In what may be an emerging trend, a certain “Terence Bosley” submitted the only comment in response to the SEC’s proposed rule IA-3098.His comment is a response to the SEC’s request for comment on a rule regarding “family offices,” which are just basically rich families with more than $100 million in assets who do things like set up trusts for each other and manage each other’s art collections.*
The SEC proposes to allow managing members of a family office to invest in the fund and charge family members fees for giving them investment advice.
And notably, by the SEC’s proposed rule, even if they aren’t a part of the family, “key employees” of a family office are allowed the same rights as family members.
In defining who it considers “key employees,” the SEC makes mention that it doesn’t allow certain “clerical” employees of the family office to be counted.
The fictional author of the comment, “Terrence Bosley,” assumes the SEC is talking about his butlers and maids, and writes the indignant response below:
October 15, 2010
I am writing to comment on the proposal to allow Key Employees to invest in family offices. First of all, let me say that I am shocked by the impudent tone of your request for comment.
A businessman of my calibre must never be addressed in such a manner. I will have you know, distinguished members of the Commission, that I am a fifth generation graduate of Harvard, and that if any professor had dared to speak to me in such a contemptuous fashion our family would have kicked him into the Yard so quickly your head would spin.
Before proceeding any further, let us make one thing very clear: you are not in charge of us, we are in charge of you.
Turning now to the more substantive matter of allowing Key Employees to invest in family offices, I find the matter completely laughable. Do you mean to suggest that our butler and maid should be allowed to sully our family office with their pitiful wages?
I assure you, by the time sun sets on payday they will have most likely squandered their meagre funds on alcohol and other such vulgar pastimes. Do you really suppose that these mouth-breathing, knuckle-dragging troglodytes have the cranial capacity to make sound investment decisions?
I believe you have erred in mistaking the hired help for genuine Americans.
*The SEC actually provides “managing art collections” as a “family office” activity in its description of the rule linked to above.
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