Occasionally I run across some unique investment opportunities that are only open to high net worth individuals due to the Investment Company Act of 1940. Let me know if you'd like me to share these.
An “Exempt Reporting Advisor” does not need any licenses to manage a fund up to $150-million AUM. Talking with people about said fund is part of managing it.
With this being said, the #1, #2 & #3 question that I've not seen asked is, "What basis was applied to perform an in-depth quantitative RISK analysis to determine this "opportunity's" actual Risk Score over (at least) one complete (prior) market cycle?"
I ask because if Michalis Kapsos’s 2014 paper on the “Mathematical Restatement of Keating and Shadwick’s Omega Ratio” has not been applied as a foundational component of assessing this ‘opportunity’s’ RISK Score, then an objective, accurate method for evaluating the quality of this ‘opportunity’ has not been determined in as comprehensive a manner as is possible today. End of Story.
I haven't looked at the law for several years, but I think you are skirting the edges of legality with this offer unless you register as an investment advisor.
UPDATE: I did look at the law and I think you violate it by your offer. I'll contact the California DFPI and see what they say.
Yes, I am an informer. I think Steve Kirsch is violating the law, and ought to stop. He shouldn't be advising people on investments through this newsletter where he benefits from their investments unless he registers as an investment advisor so that his clients have the protection of the law. That's pretty well known and I am not sure why he is doing it.
You are right that simply inquiring who qualifies as a Qualified Client or Qualified Purchaser is not a problem. But if you start pitching any investments (publicly or privately) to those people you do (I think) need to be registered as a broker-dealer or an investment advisor under federal or state law.
As one example, Section 15(a)(1) of the 1934 Securities Exchange Act generally makes it unlawful for any broker or dealer to use the mails (or any other means of interstate commerce, such as the telephone, facsimiles, or the Internet) to "effect any transactions in, or to induce or attempt to induce the purchase or sale of, any security" unless that broker or dealer is registered with the SEC in accordance with Section 15(b) of the Act.
Whether you would be a broker under the Act is a question I can't answer definitively, but I think you would. But there are exemptions for finders and others so maybe you could fit into one of those exemptions. I once knew quite a bit about these regulations but that was (thankfully) decades ago. I've been doing more productive things since then.
The purpose of registration under the Act is to prevent harm rather than to remedy harm already sustained. When you have a popular newsletter about a non-financial subject and (potentially) use that popularity to tout investments from which you benefit, an alarm bell goes off in my head. I don't think that's a good idea. Those you are pitching to deserve the protections given by the Act.
Aside from registration being required by law, if one of those investments doesn't pan out, unless you register you could (and I think should) be liable for the losses of those you enticed into investing.
In my opinion, the investing climate these days is fragile and highly manipulated by money printing, money laundering, propaganda and corruption. Since the GFC, those in power have printed over $20T with rates held artificially close to zero to keep the Ponzi "markets" propped up. I'm no risk taker, but this fraudulent and corrupt system could easily break down. I would only risk money that you are prepared to lose. If you look at the Shadowstats website which has kept track of various US economic indicators using the original formulas...inflation is actually 13% and unemployment is 25%. Most everything we are told is a lie.
Good luck to you Steve, and to all who have the opportunity and intestinal fortitude to take risks to enhance their wealth. Put it to good use.
I am not sure why people are upset with Steve. He describes himself as a high tech serial entrepreneur and philanthropist. And now investor.
That said, standard S&P 500 index funds beat the best hedge funds over a 10-year period with much lower fees. As to standard funds, the system is dynamic and the waters seem choppy, so it is never risk free.
the S&P is a great investment. You can do better, but it's difficult. There are experts who consistently beat the S&P, but those people are hard to find which is the whole point of this exercise.
Can investment management and trust companies make use of these high net worth investments if the individual's funds under management exceed the minimum?
I mean, for example, if someone has a trust fund and/or an Individually Managed Account at say, BNY Mellon Wealth Management, with assets of over $2 million in one or the other of the accounts, can the account manager invest any of the portfolio in the high net worth investments on behalf of the client? Following that line of thought, do they get the same tips for high net worth individual investments and routinely invest in them as part of their management strategy for qualified accounts over $2 million?
Possibly if one were to request certain investment they would oblige, but they will generally go by a preagreed degree of risk plan, which if it is moderate risk, may sacrifice the highest growth potential for a hedge against market downturns by investing a certain percentage in tax-free bonds. Are these high net worth individual investment tips riskier than, say, an index fund?
The #1 rule of investing should be asset preservation. I put all my assets into precious metals and numismatic coins around 25 years ago and then strayed from my original plan, big mistake. Giving all you can to the truly needy is the best investment you can make.
No. Just expensive. Free advice: own hens. I don't; yet. My neighbor started, so I save my cartons for her. Now she delivered me a free box of eggs a couple weeks ago🤗
Wow. Over 500 responses.
If you filled out the survey, I will be in touch soon.
Note you do NOT need to be in the US. And see the new definitions in the article.
An “Exempt Reporting Advisor” does not need any licenses to manage a fund up to $150-million AUM. Talking with people about said fund is part of managing it.
With this being said, the #1, #2 & #3 question that I've not seen asked is, "What basis was applied to perform an in-depth quantitative RISK analysis to determine this "opportunity's" actual Risk Score over (at least) one complete (prior) market cycle?"
I ask because if Michalis Kapsos’s 2014 paper on the “Mathematical Restatement of Keating and Shadwick’s Omega Ratio” has not been applied as a foundational component of assessing this ‘opportunity’s’ RISK Score, then an objective, accurate method for evaluating the quality of this ‘opportunity’ has not been determined in as comprehensive a manner as is possible today. End of Story.
I haven't looked at the law for several years, but I think you are skirting the edges of legality with this offer unless you register as an investment advisor.
UPDATE: I did look at the law and I think you violate it by your offer. I'll contact the California DFPI and see what they say.
Thanks John. Perhaps you can cite the section of the law I'm violating? That would be awesome!
Yes, I am an informer. I think Steve Kirsch is violating the law, and ought to stop. He shouldn't be advising people on investments through this newsletter where he benefits from their investments unless he registers as an investment advisor so that his clients have the protection of the law. That's pretty well known and I am not sure why he is doing it.
I'm simply inquiring who is a qualified client and qualified purchaser.
How is that illegal?
Cite the section of the law that is being violated.
I am not pitching any investments publicly.
And who did I harm? and what harm did they sustain?
You are right that simply inquiring who qualifies as a Qualified Client or Qualified Purchaser is not a problem. But if you start pitching any investments (publicly or privately) to those people you do (I think) need to be registered as a broker-dealer or an investment advisor under federal or state law.
As one example, Section 15(a)(1) of the 1934 Securities Exchange Act generally makes it unlawful for any broker or dealer to use the mails (or any other means of interstate commerce, such as the telephone, facsimiles, or the Internet) to "effect any transactions in, or to induce or attempt to induce the purchase or sale of, any security" unless that broker or dealer is registered with the SEC in accordance with Section 15(b) of the Act.
Whether you would be a broker under the Act is a question I can't answer definitively, but I think you would. But there are exemptions for finders and others so maybe you could fit into one of those exemptions. I once knew quite a bit about these regulations but that was (thankfully) decades ago. I've been doing more productive things since then.
The purpose of registration under the Act is to prevent harm rather than to remedy harm already sustained. When you have a popular newsletter about a non-financial subject and (potentially) use that popularity to tout investments from which you benefit, an alarm bell goes off in my head. I don't think that's a good idea. Those you are pitching to deserve the protections given by the Act.
Aside from registration being required by law, if one of those investments doesn't pan out, unless you register you could (and I think should) be liable for the losses of those you enticed into investing.
I haven't done any of the things that you hypothesize me doing.
And they updated the Marketing Rule. As long as you aren't deceptive, the marketing is permitted. And you cannot accept investors which don't qualify.
So I'm baffled what activities you believe I have done that you are seeking to report me for.
Thanks for your opinion. Very helpful.
Please tell me more.
Strikes me that the proposition is what America is all about)
In my opinion, the investing climate these days is fragile and highly manipulated by money printing, money laundering, propaganda and corruption. Since the GFC, those in power have printed over $20T with rates held artificially close to zero to keep the Ponzi "markets" propped up. I'm no risk taker, but this fraudulent and corrupt system could easily break down. I would only risk money that you are prepared to lose. If you look at the Shadowstats website which has kept track of various US economic indicators using the original formulas...inflation is actually 13% and unemployment is 25%. Most everything we are told is a lie.
Good luck to you Steve, and to all who have the opportunity and intestinal fortitude to take risks to enhance their wealth. Put it to good use.
Sigh! If only I wasn’t worth less $2M - I could be part of Steve’s 1% club (and not feel so gosh-darned worthless),:
https://www.bitchute.com/video/8ftbShzrkjl9/
INTENT TO HARM - EVIDENCE OF THE CONSPIRACY TO COMMIT MASS MURDER BY THE US DOD, HHS, PHARMA CARTEL
I am not sure why people are upset with Steve. He describes himself as a high tech serial entrepreneur and philanthropist. And now investor.
That said, standard S&P 500 index funds beat the best hedge funds over a 10-year period with much lower fees. As to standard funds, the system is dynamic and the waters seem choppy, so it is never risk free.
the S&P is a great investment. You can do better, but it's difficult. There are experts who consistently beat the S&P, but those people are hard to find which is the whole point of this exercise.
“Hello! I am a Nigerian Prince and...”
;)
That needs to be the CDCs new slogan.
grifters gonna grift...
Can investment management and trust companies make use of these high net worth investments if the individual's funds under management exceed the minimum?
i don't understand your question.
I mean, for example, if someone has a trust fund and/or an Individually Managed Account at say, BNY Mellon Wealth Management, with assets of over $2 million in one or the other of the accounts, can the account manager invest any of the portfolio in the high net worth investments on behalf of the client? Following that line of thought, do they get the same tips for high net worth individual investments and routinely invest in them as part of their management strategy for qualified accounts over $2 million?
Yes. Maybe but pretty unlikely.
Possibly if one were to request certain investment they would oblige, but they will generally go by a preagreed degree of risk plan, which if it is moderate risk, may sacrifice the highest growth potential for a hedge against market downturns by investing a certain percentage in tax-free bonds. Are these high net worth individual investment tips riskier than, say, an index fund?
Leave it to our Government to silence us!
It’s time we stand up and demand a huge change! Fire all of the elected officials and start from scratch!
So this would be like for CEO's of Pfizer, Moderna, J&J?
There were nearly 500 of my followers who qualify.
Is this available to Canadians?
Yes, anywhere in the world.
The #1 rule of investing should be asset preservation. I put all my assets into precious metals and numismatic coins around 25 years ago and then strayed from my original plan, big mistake. Giving all you can to the truly needy is the best investment you can make.
I have about 20 eggs in my frig. Not sure if that was worth
Mentioning😎
If you lived in New Zealand or UK you be rich lol.
Are they Golden?
No. Just expensive. Free advice: own hens. I don't; yet. My neighbor started, so I save my cartons for her. Now she delivered me a free box of eggs a couple weeks ago🤗
Now, if she owned a chicken that laid golden eggs, that would be worth even more.
I wonder what that chicken would taste like:)