Dear Chairman Clayton,
We applaud the recent dialogue and your proposal to update the outdated accredited investor rule that determines eligibility for persons to participate in the private capital markets. As the professional body for alternative investments, CAIA Association works with our 12,000 global membership base to represent savers, beneficiaries and the general public, intent on ensuring that financial markets serve the greater good by allocating capital efficiently to the most socially and economically beneficial activities. In that vein, CAIA Association sees a number of benefits to expanded investor access to private markets, but only with appropriate conditions and safeguards.
As you well know, changes in capital formation over the last two decades have resulted in large portions of the economy utilizing private markets for longer periods of time. It is well documented that exchange-listed firms in the U.S. have more than halved since 1996. This trend is magnified in both small cap and service-oriented industries, leaving the remaining publicly traded firms disproportionately consisting of dated and slow-growth business models. Further, the ability to avoid onerous and costly regulation, disruptive activist behavior, and to align themselves more with long-term value creation vs. short-term and emotionally driven price gyrations, is causing many companies to even consider remaining private indefinitely.
These structural shifts coupled with increasing pressure to meet retirement outcomes places undue and unsustainable pressure on public equities. Public equities have outperformed nearly every asset class since the global financial crisis of 2008, and a precipitous, steady decline of interest rates has led to strong fixed-income performance as well. Along with unprecedented global central bank support, these phenomena have rendered anything other than a traditional 60/40 portfolio unnecessary. Advisers and their investors who have entered into a relationship in the last 10 years haven't experienced a significant correction or recession and may undervalue the importance of a diversified portfolio among weak public markets and stagnant growth. A careful study of financial history and investment performance will showcase that the last decade is far from representative; the "easy money" is likely behind us and advisers will need to work harder to meet investor expectations going forward.
We believe the merits of diversification will roar back to life in this return to "normal" environment when stocks and bonds may offer lower, more volatile and even negative returns. The careful addition and use of alternative investments can mitigate downside risk, lower volatility and enhance risk-adjusted returns over the long term. But alternatives should not be viewed as a panacea or desperation move to improve alpha or close underfunded retirement gaps. This reductionist view typically includes arbitrary performance comparisons to public indexes and endless debates about the extinction of the illiquidity premium vs. publicly traded securities.
While we believe that investors can produce superior returns in private capital, it is far from universal given the wide dispersion of manager performance, natural trajectory of market cycles and the recent flaws in the price discovery process brought home by the WeWork debacle. Given we are likely late cycle with record setting levels of dry powder, the narrative supporting the benefits of alternatives must be centered on the uncorrelated cash flows, drawdown mitigation, inflation protection and diversified income streams, not an alpha beauty contest. We contend that all educated long-term investors should be given the opportunity to create a more sophisticated and balanced portfolio that extends across the full risk premiums.
While higher levels of wealth are likely correlated with more disposable income, it certainly doesn't approximate by itself to investment sophistication.
To qualify investors to participate in private markets, we therefore support a dual path toward eligibility as a proxy for sophistication: