We are currently in SEC review 'stage 1' awaiting first comments back on the prospectus and SAI (Statement of Additional Information). The SEC waits about 6-8 weeks to respond to your initial request (I'll save any jokes about why things take so long at a governmental agency). This should take things to end of January/first week of February. We then respond to their comments/questions after a review with counsel, and can get that done in about 5 days (requires specific type of filings). Then one moves to final review and approval by SEC, which will hopefully be "a matter of weeks" after our response to their first round of comments. Hence my working target will be late February, early March 2011 for the SEC to put the final stamp of approval on. That is not a firm date, or a promise - could be sooner, could be later. It is out of my hands of course, but this is what 'should' happen but this portion of the launch is mostly reliant on other organizations and not myself.
As noted in previous posts, once approved the fund can be launched to direct investors and we can apply to brokerage accounts to petition for approvals on various platforms. The application process is generally 4-6 weeks, but a handful are 2-3 weeks. From my survey a few weeks ago, in my limited sample of investors, about half are coming with direct accounts and half via brokerages. Therefore I am planning to launch the fund to the public roughly 3 weeks after SEC approval to close the time gap between when direct investors can begin to invest and when those coming in via brokerages can invest. The key reason for that of course is the first few weeks will be seeing heavy fund inflows and I can't really begin with a coherent strategy if on day 8 I have $3M and on day 22 I have $7M to work with. (that is 100%+ growth in 2 weeks) My goal is to have the bulk of the fund's initial capital from the reader base in house within 4 weeks of launch, so I can begin to implement strategy.
So the process will work like this:
- Fund Approved by SEC
- Immediately apply to brokerages to get approved on their platforms
- Officially launch fund 3 weeks after SEC approval to investors creating direct accounts
- The brokers which grant approval, should have the fund available for investors to purchase on their platform 4-6 weeks after initial application is put in.
On a related front, the person who is volunteering (many hours) to help me with new fund website, and I, decided to do an overhaul of the design the past week to hopefully give it a more professional air. Still a work in progress in terms of text alignment, content, and some design issues but here is a first pass of the home page. Even when the design is done, I am not allowed to release it until another regulator (not SEC) reviews it, and it is just not a high priority item yet so I'm standing in line on that issue as well. I was hoping it would be up in December but we're stymied on this one.
I'll move this entire post to the front page of FMMF during the holiday weekend for those who missed it.
[click to enlarge]