: +44 (0) 20 7832 6615 [email protected] SENIOR PUBLISHING ACCOUNT MANAGER Tara Nolan +44 (0) 20 7832 6612, [email protected] hfmweek.com PUBLISHING ACCOUNT MANAGER Rebecca Wheeler, +44(0) 20 7832 6613 [email protected] CONTENT SALES Tel: +44 (0) 20 7832 6511 [email protected] CIRCULATION MANAGER Fay Muddle T: +44 (0) 20 7832 6524 [email protected] HFMWeek is published weekly by Pageant Media Ltd ISSN 1748-5894 Printed by The Manson Group © 2014 all rights reserved. No part of this publication may be reproduced or used without the prior permission from the publisher 21 H F M W E E K . CO M 3 CONTENTS H O W T O S TA R T A H E D G E F U N D I N T H E U S 2 0 1 4 06 LEGAL SUCCESSFULLY LAUNCHING A HEDGE FUND 15 Ron Geffner of Sadis & Goldberg explains how a new launch can be successful in an ever evolving and increasingly regulated market 09 STRENGTH FROM WITHIN Corey McLaughlin of Arthur Bell CPAs explains the importance of internal controls and infrastructure to managers starting a hedge fund ACCOUNTANCY LESSONS FOR NEW EMERGING FUNDS Nick Tsafos, Mike Laveman and Jeff Parker look at best practices for forming a fund and explain how EisnerAmper can help with the process 12 INVESTMENT ACCOUNTING FUND SERVICES STARTING YOUR ALTERNATIVE INVESTMENT BUSINESS Frank Napolitani of Concept Capital discusses the steps involved in starting up an alternative investment fund 4 H F M W E E K . CO M 18 FUND SERVICES A HELPING HAND Michael Von Bevern of U.S. Bancorp Fund Services discusses the difﬁculties in starting up a hedge fund 21 FUND SERVICES MAKING THE LEAP Jerry Wright of UMB Fund Services answers the burning questions managers have about launching a hedge fund We take the bull by the horns. Whether market conditions are stable, bullish or bearish, ﬁnancial services companies need to thrive. Anchin has a team of experts dedicated to the unique needs of investment partnerships, hedge and private equity funds, and investment advisors. We provide audit, tax, ﬁnancial reporting, and advisory services to hundreds of ﬁnancial services companies. Let us be Your Expert Partner. Jeffrey I. Rosenthal, CPA - Partner-in-Charge, Financial Services [email protected] 1375 Broadway, New York, NY 10018 212.840.3456 anchin.com @anchincpa H O W T O S TA R T A H E D G E F U N D I N T H E U S 2 0 1 4 SUCCESSFULLY LAUNCHING A HEDGE FUND RON GEFFNER OF SADIS & GOLDBERG EXPLAINS HOW A NEW LAUNCH CAN BE SUCCESSFUL IN AN EVER EVOLVING AND INCREASINGLY REGULATED MARKET T Ron Geffner is a partner of Sadis & Goldberg LLP and oversees the Financial Services Group. He regularly structures, organises and counsels private investment vehicles, investment advisory organisations, broker-dealers, commodity pool operators and other investment fiduciaries. Geffner also routinely counsels clients in connection with regulatory investigations and actions. he hedge fund industry has matured over the last ten years. Now more than ever, successfully launching a hedge fund is dependent upon selecting the proper structure and complying with the ever changing regulations governing hedge funds. Structuring a hedge fund involves both the creation of one or more entities through which investments will be made (domestic and offshore hedge funds), as well as the management entities through which the advisory services will be provided to the hedge funds (the general partner and/or the investment manager). The structure and domicile of the hedge fund is primarily dependent upon two variables: (i) the nature and demographics of the prospective investors, and (ii) the investment strategy employed by the investment manager. The structure and domicile of the investment manager is primarily determined by the citizenship and tax considerations of its owners, as well as the regulatory regime of the domicile. ECONOMIC ANALYSIS In determining whether to form both a domestic and an offshore hedge fund, it is advisable to determine the amount of anticipated assets which will be invested in the hedge funds within a few months after the launch of the funds. In short, the anticipated aggregate investment at or shortly after the launch of the business may not justify the formation of both a domestic fund and an offshore fund and to create both may impair the investment manager’s ability to survive due to the organisational expenses and the costs of maintaining both domestic and offshore hedge funds. With early stage managers, cash burn is often overlooked and can be critical to the survival of the newly formed asset management firm. The manager must have an opportunity to establish a proven track record. SIDE BY SIDE, MASTER FEEDER & MINI-MASTER STRUCTURES Managers seeking to launch both domestic and offshore funds have several options available in structuring. The three most common structures are side-by-side, master feeder and mini-master. In a sideby-side structure, the domestic fund and the offshore fund make direct investments pursuant to the investment strategy and trade tickets are allocated between the domestic fund and the offshore fund. In a master feeder structure, a third entity is created (the master fund) and the domestic fund and the offshore fund, rather than making direct investments, invest all of their assets into the master fund and in turn, the master fund makes the investments on behalf of the domestic fund and the offshore fund (often referred to as the domestic feeder and offshore feeder). The mini-master structure generally is comprised of two entities; an offshore feeder and a master entity. While the offshore feeder is taxed as a corporation to benefit US tax-exempt investors and block UBTI, the master entity may be structured for tax purposes as a partnership. Rather than the US based manager receiving its incentive as a fee from the offshore fund and being subject to ordinary income tax, the US based manager may receive the incentive as an allocation from the master entity, in an attempt to benefit from capital gains tax treatment. LAUNCHING A HEDGE FUND IS DEPENDENT UPON SELECTING THE PROPER STRUCTURE AND COMPLYING WITH EVER CHANGING REGULATIONS STRUCTURING THE HEDGE FUND Investors can be divided into three classes: (i) US taxable investors, (ii) US tax-exempt investors, and (iii) non-US persons. In the majority of circumstances, if the investors are US taxable investors, the fund will be formed as a US limited partnership or a limited liability company. The US fund is often referred to as a “domestic fund.” Most domestic funds are organised in Delaware. If the investors are US tax-exempt investors or non-US persons, the fund generally will be formed in a jurisdiction outside of the US as a corporation (or other analogous entity). The non-US entity is often referred to as an “offshore fund.” Most offshore hedge funds organised on behalf of US based investment managers are organised in Bermuda, the British Virgin Islands and the Cayman Islands. US tax-exempt investors typically prefer to invest in an offshore fund set up as a corporation because if the offshore fund purchases securities on margin (often referred to as leverage), an offshore fund which is set up as a corporation blocks the unrelated business taxable income (UBTI) that would otherwise be taxable to the US taxexempt investor. ” 6 H F M W E E K . CO M LEGAL There are many legal and commercial drivers in determining the ideal structure. For example, if the strategy calls for significant investment in illiquid or thinly traded positions which are difficult to allocate among two brokerage accounts, a master feeder structure may be preferred as the investments will be allocated on a pro rata basis at the master fund yet only require the investment manager to purchase and sell the positions through one brokerage account. Also, in many transactions involving early stage or “seed” investment, if the seeder is located offshore, it may prefer a master feeder structure so that all fees and allocations may be taken at the master fund and thus avoid the US tax regime. Conversely, employing a tax efficient strategy for US taxable investors may be of little benefit or detrimental to US tax-exempt investors and non-US persons. Thus, a side by side structure allows the investment manager the ability to employ tax efficiency with the domestic fund, while maximising the entry and exit points of securities positions without regard to long-term tax gains for the offshore fund. STRUCTURING & DOMICILE OF THE INVESTMENT MANAGER The structure and domicile of the investment manager is primarily determined by the citizenship and tax considerations of its principals. Empirical evidence suggests that the super majority of hedge funds are managed by US domiciled entities structured as either limited liability companies or limited partnerships which are taxed as flow through vehicles (rather than as corporations). In circumstances involving non-US persons, if the nonUS persons own the majority of equity in or receive the majority of the economics from the investment manager and their interests are controlling, the investment manager may be organised in an offshore jurisdiction to accommodate the tax needs of the non-US persons. Historically, federal and state regulation often impact- ed the location at which the investment manager maintained its office in the United States. Certain states have compulsory registration requirements which require an investment manager with an office in those states to register as an investment adviser prior to the launch of the hedge fund. Prior to The Dodd Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) certain managers chose to maintain offices in neighboring states which did not have compulsory registration requirements so as to avoid having to register as an investment adviser. Post Dodd-Frank, managers have accepted registration as an investment adviser as inevitable. JOBS ACT The US Securities & Exchange Commission adopted Rule 506(c) of Regulation D, which allows for issuers to use general solicitation and advertising to offer securities, provided that the issuer takes reasonable steps to verify that all purchasers are “accredited investors” as defined in Rule 501 of Regulation D. Managers need to evaluate the benefits and implications associated with engaging in a general solicitation. At this time, there appear to be fewer than 24 firms seeking to advertise. It remains unclear as to whether hedge fund investors will respond to advertising. RESPONDING TO INVESTOR DUE DILIGENCE Due diligence is a critical part of the hedge fund investment process. A successful launch also depends upon providing prospective investors with comfort regarding non-investment considerations, such as the manager’s operations, compliance, and risk management. Having a standard due diligence questionnaire (DDQ) is recommended. It is critical that managers be consistent in all of their disclosures to investors. Consistency across documents is vital to the maintenance of a manager’s credibility in the due diligence process. The same level of care and consideration should be invested in marketing material, DDQs and requests for proposals. Each of these documents should respond to each item in the same manner. A different sentence or even a single word can change the message or meaning and result in a different understanding to the investor. CONCLUSION While cash burn is critical to a new manager, the quality of the firm’s infrastructure cannot be sacrificed. Having spent approximately two decades practicing law in this industry, both as an enforcement attorney with the SEC and in private practice, I have had the benefit of witnessing many successes and failures. It is important to use law firms with corporate, tax and regulatory experience in connection with structuring and maintaining hedge funds. Failure to properly structure your firm will have material opportunity costs. A firm with structural issues is less likely to attract investment and more likely to be plagued with investor litigation, regulatory prosecution, limitation on capital resources and reputational damage. In many cases, the costs associated with fixing a problem far exceed the costs of doing the job correctly at the outset. In certain cases, the problems cannot be fixed. Q H F M W E E K . CO M 7 Jill Calton, Managing Director, Alternative Investments umbfs.com Accountable At UMB Fund Services, delivering the unparalleled customer experience means being accountable for seamless operations. We’re focused on timeliness, accuracy and technical Our full-service line-up for alternative investments includes: + Product formation assistance expertise—all the while, taking into account the unique needs of each of our clients. By all accounts, we’re delivering value to our clients through the responsiveness and consultative approach that comes from working with a boutique service provider. It’s why more and more asset managers are choosing + Fund accounting + Fund administration + Tax preparation/reporting + Investor accounting/reporting + Custody* to count on UMB Fund Services. *Custody services provided by our affiliate UMB Bank, n.a. We’d love to talk with you about your goals and service needs. Visit umbfs.com to learn more and contact a business development representative. Alternative Investment Services A C C O U N TA N C Y H O W T O S TA R T A H E D G E F U N D I N T H E U S 2 0 1 4 LESSONS FOR NEW EMERGING FUNDS NICK TSAFOS, MIKE LAVEMAN AND JEFF PARKER LOOK AT BEST PRACTICES FOR FORMING A FUND AND EXPLAIN HOW EISNERAMPER CAN HELP WITH THE PROCESS L aunching a hedge fund can be a daunting and complicated process, with various factors to take into consideration and pitfalls to avoid along the way. EisnerAmper provides services to managers forming new funds and helps them incorporate best practices and standards. HFMWeek caught up with partners Nick Tsafos, Mike Laveman and Jeff Parker to find out more. Nicholas Tsafos is an audit partner with 25 years of diversified accounting and auditing experience. His practice is primarily devoted to hedge funds, private equity funds, broker-dealers in securities, registered investment companies and investment advisers. Michael Laveman is a tax partner and member of the Financial Services Group. He is involved in the structuring of investment funds and related entities, as well as in providing advice on the tax complexities of financial products and investment strategies. HFMWeek (HFM): What are the key considerations for hedge fund managers starting up in the US? Nick Tsafos (NT): Most important is regulation. Fund managers in the US need to understand the regulations around hedge funds here, for example the ’33 Act, ’34 Act, ’40 Act, Dodd-Frank, and JOBS Act. When you’re devising a strategy for a hedge fund you need to keep these all in mind because regulation has control over all the operations. In addition, the regulations are ever-changing – and growing. What’s even more important in terms of raising capital is having a business plan. A lot of advisers who start a fund think that if they just talk about their strategy, investors will want to invest. That doesn’t happen anymore. It’s very important to develop a business plan that talks about your business strategy, how you’re going to execute that strategy to achieve the rates of return that you hope to achieve, and the capital levels to which you want to grow. By putting everything down on paper, you’re making and documenting decisions about the type of service providers you’re going to need, the type of infrastructure you’re going to build to meet the regulatory requirements, and the needs of investors. Investors also want to see that you’re capable of executing the business plan you present. It’s very important that you can persuade your investors to buy into what you’re doing and that you’ll be able to do it. These elements will set you apart from other investment advisers. and running today than it did five years ago because of the challenging fund raising environment. Managers should make sure they have enough start-up capital to get them through this period. Building an infrastructure that can grow as the fund grows in complexity and size is very important. Many fund managers focus on the near-term, but also need to spend time thinking ahead to what challenges they will face in the future. Having flexibility in the fund documents is a critical part of this. It is also important for fund managers not to neglect allocating time related to setting up their management companies and incentive fee vehicles as well as considering employee compensation issues. Finally, making sure that you’re working with the right service providers, with the right experience and expertise who can grow with your business is very important. IT’S VERY IMPORTANT THAT YOU CAN PERSUADE YOUR INVESTORS TO BUY INTO WHAT YOU’RE DOING AND THAT YOU’LL BE ABLE TO DO IT HFM: How can EisnerAmper help new hedge fund firms during the start-up stage? ML: We’ve been working with hedge fund managers for more than 30 years, many of which are (or started with us when they were) emerging managers. We have a high level of partner involvement from day one. We deal with all the practical implications of starting up a new business. A lot of start-up managers don’t have a business plan or the expertise of running a business so we spend a significant amount of time on the structuring issues, types of entity to set up etc. It’s something that we’ve really excelled at for many years. We can also provide business advice on insurance needs, assist with IT/space consulting, provide outsourced CFO services, and make introductions to resources which may be able to help the manager grow. Tax planning for the manager, especially in the estate tax area, is also a very important topic we discuss. One particular service that we are seeing a demand for, particularly from smaller managers, is for us to review past performance returns. Typically referred to as agreed-upon procedures, these attestation services can provide potential investors additional comfort from the returns the managers are touting in their marketing materials. ” HFM: What key pitfalls should a new manager avoid? Mike Laveman (ML): These days you need to have realistic timing expectations of getting a fund off the ground. It probably takes two or three times longer to get a fund up H F M W E E K . CO M 9 A C C O U N TA N C Y H O W T O S TA R T A H E D G E F U N D I N T H E U S 2 0 1 4 current and advise them on a host of issues relevant to their ventures. HFM: What factors do new fund managers need to consider from a tax perspective? JP: Within a fund’s strategy there are certain tax ramifications, such as whether the fund is classified as a trader or an investor. This has a large tax effect on the ability to take deductions. By better understanding the rules and their implications, managers can structure their funds to support their strategies with optimum tax efficiency. Certainly doing business in New York City is significant from a marketing perspective but it is also very expensive. Managers need to understand the pros and cons and whether it makes sense to incur the tax costs to be in New York. Structuring of management companies has other effects as well, such as self-employment tax and the new net investment income tax, also known as the Obamacare tax. Another area that’s also become very important from a tax perspective is Fatca. Fortunately we have a lot of expertise in this area; Mike Laveman is one of the co-leaders of our Fatca initiative. The structuring and much of the registration obligations need to be happening right now, so funds need to make sure they have the flexibility and understand what they need to do under Fatca. NT: Our clients consistently rank us very high for client service. We’re always willing to talk about and share our knowledge. Jeff Parker (JP): One thing that we always stress internally to our employees and partners is that the investors in the funds are the fund managers’ clients. Whether it’s timing of deliverables or expertise, we really pride ourselves in advising fund managers for the benefit of their investors. HFM: How does EisnerAmper’s service stand out or differ from the competition? JP: One way in which we stand out is with our size. We are large enough to have the right amount of expertise but small enough to still be able to provide great service. With regard to our fund practice in general, a significant portion of our client base is funds. At the same time, we have substantial experience in what I would call ancillary services, such as valuations, international planning, state local planning and personal tax services, etc. Many of our clients see value in taking advantage of these as well – and appreciate the comprehensive perspective it allows us to bring to their ventures. We often find that our clients may have a relationship with a smaller accountant who has been handling their personal work for years, but they quickly realise that they have outgrown them and need personal income tax preparers that really understand the fund world. Another thing that makes us different from our competitors is that we’ve got a very high degree of partner involvement, from the initial proposal stage to servicing our clients. Some of our competitors may bring in top-level people for the initial meeting, but they do not get involved in the details of the engagement. NT: What’s also of value are our offices in the Cayman Islands and India, which provide us an international perspective and presence. We have the kind of expertise not typically expected of firms our size. JP: We also provide a lot of education for our clients through webinars, events and publications to keep them 10 H F M W E E K . CO M Jeffrey S. Parker, CPA, MBA, MST, JD, is a tax partner specialising in advising investment partnerships, funds of funds and broker-dealers, including structuring and compliance. Jeff also advises fund managers on personal tax returns and planning. HFM: What standards do fund managers need to meet to ensure best practice? NT: Investment advisers have to be able to show that they can meet all the regulatory requirements and provide information to investors. They need to have a good understanding of the business environment that they’re in and be able to showcase that understanding when they’re speaking to investors. We ensure they not only do it right – but can aptly discuss the issues and nuances. The managers also need to ensure that they understand the investors’ needs and how those needs fit into their investment strategies as well as the operational infrastructure. Because of our experience advising clients with an eye towards their investors, we can provide insight to those needs. Managers also need to have an infrastructure that gives them a platform to support many investment vehicles, not just hedge funds. Whatever the case may be, investment advisers need to understand the business environment, the implication of their structure and options, and be able to discuss them in a manner that impresses investors. Q OUR CLIENTS CONSISTENTLY RANK US VERY HIGH FOR CLIENT SERVICE. WE’RE ALWAYS WILLING TO TALK ABOUT AND SHARE OUR KNOWLEDGE ” W H E N I T C O M E S T O Y O U R C PA F I R M . . . Is bigger better? Our focus on the hedge fund and managed futures industry keeps you and your investors safe. Experience you can rely on since 1974. Experience Reliability W W W. A R T H U R B E L L C P A S . C O M Audit & Assurance Tax Performance Analysis Investor Representative Family Ofﬁce Services Consulting H O W T O S TA R T A H E D G E F U N D I N T H E U S 2 0 1 4 STARTING YOUR ALTERNATIVE INVESTMENT BUSINESS FRANK NAPOLITANI OF CONCEPT CAPITAL DISCUSSES THE STEPS INVOLVED IN STARTING UP AN ALTERNATIVE INVESTMENT FUND S Frank Napolitani is a managing director in the Prime Services Group of Concept Capital Markets in New York. Frank has spent the past 16 years in the hedge fund industry as an analyst at a fund of funds, portfolio manager at a family office and in a managerial/business development role in prime brokerage since 2005. tarting your own alternative investment fund is a formidable undertaking, and while it can be an exciting and lucrative endeavour, it will require a great deal of thought and careful planning. Concept Capital has been involved in new fund launches for many years and has played a key role in assisting a large number of managers to get started as well as to navigate their various growth phases. Our experience suggests that when investment managers make the right decisions early on, it dramatically enhances their success rate. As managers embark on their new venture, you’ll want to consider the following: DEVELOPING A BUSINESS PLAN By writing a detailed business plan, you will increase the odds of succeeding as an entrepreneur. It will not only help you articulate your investment strategy and process, but importantly also understand the financial undertaking you’ll be committing to in order to establish and manage a sound business. Writing a business plan is an excellent way to determine whether or not the idea of starting your new business is feasible. CHOOSING A STRUCTURE There are a number of legal issues to consider when deciding how best to structure your fund management business. Complying with applicable laws is important throughout the entire process, both prelaunch and after the fund/business is up and running. Selecting a fund structure is equally critical as you’ll have to consider the costs of varying ones and the flexibility that they will afford you and the investors you hope to attract. Among the options are the following: Incubator hedge fund: Ideal for portfolio managers who are looking to incubate their investment strategy with their own personal capital for a set period of time to build a track record. Domestic hedge fund: Appropriate for investment by US-based taxable investors. Offshore hedge fund: Appropriate for investors located outside of the United States or tax-exempt US investors such as qualified pension plans. Side by side structure (onshore & offshore funds): Accommodates both domestic and foreign investors, but could result in operational inefficiencies and slippage between the two funds. 1 2 H F M W E E K . CO M Onshore/offshore master feeder structure: Accommodates the efficient management of one pool of capital for the investment manager as all portfolio positions are held in the master fund, with the feeders holding shares in the master. Separately managed account (SMA) platform: SMAs allow investors to allocate to hedge fund managers without commingling assets. The investor retains control of its assets, has complete transparency into the advisor’s activity, and enjoys the ability to disengage from the manager on very short notice. 1940 Act – liquid alternative mutual fund structure: Allows hedge fund strategies to be packaged into mutual fund structures for broader distribution into the “advice channels” of registered investment advisors (RIAs), traditional financial advisors and wire-house brokers. These are attractive to investors unable to, or prohibited from, investing in private placements. Ucits fund structure: Allows funds to operate under a set of European directives that are aimed at allowing commingled investment pools to operate freely throughout the European Union (EU) on the basis of a single authorisation. Insurance dedicated fund (IDF) structure: The insurance structure allows high-net-worth individuals, family offices and/or corporations to invest in alternative investment funds on a more tax efficient basis using insurance products as the source of funding. SELECTING SERVICE PROVIDERS After selecting the fund structure you will employ, you will need to choose the service providers that will help you execute your plan. These include legal counsel, auditors/accountants, fund administrators, and of course, prime brokers. As a new organisation, and with a relatively low asset base, it is widely expected and accepted in the investment community that many of the key, noninvestment related functions in your business will be outsourced. This is a less expensive and more efficient route by which to implement best practices throughout your organisation. LEGAL If you choose a traditional domestic hedge fund structure, you will need to create the following three entities: general partner (GP), investment management company (IM) and the fund. The GP and IM are often organised FUND SERVICES as Limited Liability Companies (LLC). The GP engages the IM through an Investment Management Agreement (IMA) to manage the fund. The IM is paid the asset based management fee, generally 1%-2% of assets, and the general partner receives the incentive allocation, often 20% of net new profits. The fund’s offering documents will comprise a private placement memorandum (PPM), limited partnership agreement (LPA), and subscription documents. While drafting your fund offering documents with legal counsel, there are key issues to consider when determining the fund’s investment terms, including minimum investment, management fee, incentive allocation, founders’ class, subscription dates, lockup, redemption notice, redemption period, and gate provision. ACCOUNTING Your accounting firm will provide audit, tax and estate planning services. The accounting firm you choose should have experienced staff, thought leadership, access to senior practice leaders, and technology expertise. FUND ADMINISTRATION The fund administrator is responsible for maintaining the official books and records of the fund and performance reporting to investors. There are many firms offering such services, so you will want to select one whose experience and capabilities best match your needs. Many administrators provide a comprehensive, turnkey solution, including client on-boarding, online reporting portal, shareholder services, portfolio reporting, and performance and fee calculations. PRIME BROKER Because an investment manager is trading securities on a daily basis, the prime broker often is the main cog in the wheel of the service provider relationships, generally offering custody and clearance, execution, securities lending and financing, and portfolio reporting services. Some offer more extensive services, including portfolio and risk analytics and reporting and capital introduction, while others, through affiliates, also provide middle and back office services and IT and office support. When considering your prime brokerage options, it’s important to investigate each firm’s capabilities and how the respective offerings match your specific anticipated needs. MIDDLE OFFICE SOLUTIONS These are the daily operational solutions that will allow investment managers to benefit from an independent daily workflow that includes trade capture, confirmation, settlement, and reconciliation; trade error resolution; position and valuation reconciliation; corporate actions; shadow books and records; and month-end reconciliation with the administrator. As an emerging manager, outsourcing your middle/back office operations to a high quality partner will allow you to focus on your core competencies and generating returns. Institutional investors also tend to appreciate the value of a third party’s review of such matters. MARKETING/CAPITAL RAISING Managers need to clearly articulate their investment strategy and investment process, and summarise the management team’s capabilities. Building a relationship with the investment community is a key component to an investment firm’s growth, and this will entail identifying appropriate potential investor types and concentrating on those potential investors with the highest probability of closing. Q Concept Capital Markets, LLC offers emerging managers a comprehensive set of solutions ranging from extensive pre-launch consulting, to custody, clearing and execution, to post-trade and ancillary operational support, portfolio and risk reporting, and office infrastructure and IT support. As our client, you will benefit from our seasoned team, our client centric service model, our extensive market expertise, and our top-tier technology platform. Concept Capital Markets, LLC is a dual registered broker-dealer and registered investment adviser with SEC, member FINRA, NFA, and SIPC. H F M W E E K . 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E 18 14 EVERY WEEK YOU WILL RECEIVE Ô More exclusive stories than any other hedge fund publication Ô All the latest searches and investment news Ô Exclusive data on launches and performance Ô Investment strategy analysis Ô Topical comment from leading industry figures Ô Exclusive research surveys Ô Regulatory developments Ô People on the move As a subscriber, you will also receive full registration to www.hfmweek.com, where you can access: Ô Daily updated performance data Ô Exclusive research Ô Daily news alerts Ô Industry events information Ô Service directory listings and much more... F O R M O R E I N F O R M AT I O N P L E A S E CO N TA C T v email [email protected] Richard Freckleton at +44 (0)207 832 6593 OR O R V I S I T H F M W E E K . CO M FO R D E TA I L S INVESTMENT ACCOUNTING H O W T O S TA R T A H E D G E F U N D I N T H E U S 2 0 1 4 STRENGTH FROM WITHIN COREY MCLAUGHLIN OF ARTHUR BELL CPAS EXPLAINS THE IMPORTANCE OF INTERNAL CONTROLS AND INFRASTRUCTURE TO MANAGERS STARTING A HEDGE FUND I Corey McLaughlin is the member in charge of audit, assurance and advisory services at Arthur Bell CPAs. For 16 years, he has helped managers in the hedge fund and managed futures industry prepare their operations to satisfy audit, shareholder, and investor requirements. n today’s environment, managing a hedge fund has become increasingly difficult due to evolving regulatory requirements, a higher demand for transparency, and more complex due diligence processes. For managers looking to launch a fund in the US, the task can seem daunting. One of the biggest challenges with starting a fund is raising capital, which is the life blood of the manager. Yet many managers overlook the importance of having the right internal controls and infrastructure in place to attract investors. Given the impact of frauds on the industry, investors have increased their due diligence procedures prior to investing in a hedge fund. In particular, investors require longer track records and focus more on the manager’s operations. As such, managers must be committed to establishing processes, systems, and experienced teams that build investor confidence in the manager’s ability to protect investor money, data, and privacy. Internal controls are crucial because investors want to know their assets are safe. Proper internal controls prevent and/ or detect any misappropriation of assets. Prevention is obviously the strongest and most desired approach. When developing processes around controls, managers should validate that one individual is not able to steal or manipulate assets of investors or the management company. Managers should also consider if any person in control has a self interest to commit fraud or collusion. As managers design their internal control procedures, they should focus on segregation of duties. An efficient way for start-up managers with limited resources to segregate duties over investor assets is to involve an independent third-party administrator that is responsible for approving cash disbursements and preparing accounting separate from the manager. In addition, as managers document their internal controls, they should include policies that address investor concerns around privacy, data protection, and employee trading practices. Nowadays, we see managers launching funds with fewer assets under management, so they feel more pressure to make operational decisions based on costs. Even if starting a fund with limited resources, it’s important for managers to think strategically about how to build a so- phisticated and scalable infrastructure that will support their business needs and investor demands over time. As an example, managers should ask themselves how they can manage the trading and investor inquiries while also avoiding regulatory, compliance, tax and accounting pitfalls. For most managers, this means hiring a chief operating officer (COO), either in-house or third-party, that has experience with financial operations, internal controls, regulatory requirements and vendor selection. A strong COO also knows how to maximise the use of reputable attorneys, compliance advisers, administrators, auditors and tax professionals. The guidance of experienced advisers who understand the hedge fund industry will help the manager and COO prevent issues that can be expensive to resolve and that might damage the manager’s reputation. Building a team of advisers who care about the manager’s success makes a big difference. These advisers devote additional time to helping the manager through the various start-up and growing pains that occur over the first few months and years of launching a fund. In particular, the manager should immediately hire legal counsel that is familiar with hedge funds and is willing to collaborate with audit and tax advisers when setting up the fund. Legal and tax planning are critical at this stage to ensure that the entities are structured efficiently from an operational, tax and cost perspective. A manager should avoid attorneys who use standardised templates resulting in more complex and expensive structures that ignore the manager’s current needs, facts and circumstances. Good legal counsel works with the manager to strike a balance between what works for the manager today and what provides flexibility for growth and attracting new investors in the future. When hiring an independent auditor, the manager should consider auditors with a good reputation in the industry. Also, having the financial statements of a hedge fund audited from inception will show potential investors that the manager takes financial reporting seriously and goes the extra mile to ensure that the financial statements are independently examined. Sometimes managers make the mistake of assuming an audit is all they need to have an effective internal con- INTERNAL CONTROLS ARE CRUCIAL BECAUSE INVESTORS WANT TO KNOW THEIR ASSETS ARE SAFE. PROPER INTERNAL CONTROLS PREVENT AND/OR DETECT ANY MISAPPROPRIATION OF ASSETS ” H F M W E E K . C O M 15 H O W T O S TA R T A H E D G E F U N D I N T H E U S 2 0 1 4 trol environment. However, an auditor is only required to gain an understanding of internal controls to assess the risk of material misstatement of the financial statements. An audit does not test the operating effectiveness of the manager’s internal controls to identify all of the deficiencies. Therefore, even with an audit, the manager needs to establish an effective infrastructure and internal control environment. When it comes to compliance with regulatory and tax matters, managers should always consult with experienced compliance and tax advisers. Compliance is one area that managers should not ignore. There are too many industry and tax regulations for one person to follow. If a manager misses a deadline or fails to register properly for a regulatory requirement, the penalties can be costly and severe. Managers should avoid any missteps that could earn them a reputation for disregarding the rules, even if by mistake. Setting up internal controls, building infrastructure, and hiring a team of experienced advisers – either internal or external – cost money. So managers often ask what level of capital is appropriate for launching a hedge fund. There is no one right answer to this question, as it can be facts and circumstances driven; however, we typically recommend that anyone launching a fund under the $5m range should consider setting up separate managed accounts until they have enough capital to absorb the annual operating costs of a hedge fund. Separate managed accounts allow emerging managers to establish a performance track record, which is important, particularly to institutional investors, as they try to raise capital for the 16 H F M W E E K . CO M INVESTMENT ACCOUNTING SETTING UP INTERNAL CONTROLS, BUILDING INFRASTRUCTURE, AND HIRING A TEAM OF EXPERIENCED ADVISORS – EITHER INTERNAL OR EXTERNAL – COST MONEY ” fund. In addition, an independent auditor familiar with the hedge fund industry can examine the performance history to provide comfort to potential investors, similar to the audit of a fund. Once proper controls and infrastructure are in place, managers should gain a higher level of investor confidence in their ability to handle and protect investor assets, data and privacy. As a result, these managers are better prepared to market to a larger group of investors worldwide. Also, as the manager becomes more established, a scalable infrastructure will allow the manager to grow and leverage the procedures already established. In today’s hedge fund industry, a manager can’t afford to not invest in having sound internal controls and a good infrastructure, especially if raising capital is a concern. Q WE PRACTICE LAW BUT WE LIVE BUSINESS Sadis & Goldberg represents over 600 hedge and private equity funds. Above all else, we value our client relationships. Our attorneys strive to provide excellent, consistent, practical and efficient legal services. We distinguish ourselves from other law firms by assisting our clients in the development of their businesses. This comprehensive approach has often earned us recognition as one of the top five law firms in the U.S. for our hedge fund practice. Invest a few minutes to learn what our attorneys can do for your business. Best Law Firm Hedgeweek USA Awards 2011 Investment Funds’ Law Firm of the Year Finance Monthly, 2010 - 2013 Best Hedge Fund & Private Equity Law Firm USA InterContinental Finance 2011 - 2013 Lawyers World Leading Lawyer Award 2012/ Best Hedge Fund Law Firm - USA -2013 Global Awards 2011 and 2012 Private Funds Law Firm of the Year ACQ Law Award 2011 - 2013 Financial Services Industry Law Firm of the Year - NY, Acquisition International 2013 Law Firm of the Year – Private Funds, DealMaker Law Awards, 2011 - 2013 / Deal Maker Global Awards 2012 - 2013 Private Funds Law Firm of the Year M&A International Global Award 2013 Hedge and Private Equity Fund Formation | Transactional Counseling Compliance Services | Regulatory Representation | Litigation | Derivatives Tax, ERISA and Estate Planning | Real Estate 551 Fifth Avenue, 21st Floor New York, NY 10176 212.947.3793 www.sglawyers.com H O W T O S TA R T A H E D G E F U N D I N T H E U S 2 0 1 4 A HELPING HAND MICHAEL VON BEVERN OF U.S. BANCORP FUND SERVICES DISCUSSES THE DIFFICULTIES IN STARTING UP A HEDGE FUND S tarting up a hedge fund is more complex than the emerging manager might first realise, bearing many hurdles which need to be overcome in order to be successful. Prospective fund managers need to understand the difficulties along the way as well as the best resources to provide a helping hand. Michael Von Bevern of U.S. Bancorp Fund Services gives the full story on what they need to know. Michael Von Bevern serves as a head of US operations in the Alternative Investment Solutions division, having joined U.S. Bancorp Fund Services through the acquisition of AIS Fund Administration in December 2012. Von Bevern began his career in the audit practice of KPMG LLP and has more than 20 years of experience in the financial services industry. 18 H F M W E E K . CO M HFMWeek (HFM): What main pieces of advice would you give to emerging managers starting out in the US? Michael Von Bevern (MVB): Today’s emerging managers face a daunting task. The markets are challenging, costs are increasing, and competition for investor capital from overseas markets along with large, well-established US funds pose a significant barrier to entry. Additionally, as the flow of talented traders and aspiring fund managers from investment banks increases, they face many difficult and complex business decisions that they more than likely are not prepared for and did not have to deal with as a member of a larger organisation. Putting aside how difficult it is to find qualified investors, an emerging manager is faced with many issues related to running an entire business such as corporate real estate, payroll, legal, business continuity planning and regulatory and compliance requirements that are PUTTING ASIDE HOW DIFFICULT IT IS TO FIND QUALIFIED INVESTORS, AN EMERGING MANAGER IS FACED WITH MANY ISSUES RELATED TO RUNNING AN ENTIRE BUSINESS ” part of being on your own. In most cases, picking a trading strategy and fund structure turns out to be the easy part. Finding the right service providers and negotiating an array of legal agreements, while trying to navigate an increasingly complex operating environment FUND SERVICES that has matured to the point where only the strong will survive, only adds to hurdles one must face. Starting up a hedge fund is much more complex than trading is; you have to be an exceptional trader, but you also have to be a great risk manager, good at performing operations and have the ability to understand regulatory issues. It’s more like being the CEO of a business. Unfortunately, the barriers to entry are pretty low in the hedge fund business. You can start hedge funds pretty much at will, but the successful managers are the ones who understand the breadth of knowledge that is needed to survive in this business. I would say to emerging managers: do your homework and your due diligence, and perform the right tests and checklists. If you don’t have the right partner that is culturally a good fit for you, it can be very difficult to be successful in the long term. HFM: What are the biggest challenges facing emerging managers in the US and how they can be overcome? MVB: One of the biggest challenges facing start-up managers is the realisation that the alternative asset business is vastly complex and that without size and scalability, issues such as technology, middle and back-office costs, marketing and investor relations functions and legal costs can be a significant obstacle to overcome. All of these hurdles have caused emerging managers to fail to get off the ground. As a group, emerging managers are usually pretty optimistic on their chances for success and that optimism and drive to create and succeed has fuelled our industry since its inception. However, given the landscape in 2014, I recommend that emerging managers avail themselves of the many competent and knowledgeable business partners that exist to help guide them towards a successful launch. To that point, I would add that identifying service providers that are true partners in your business and who are vested in your success is vitally important. An experienced legal team, focused auditors and an independent administrator that provides the same level of services to small emerging managers as they do for their largest clients can make the difference in the long term success of the fund. HFM: What are the main trends currently in the US hedge fund sector and how do they impact start-up funds? MVB: At U.S. Bancorp Fund Services, we see many of our emerging managers dealing with a variety of issues. The most prominent are the ability to attract investor capital, draw on investor commitments and launch a fund with enough size and scale to cover their cost basis. Unfortunately for emerging managers, larger, more established funds have been more successful in attracting new investor money in the past and that trend continues today. Additionally, emerging managers now face increased regulatory requirements that larger managers with more robust support systems have just finished or are still digesting. Lastly, the investor community continues to demand lower fees, increased transparency and com- plex reporting, requiring emerging managers to invest in state-of-the-art technology and to outsource support functions when previously they could forgo these costs until they had reached a critical mass. From a new business perspective, we are seeing an increase in registered alternative funds or ‘liquid alts’ and other investment vehicles, such as business development companies and insurance dedicated funds, which indicates that emerging and existing managers realise the key to initial and future success is to expand the array of strategies and products they offer to meet investor demands. HFM: What are the benefits of the US as a location to start up a hedge fund? MVB: Contrary to popular belief, it is still possible to launch a hedge fund today in the US. Recent data does indicate that the Asian and European markets are seeing the largest inflows of new money, but that doesn’t mean that a new US-based manager, with a well-designed business model and dedicated and complementary business partners cannot be successful. Every year we see many EMERGING AND EXISTING MANAGERS REALISE THE KEY TO INITIAL AND FUTURE SUCCESS IS TO EXPAND THE ARRAY OF STRATEGIES AND PRODUCTS THEY OFFER TO MEET INVESTOR DEMANDS ” US-based managers launch successfully, and the common denominator is a focused and diligent approach to building a business that will endure for the long term and not the next three to five years. HFM: How do you foresee the hedge fund space evolving in the next 12 months, particularly in relation to start-up funds? MVB: Over the next year, I foresee a steady increase in alternative investment products and strategies, an increase in hedge funds with more private equity-like features, such as performance fees based on carried interest models, as well as more investor transparency and access to data and increased due diligence. All of these trends indicate that investors are driving the future of the hedge fund industry. Hopefully over the next 12 months we will see an increase in the allocation to the alternatives asset class. My hope would be that all fund managers will be given the opportunity to focus on more desirable technology initiatives such as client-facing portals, trading and order management systems and middle and back-office technologies that will actually help them to grow their business and increase margins. Q H F M W E E K . C O M 19 FUND SERVICES H O W T O S TA R T A H E D G E F U N D I N T H E U S 2 0 1 4 MAKING THE LEAP JERRY WRIGHT OF UMB FUND SERVICES ANSWERS THE BURNING QUESTIONS MANAGERS HAVE ABOUT LAUNCHING A HEDGE FUND I Jerry Wright has over 13 years of accounting experience in the alternative investment industry, and extensive experience helping clients launch new funds and resolve operational challenges. He holds a minor in personal financial planning, a bachelor’s degree in accounting, and an MBA from Utah State University and is a certified public accountant. n today’s challenging environment, investors are looking for increasingly longer track records, more transparency, and are placing even more importance on the strategies and internal controls of a fund. As a result, prospective fund managers must focus more than ever on having a solid strategy and building a positive, three-year track record before considering launching a fund. Developing a great track record and reputation for strategy execution proves resilience in the market and will be crucial in attracting large investors. I frequently field basic questions from potential startup managers. Many of these funds will not make it to launch because managers are not fully prepared to enter this space. Some hear there is money in the industry, small barriers to entry and want to make money without having a passion for investing, which is a common mistake. Others are more prepared to make the move and quit their day jobs. In this article, we’ll take a look at some of the most common questions start-up managers ask. The answers can help them determine this industry is not for them, or fuel them to work harder to make the leap as a prepared, knowledgeable manager. WHAT ARE THE FIRST STEPS IN SETTING UP A HEDGE FUND? The first step is determining whether hedge fund management is the right career for you. If you don’t have a passion to invest or a great idea you are willing to sell to friends and family in order to get the needed seed money, then there is little chance of success. Once you are committed, you need to establish a relationship with a reputable law firm experienced in hedge funds to help create the needed legal documents and offerings. Excellent legal work is not cheap, and I recommend considering a few firms and then letting them compete for your business. Next, you will need to find a reputable administrator who can walk you through the operational processes and set up controls that will enable you to develop best practices and eventually become an institutional investor-ready firm. From there, it is important to establish a broker account and a bank account in order to start accepting seed money from friends and family. Friends and family should complete subscription documents so they fully understand the terms and risks of their investments. WHAT COSTS ARE ASSOCIATED WITH LAUNCHING A HEDGE FUND AND HOW MUCH CAPITAL WILL I NEED TO BE PROFITABLE? The cost of launching a hedge fund depends on a myriad of factors. However, attorney costs typically range from $20,000 to $70,000 to create legal documents for a new H F M W E E K . C O M 21 H O W T O S TA R T A H E D G E F U N D I N T H E U S 2 0 1 4 FUND SERVICES performance and to market the fund to potential investors. hedge fund. You will likely need to engage an audit firm and administrator in order to have an independent company verify the existence and value of your investments. For a start-up fund, the fees range from $15,000 to $60,000 per annum for an audit firm and from $20,000 to $70,000 for an administrator. Fund expenses, such as tax, also have to be taken into consideration, which can add up to $10,000 to $20,000. These fees can be a big drain on a start-up and can cut into performance. Therefore, the recommended start up capital is $10m, otherwise start-up expenses will be too much for the fund to handle and will negatively impact performance. Some managers with limited resources opt for an incubator fund, where they scale back services. Once they have reached the recommended $10m, they can officially launch. WHAT DO I NEED TO INCREASE MY CHANCES OF HAVING SUCCESS AS A NEW HEDGE FUND MANAGER? WHAT ARE THE OBSTACLES THAT I WILL NEED TO OVERCOME? When it comes to building a new hedge fund, there are three factors that can increase your chance of having success: strategy, performance and distribution. Your strategy is critical in the growth of your fund. It must be simple and easy to explain to investors why they should invest in your strategy and why you are the right person to make it work in practice, not just in theory. Without a great strategy it is an uphill battle to get distribution, which is crucial in raising assets. Success will require hiring the right people to help you once you have enough assets. Until you have the needed capital, it is difficult to hire anyone to help you market your fund, therefore many start-up managers work double, both to generate 22 H F M W E E K . CO M WHAT ARE SOME WAYS I CAN POSITION MY FUND TO ATTR ACT INSTITUTIONAL INVESTORS? Institutional investors expect the hedge fund to have a robust compliance team and system. They want to know that funds are working with a recognisable PCAOB audit firm that performs an independent audit and that the fund has a reputable administrator. Having the right service providers and controls in place allows investors to have more confidence in the fund. The controls put in place by the administrators needs to provide both prevention and detection of misuse of capital funds. Prevention is the most important factor. An institutional investor wants to know that controls are in place preventing money from leaving the fund without an administrator signing for it and making sure that money leaving is in agreement to the offering documents. Institutional investors require a high amount of due diligence in considering a fund. They will run background checks on key employees, and require that there are robust disaster recovery standards and that the investment managers are also registered with the SEC. They expect the fund to be fully compliant with their specific standards. After the institution is confident that operations are in compliance with their standards and that the strategy fits their needs, they will then look at the track record of the fund manager. Additionally, institutional investors need every assurance they can really trust the manager in implementing the agreed-upon strategies and that investors’ money will not be misused. HOW WILL THE FEE COMPRESSION IMPACT MY START-UP FUND AND WHAT ARE THE DIFFERENCES TO CONSIDER STARTING A HEDGE FUND AFTER THE LAST FINANCIAL CRISIS? At the moment, management fees are being compressed and costs of running funds are increasing. The industry has become more regulated and with this regulation comes increased expenses while at the same time revenue from WHEN IT COMES TO BUILDING A NEW HEDGE FUND, THERE ARE THREE FACTORS THAT CAN INCREASE YOUR CHANCE OF HAVING SUCCESS: STRATEGY, PERFORMANCE AND DISTRIBUTION management fees and incentive fees is decreasing. Investors are coming in with more money and expect lower performance fees and management fees so the days of starting a hedge fund with $1m from friends and family are over. There are increased barriers of entry into the market after the events of the 2008 financial crisis. In many cases today, institutions or high-net-worth individuals want to know how a hedge fund manager performed during the 2008 financial crisis, which puts newer funds without that track record at a decided disadvantage. Q ONE COMPLETE MULTI-PRIME SERVICE PLATFORM DESIGNED TO LET YOU FOCUS ON WHAT’S IMPORTANT Concept Capital Markets, LLC offers a comprehensive suite of brokerage and related services that provide traditional and alternative investment managers with solutions that are customizable and scalable. The firm was built by former investment managers to serve hedge fund managers, managed account platforms, institutional investors, family offices, and registered investment advisors with turn-key solutions designed to free its clients to focus on their core competencies. Our offering features world-class custody and clearing options, multi asset class capabilities, leading execution and order management systems, a seasoned execution desk, a range of financing options, a highly professional operations and customer support team, comprehensive portfolio reporting capabilities, and capital introduction. CONCEPT CAPITAL MARKETS, LLC www.conceptcapital.com MEMBER FINRA, NFA AND SIPC Jack D. Seibald Managing Member 516.746.5718 [email protected] Michael S. Rosen Managing Member 516.746.5723 [email protected] GARDEN CITY, NY I NEW YORK, NY I GREENWICH, CT I ATLANTA, GA I SAN FRANCISCO , CA EL SEGUNDO, CA | LOS ANGELES, CA I BOCA RATON, FL © 2014 Ernst & Young LLP. All Rights Reserved. ED None. Where’s the hedge fund industry headed? We know. In our 7th annual global hedge fund and investor survey, we offer you a glimpse into the minds of more than 150 of the top managers and investors. From strategic priorities to regulatory compliance, we’ve got powerful insights into leading trends — information you can use to steer your business and investments. A better working world starts with yours. LgÕf\gmlegj]$nakal ey.com/HedgeFundSurvey.
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