My last post about Bramdean Asset Management observed that Bramdean had sent money to an un-named fund and received it back the same day. This was done for "regulatory purposes".
I presume that there must be a legitimate reason for doing this - but to date I have not found one and nobody has identified one. I still seek assistance.
Several people in comments have suggested nefarious regulatory purposes are possible - with the best example being a lawyer who transferred considerable trust funds to his own account for one hour (and returned them in full) so as to qualify for better credit at a casino.
I presume that the fund in question is better than a Casino - but maybe private equity funds from 2007 are in fact glorified casinos and someone just needed to maintain credit.
Anyway I would love somebody to identify a respectable regulatory purpose as I have not been able to do so.
I did ask this question of Bramdean. And (contrary to what I said in the last post) there has been a reply.
I repeat it here in full for your benefit.
Dear Mr HemptonThank you for your email and for your interest in Bramdean Alternatives Limited.With regards to your query, private equity funds are structured and governed within the terms of their stated mandates.Regards,Loretta MurphyHead of Investor Relations and CommunicationsFor and on behalf of Bramdean Asset Management LLP35 Park LaneLondon W1K 1RBTel: +44 20 7052 9272DDI: +44 20 7590 2001Fax: +44 20 7052 9273E:mail:-lmurphy@bramdean.com
I am not picking on Bramdean here. The unnamed fund probably sent the same request to almost all of their investors and the investors all sent money for a "regulatory purpose" and received it back later. The activity is widespread and almost certainly legitmate.
I just don't know what it is and a fairly direct email to Bramdean did not produce a helpful reply. If they do reply I will let you know again.
John
PS. One of my favourite bloggers - on seeing the Bramdean letter said "regulatory arbitrage is so 2006". Maybe we are just caught in a timewarp.
If I was a regulator kicking the tyres on a private equity fund's accounts, particularly in the current environment (and particularly if I was a little bit crook about some of the investors with commitments), one of the things I might do would be to ask that fund to make a bed & breakfast cash call, just to see if the counterparties existed, has bank accounts, were capable of coming up with that sort of cash at short notice etc.
ReplyDeleteBoosting assets under management for reporting?
ReplyDeleteCould they have a review by their prime on the leverage provided, and needed to drop the ratio temporarily to slide through? Though Bruschetta's idea seems more likely.
ReplyDelete