Legal Framework for Hedge Fund Regulation

There is no statutory definition of the termadvisor that it will not be liable under ERISA for
"Hedge Fund." The industry accepted definition isany misconduct on the part of the hedge fund
that they are privately offered investmentadviser in managing plan assets.
vehicles in which the contributions of the high netThe Commodity Futures Trading Commission
worth participants are pooled and invested in a(CFTC) provides hedge fund advisors exemptions
portfolio of securities, commodity futuresfrom Commodity Pool Operator (CPO) and
contracts, or other assets. Investors are typicallyCommodity Trading Advisors (CTA) registration.
able to redeem their investments on a quarterly,Though they are required to keep the books of
semi-annual or annual basis. A high net worthrecord, but can avoid disclosure, periodic reporting
participant (or a qualified purchaser) as defined byor audit requirements that apply to a registered
Securities Exchange Commission (SEC) is anCPO/CTA. Regulations under the Commodity
individual with an asset base of $ 1 million dollarsExchange Act (CEA) provide an exemption from
and an institution or a fund or a trust with anregistration to CPOs operating pools that engage
asset base of $ 5 million. Apart from thisin limited commodity futures activities and sell
statutory limit, investment in hedge funds isinterests solely to certain qualified individuals and
largely the preserve of sophisticated investorsthat sell interests to highly sophisticated pool
who possess the required knowledge to assessparticipants. Investment advisors to Hedge funds
the risks associated with investing in this assetthat operate in reliance upon Section 3(c)(7) of
class.the Investment Act may be able to rely upon
Though the original purpose of hedge funds wasone of these CFTC exemptions. Like the Advisors
to invest in equity securities and use leverage andAct's de minimis exemption CEA also provides a
short selling to "hedge" the portfolio's exposure tosimilar de minimis exemption from CTA
movements of the equity market, this remit hasregistration.
altered. Today, hedge fund advisers useSections 352 of the USA Patriot Act require
labyrinthine investment strategies and techniquesevery "financial institution" to establish an
to increase investor returns and many are veryanti-money laundering program that meets certain
active in the trading of securities, representingminimum requirements, especially related to anti
between nearly 20% of equity trading volume inmoney laundering procedures. In addition to
the US securities market.adopting an anti money laundering program, these
Regulating the Hedge Fundsentities would be required to provide a written
The most clamorous reasons cited by thenotice to the Treasury within 90 days of
votaries of regulating the Hedge Fund industry isbecoming subject to the rule.
the incredible growth of hedge funds and theRegulations in India:
increased influence and power that hedge fundsWith the notification of SEBI (Mutual Fund)
are having on the financial markets. The industryRegulation 1993, the asset management business
is attacked for being secretive, engaged in riskyunder private sector took its root in India. In the
behavior and capable of unduly influencing globalsame year SEBI also notified Regulations and rules
economies and corporate activities. An increase ingoverning portfolio managers who pursuant to a
fraud cases involving hedge fund advisers,contract or arrangement with clients, advice
juxtaposing with an increase in exposure ofclients or undertake the management of portfolio
unsophisticated small investors to the risks ofof securities or funds of the client. There are no
hedge fund investing has enticed the policymakershedge funds domiciled in India and they are not
and regulators to bring the hedge fund industryallowed to raise funds from the domestic market.
under greater scrutiny. Hedge Funds were largelyFurther, on account of limited convertibility,
held responsible for the South East Asianoffshore hedge funds have yet to offer their
Economic crises in the late 1990s, the failure ofproducts to Indian investors within India. The RBI
the Long Term Capital Management Fund in thethrough liberalized remittance scheme has allowed
US in 1990s and its subsequent $ 3.5 billion bailoutresident individuals to remit up to US $ 25,000 per
by the Federal Reserve Bank to prevent theyear for any account or for capital account
cascading collapse of global financial markets; andtransaction. This liberalized scheme will allow
the current surge of the Bombay Stockindividual investors to explore the possibility of
Exchange SENSEX, which even surprised theinvesting in offshore financial products.
Indian Finance Minister as to comprehend theThe current fiscal year has seen a spectacular
reasons for such a surge, creates an argumentgrowth in FII investment activities and they
that some form of regulation should beaccount for nearly 30% of FII inflows into the
encouraged for hedge Funds.Indian market. Robust economic fundamentals,
There have been studies into the possibility ofstrong corporate earnings and improvement in
direct regulation undertaken over the past numbermarket micro structure are driving the FII interest
of years by such bodies as the Basel committeein India. With such fundamentals, hedge funds
on banking supervision, the Internationalhave evinced keen interests and would like to
Organization of Securities Commissioners anddirectly invest in Indian markets as a registered
probably most significantly, the US president'sentity under the SEBI (Foreign Institutional
working group on financial markets. However, noInvestors) Regulations, 1995 (FII Regulations).
major regulatory body has advocated directHedge funds typically invested in the offshore
hedge fund regulation.derivatives instruments (Participatory Notes (PNs))
Self Regulations:issued by FII against the underlying Indian
Even though there is no statutory obligation tosecurities. Through this route the hedge funds
make a public disclosure, hedge funds providecould derive economic benefits of investing in
their potential investor with a private placementIndian securities without directly entering the
memorandum that discloses information about theIndian market as FIIs or their sub-accounts. As of
overview and investment strategies of the hedgeOctober '07 there were more than 1,100
fund. The memorandum also provides the adviserregistered foreign investors and 3,447 registered
with the maximum flexibility in selecting, shiftingsub-accounts.
and modifying its strategies and arms him withThrough recent amendments to the FII
broad discretion in valuing hedge fund's assets.Regulations (Regulation 15A and 20 A), the
Hedge Fund investors generally receive someRegulatory regime has been further strengthened
ongoing performance information, risk analysis andand periodic disclosures regime has been
portfolio profiles from their hedge fund advisors.introduced. The provision 15 (3)(a) of the FII
Most hedge funds retain an auditor to conduct anRegulations relates to the prohibition on short
independent audit which if certified is preparedselling of securities by FIIs. It allows that FIIs may
using generally accepted accounting principlestransact business only on the basis of taking and
(GAAP). Market competition has also led to agiving deliveries of securities bought and sold, and
growing demand by the investors forcannot engage in short-selling securities. Further
business-unit level SAS 70 assessmentregulation 6(1)(b) of FII Regulations, provides that
(Statement on Auditing Standards No.70 Servicethe hedge fund have to be registered with the
Organizations,) by reputed firms.statutory regulatory authority in their place of
The hedge fund industry's main trade group in theincorporation. Most Hedge funds would fail to
US, Managed Funds Association, has laid downmeet this criterion because they are not
certain professional the guidelines in a publicationregistered with any regulatory authority, nor are
called "Sound Practices for Hedge Fund Managers".the managers registered with regulatory
It contains guidance about anti-money launderingauthorities.
policies, determining net asset value, riskIn October '07 SEBI has mandated that in the
monitoring and also a model "due diligence"spot market, FII will not be allowed to issue
questionnaire to enable the investors to questionP-notes that were more than 40 per cent of their
hedge fund managers.assets under custody and those FII over the
Also though the much talked about performancethreshold will have to freeze their holdings. FIIs
fee figure is generally 20%, yet the commonthat have issued P-notes below the limit may
practice is that there is a "high water mark" thatincrease issuances at an incremental rate of 5 per
is often applied to its calculation. This means thatcent of their assets under custody, he said. Also
the manager does not receive performance feesthe reference date for calculating such assets will
unless the value of the fund exceeds the highestbe September 30, which is the latest date for
net asset value it has previously achieved. Thiswhich data is available.
measure is intended to link the manager'sThe FII Regulations allow sub accounts sponsored
interests more closely to those of investors andby registered FIIs to invest in India. Regulations 2
to reduce the incentive for managers to seek(k) defines "sub-account" which "includes foreign
volatile trades. It is pertinent to keep in mind thatcorporate or foreign individuals and those
these are more of market competitive regulationsinstitutions, established or incorporated outside
than statutory regulations.India and those funds or portfolios, established
Statutory Regulations in the US:outside India, whether incorporated or not on
Most Hedge funds have substantial investments inwhose behalf investments are proposed to be
securities that would cause them to fall within themade in India by a foreign institutional investor".
definition of Investment Company under theFurther provisions of regulation 13 lay down the
Investment Company Act 1940 (Investmentconditions and the procedure for granting
Act). However, Hedge Funds generally rely on oneregistration to a sub-account of an FII. But the
of two statutory exclusions from the definition ofOctober '07 SEBI mandated new guidelines, under
"Investment Company" which enables them towhich FII currently registered in India will not be
avoid the regulatory provisions of the Investmentallowed to issue new derivatives from
Act.sub-accounts based in tax havens such as
Section 3(c)(1) of the Investment Act, excludesMauritius.
from the definition of investment company anyHowever in practice if an applicant indicates in the
issuer whose outstanding securities(other thanapplication that it is a Hedge Fund, the
short term paper) are beneficially owned by notconsideration of the application is generally
more than 100 investors and which is not makingwithheld. Since granting of registration to FII
and does not presently propose to make a publicsub-accounts is based on the disclosure of the
offering of its securities.details and on the undertaking given by the
Section 3(c)(7) of the Investment Act excludesapplicant in the application form; it could be
from the definition of the investment companypossible that the few entities who described their
any issuer whose outstanding securities areactivities in the application form in terms other
owned exclusively by persons who at the time ofthan Hedge Funds could have already got
acquisition of such securities are "qualifiedregistration as sub-accounts. However it is
purchasers" (high net worth individual) and which ismandatory that the sub accounts have to be
not making and does not at the time propose tosponsored by registered FIIs who are required to
make public offering of its securities. Though abe regulated entities by relevant regulators in their
hedge fund relying on this provision may accepthome countries.
an unlimited number of qualified purchasers forChapter II of the SEBI (Foreign Institutional
investment in the fund, but in practice, however,Investors) Regulations, 1995 interalia lists out the
most funds refrain from signing up more thaninstruments in which an FII/sub-account can
499 investors in order to avoid the registrationinvest. The regulation does not include currency or
and reporting requirements of the Securitiescommodities as eligible instruments for investment
Exchange Act,1934 (Exchange Act).for the FII. Therefore, currency trading or
The Exchange Act contains the registration andinvestment in commodity related financial products
reporting provisions that may apply to Hedgewill not be an option for any hedge fund under
funds. Section 12 of the Exchange Act and thethe present FII Regulations.
rules promulgated there under govern theThe FII Regulations also lays down scrip-wise and
registration of classes of equity securities tradedfund wise maximum limits a fund can invest.
on an exchange or meeting the holder of recordFurther, through circular dated February 12, 2002
and assets tests of section 12 (g) and relatedand March 9, 2004 issued in the Secondary
rules. Section 12(g) and rules 12 (g)(1) there underMarket Department, position limits for investment
require that an issuer having 500 holders ofby FII in derivatives have been advised. These
record of a class of equity security (other than anlimits will help diversify the foreign hedge fund
exempted security) and assets in excess of $10investments and further help in jettisoning
million at the end of its most recently ended fiscalconcentration in any specific scrip. The
year register the equity under the Exchange Act.government wants to keep the hedge funds out
Registration of a class of equity security subjectsof short selling at least in the cash segment and
domestic restraints to the periodic reportingthus provisions of chapter III (Regulation 15 (3)
requirements of section 13, proxy requirements(a)) disallows short selling by FII and stipulates that
of section 14 and insider reporting and short swingall trades by FII be delivery based.
profit provisions of section 16 of the exchangeThe Money Laundering Act, 2003, is an
Act. To avoid registration most hedge funds haveendorsement of various international conventions
not more than 499 investors affiliated to ato which India is signatory. It adequately
particular fund.empowers the state authorities to declare
The Beneficial ownership reporting rules underlaundering of monies a criminal offence. Working
sections 13(d) and 13(g) of the Exchange Actout modalities of disclosure by financial institutions
generally require that any person who beneficiallyregarding reportable transactions, confiscation of
owns greater than 5% of the class of equitythe proceeds of crime, declaring money laundering
securities, file a beneficial ownership statementsas an extraditable offence and promoting
(schedule 13D or 13G). Hedge fund advisors alsointernational cooperation in investigation of money
may be subject to the quarterly reportinglaundering is the main aim of the act. It also
obligations of section 13(f) of the Exchange Act,provides for reciprocal arrangement for assistance
which apply to any "institutional investmentin certain matters and procedure for attachment
manager" exercising investment discretion withand confiscation of property to facilitate transfer
respect to accounts having an aggregate fairof funds involved in money laundering kept
market value of at least $100 million in equityoutside the country and extradition of the
securities. An institutional investment manageraccused person from abroad.
includes any person(other than natural person)CONCLUSION:
investing in or buying and selling securities for itsHedge Funds as a whole are becoming a
own account, and any person exercisingprominent segment of the asset management
investment discretion with respect to the accountindustry and gaining popularity from investors
of any other person.particularly from high net worth investors,
Section 16 applies to every person who is theuniversities, charitable funds, endowments, pension
beneficial owner of more than 10% of any classfunds, insurance and other institutional investors.
of equity security registered under section 12 ofMost hedge fund managers are embracing the
the Exchange Act and each officer and directornew sources of capital from institutional investors,
of the issuer of the security (collectively,who are, by their very nature, highly regulated
"reporting persons"). Upon becoming a reportingand their investments scrutinized. They encourage
person, a person is required by section 16(a) tothe hedge funds to improve their internal controls
file an initial report with the SEC disclosing theto meet the Alpha requirements.
amount of his or her beneficial ownership of allThe assets under management of the hedge
equity securities of the issuer and also anyfunds are growing on a double digit rate and it is
subsequent changes thereafter. Hedge funds areestimated that worldwide the Hedge Fund
also subject to the short swing profit provisionsindustry is nearly $3 trillion dollars. This has created
of section 16 (b) of the exchange act.a lot of disquietude for financial regulators as
The Investment Advisors Act, 1940s (AdvisorsHedge funds are able to influence markets in a
Act) regulates the actions of investment advisers.more radical manner than they would do so when
Many hedge fund advisors, however, avoidthey first started.
registering with the SEC by relying on theIn India the issues are intended to widen the FII
Advisors Act de minimisexemption under sectioninflow and to allow these alternatives investment
203(b) by having fewer than 15 clients during thepools to our securities market in a transparent
preceding 12 months, For the purposes of sectionand orderly manner. In addition, the suggestions
203(b), current SEC rules provide that investmentalso provide for adequate safety measures to
advisors may count a "legal organization" such asaddress legitimate concerns associated with these
a hedge fund as a single client.funds.
Investment advisors that are exempt fromMost industry people are of the view that
registration nevertheless are subject to theregulation is welcome and good but only if it does
antifraud provisions of the Advisors Act. But it isnot impinge on innovation, competitiveness and
pertinent to know that many hedge fundthe industry's ability to evolve. It's all about
managers due to market competition do registereducating the investors and ensuring they know
with the commission voluntarily because thewhat they are getting into.
investors demand it. The SEC's attempt inHedge Funds bring liquidity to capital markets, and
December 2004 to require hedge fund managersalso make capital markets more efficient because
to register under the Advisers Act failed when itthey scour the financial landscape for inefficiencies,
was challenged in court and the SEC was askedand then use expertise to structure the optimal
to review the requirement (Philip Goldstein v SECinvestment to take advantage of the opportunity.
(2006)).They have been instrumental in transforming the
The Employee Retirement Income Security Actinvestment landscape, making it much broader
(ERISA) plans are very alluring from the point ofthan equities, bonds and property. Hedge funds
investment and some hedge fund advisors accepthave acted as a beachhead in new investment
regulations under the ERISA in order to have anstrategies, including middle market lending,
access to ERISA pension funds. An investmentasset-backed lending, credit derivatives,
advisor to a hedge fund is an Employeereinsurance, and carbon credits.The greater
Retirement Income Security Act (ERISA) planchallenge for the regulators is as to how to
fiduciary if it exercises discretionary authorityincrease compliance and protect investors without
over the management of "plan assets". Themaking hedge fund managers relocate to
assets of a hedge fund are deemed to be "planunregulated jurisdictions.
assets" if an ERISA plan's investment is deemedThe governments, central banks and the
to be significant (25%), a benchmark that manyregulating agencies have to make a choice
hedge funds want to keep under. Generally, hedgebetween the efficaciousness of a regulation and
fund adviser can shield ERISA plan fiduciaries fromthe price involved in complying with it. As for the
liability for its misconduct by registering as anHedge funds, an investment sector wary of
investment adviser under the Advisers Act, andwatchdogs after years of being unregulated,
by qualifying as an "investment manager" underregulators will need to persuade fund managers
ERISA. Before investing plan assets in hedge fund,that the free flow of information and open
however, the non-advisor ERISA plan fiduciarydialogue are essential, and that intervention will
typically will require assurances from hedge fundonly come where market stability is at stake.