Introduction and Overview of 40 Act Liquid Alternative Funds
            
            
              |
            
            
              7
            
            
              Chart 1 below provides an overview of the single-fund
            
            
              mutual fund structure and the key relationships and
            
            
              service providers required.
            
            
              Due to the daily liquidity requirement, the most
            
            
              common alternative strategies being implemented
            
            
              in these single-manager mutual funds are equity
            
            
              long/short, equity market neutral and global macro.
            
            
              These strategies trade in highly liquid securities
            
            
              such as equities and listed derivatives. In order to
            
            
              meet the liquidity and leverage requirements of the
            
            
              ’40 Act open-end funds, some hedge fund managers
            
            
              exploring these structures are refining the execution
            
            
              of their investment strategies to comply with the
            
            
              mutual fund trading limitations.
            
            
              The most common way of achieving this aim is to
            
            
              carve out the most liquid subset of trading signals
            
            
              used in the manager’s private fund offering and
            
            
              create a mutual fund wrapper around this set of trade
            
            
              ideas. As a result, these simplified trading strategies
            
            
              offer a different risk-return profile when compared
            
            
              with the hedge fund manager’s private fund product.
            
            
              Articulating the difference in trading style between
            
            
              publically offered and privately offered funds helps
            
            
              the manager justify the divergent fee schedules and
            
            
              limit the potential of investors wanting to leave a
            
            
              higher fee product in favor of a lower fee offering.
            
            
              The management fee for the mutual fund can be
            
            
              shared between the IM and the IA depending on their
            
            
              arrangement and functions.
            
            
              A good example of the single-manager alternative
            
            
              mutual funds is the PIMCO Long/Short Equity
            
            
              Fund (PMHAX), which was formed by PIMCO after
            
            
              acquiring hedge fund manager Catamount Capital
            
            
              Management in Q2 2012. They were able to convert
            
            
              Catamount’s private fund into a mutual fund because
            
            
              it was determined that the historical performance
            
            
              was generated by the fund, which used strategies
            
            
              and leverage that was compliant with the ’40 Act
            
            
              regulations. PIMCO now acts as both the IM and the
            
            
              IA to the fund. If a private fund can be converted into
            
            
              a mutual fund, it can maintain the track record of the
            
            
              hedge fund. If that track record is 3 years or longer,
            
            
              the IM can potentially have its fund more readily
            
            
              recognized on the mutual fund ratings sites such as
            
            
              Morningstar and Lipper, which can increase attention
            
            
              and interest in the product.
            
            
              In the sub-adviser version of the single manager
            
            
              product, the IM is either affiliated or distinct from the
            
            
              IA and provides operations and oversight functions
            
            
              for the fund. The IM in this model is often also the
            
            
              primary distributor for the fund, offering either their
            
            
              own distribution network and/or ensuring that the
            
            
              fund is available via broker-dealers, wire-houses,
            
            
              mutual fund supermarkets and platforms as well as
            
            
              Chart 1: Basic Open-End Mutual Fund Structure
            
            
              
                Chart 1
              
            
            
              Basic Open-End Mutual Fund Structure
            
            
              Mutual Fund -
            
            
              Registered Investment Company
            
            
              Security Listed on Public Exchanges
            
            
              Key Service
            
            
              Providers
            
            
              Independent Board
            
            
              of Directors
            
            
              Investment Manager
            
            
              & Adviser
            
            
              Single Pool of Assets
            
            
              Investment Adviser
            
            
              Distribution Agents
            
            
              Key Service
            
            
              Providers
            
            
              MF
            
            
              Administrator
            
            
              Sponsor
            
            
              Executing
            
            
              Brokers
            
            
              Prime
            
            
              Brokers
            
            
              Custodian
            
            
              Investor
            
            
              Services
            
            
              Trading & Financing Counterparties