Subject: File No. DF Title IV - New Threshold
From: Raiford Garrabrant, CFA

July 29, 2010

Transparency, transparency, transparency - that is a cornerstone of the disclosure required of public companies.
And when it comes to transparency among money managers, shouldn't hedge funds be held to the same standard as their long-only peers? Please require all hedge funds to disclose their short-positions, not just their long positions.

The current rules result in an incomplete picture and allow hedge funds to portray themselves as big believers in a company when in fact, they may be short many more shares than they own.

Lift the veil