Author Archives: Seth Berlin

About Seth Berlin

Seth Berlin is Principal at Performance Thinking & Technologies (PTT). PTT is a consulting firm that focuses on operations, reporting, and risk management for hedge funds and investors. Seth has many years in the investment industry from an investment analyst, operational, and technology management perspective. He can be reached at www.p-t-t.com or at info@p-t-t.com.

Summary of SEC Emergency Order on Short-Selling Disclosure

This document is intended to be a summary of the SEC Release No. 58591 on September 18, 2008.  For the full SEC document, please go to the following link:  http://www.sec.gov/rules/other/2008/34-58591.pdf .  For the Edgar Form SH: http://www.sec.gov/about/forms/formsh.pdf Who does this ruling pertain to? An institutional manager that exercises discretion on accounts with at least $100,000,000 in FMV of 13(f) securities […]

When You Swing The Big Stick – Swing It Big (An Update on SEC Short-Selling Disclosure)

Wow!  That’s all I can say over the past day.  The government swung and swung big.  I am least suprised by Short Selling Disclosure and the creation of a “no borrow” list.  In light of the seizure of the credit market and redemptions in Money Markets on Tuesday and Wednesday mornings it is no suprise that someone had to swing for […]

Walk Softly And Carry A Big Stick – Short Position Disclosure By the SEC

Fear and greed are amazing motivators, but fear has an immediacy that greed will never have.  Fear adds the propensity to “do something” and do it quickly.  But this “do something” mentality can have unintended consequences.  In the SEC’s case, daily short reporting for hedge funds and institutions, if not managed correctly, can add market volatility right when it is […]

13F Filings – Quick Notes

If your fund is still registered and filing a 13F HR or 13-F HR/A, here are a couple of quick notes on what is included/excluded: 13F is due 45 days after the end of each quarter Long positions only for 13F securities (a list of 13F securities can be found here – http://www.sec.gov/divisions/investment/13flists.htm ) Long Call/Put positions need to be included […]

The Mythology of the Due Diligence Questionairre

I have spent a great deal of time talking to Fund of Funds, Investment Consultants, and Investors about their methodology for reviewing funds.  Most players have a rigorous methodology for review of quantitative return streams…..and then comes the review of the DDQ (Due Diligence Questionairre). This is a story I see played over and over again.  Analysis, analysis, analysis, and then the DDQ.  For some […]

Does Mimicking behavior lead to market crashes?

In this model by Capital Fund Management (www.cfm.fr), high levels of copying behavior leads to bubbles and then crashes.  This is regardless of positive or negative news stories. Although only a mathematical model, this is interesting to me.  The key here is the definition of low vs high level of copying behavior.  If an inflection points exists for copying behavior, then […]

The Path of Securities Lending – Will It Ever Change – Part I

Securities Lending is the last bastion of manual intervention in an otherwise automated trading world.  The process remains the same as it did years ago.  You pick up the phone, call your borrow contact at a prime broker, and get quoted a rate.  This process repeats itself once for every prime broker.  Then, you arrange a borrow and hope that […]


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