Aggregate Asset Management is a fund management company that holds a Capital Markets Services (CMS) Licence for fund management activities under the Securities and Futures Act, Singapore; and is regulated by the Monetary Authority of Singapore (MAS)
Aggregate Asset Management is one of the earliest and rare fund management companies that aligns clients’ interests with our own – we do not charge management fees; clients only pay performance fees when they enjoy absolute returns.
We are value investors – we invest in undervalued listed securities in Asia by practicing an independent, bottom-up approach to security selection.
Our objective is to achieve net of fee returns of 10% per annum on a long term horizon for our clients. By long term, we mean 5 years or more. Our clients are high net worth individuals, companies, family foundations and institutions. Under Monetary Authority of Singapore regulations, we can only serve Accredited Investors. An Accredited Investor is defined according to the Securities and Futures Act, as an individual with net assets of at least S$2 million (maximum of S$1 million net in primary residence), or an annual income no less than S$300,000, or net financial assets of at least S$1 million.
0%Typically most funds charge a management fee as a fixed percentage of assets under management (AUM). This incentivizes funds to chase growth of AUM instead of performance for their clients. Aggregate revolutionises this by being the first fund management company in Singapore that offers a zero-management fee model in it’s one and only flagship fund - The Aggregate Value Fund. It aligns the interest of clients with the company. At AAM, clients only pay a fee when their investments are profitable. (In investor parlance, only a performance fee is levied when the fund hits a new high water mark). This is unheralded in the fund management industry in Singapore. AAM’s asset under management has grown quite significantly to S$450M from its inception 4+ years ago. Evidently, investors appreciate the AAM’s philosophy of giving investors a fair bargain.
AAM holds more than 600 stocks in its portfolio. AAM recognizes that investing in stocks is a risky endeavor – and a unique and effective method that AAM pioneered to reduce risks substantially is by extensive diversification. Traditionally, most fund management companies hold stock positions of between 20-50. Holding too few stocks can result in highly volatile results and a mistake made in stock selection can be punishing to performance for the entire fund. AAM’s breakthrough method of extensive diversification of hundreds of stocks across Asia results in a fund with low volatility and reduces the chances of permanent loss substantially. With extensive diversification, clients and fund managers can sleep better at night.
10%AAM’s objective is to deliver net returns of 10% p.a. over the long term. So far, since inception 4+ years ago, AAM has returned an average of net 11+ % a year, exceeding its targeted return. This was achieved despite a difficult period of the last few years against a backdrop of the Euro crisis, Brexit, commodity bust, correction in oil price. Since inception, $1.0M dollars invested in AAM in Jan 2013 has resulted in net returns after all fees and expenses of $1.6+M in 2017. AAM is confident of its stated objective of delivering net returns of 10% p.a. in the next 5 years. At a 10% rate of return per year, $1M invested will grow to $2M in 7 years and $3M in 11 years.
AAM was set up with a focus to help individual investors meet their retirement goal. The minimum investment amount to get started is S$150,000 – a relatively friendly entry level because we want more people to have a chance to experience the wonders of value investing and the powerful effects of compounding. We are a firm set up by individuals for individuals because we see so many people struggle with meeting their retirement needs. AAM pioneered the concept of a 5% withdrawal rate. What this means is that every investor has the flexibility to withdraw 5% of their total investment funds every year. For example, a client with $1M dollars in investment, can withdraw $50,000 every year to fund his retirement cash flow needs. The value investing approach used by AAM will ensure that the retiree will not run out of money despite the annual withdrawals made AND potential market corrections/volatile market swings. The value of this concept is that at the end of the day, he will still be able to leave a sizeable amount for his beneficiaries. The 5% withdrawal rate is made possible because the long-term rate of return far exceeds the 5% withdrawn. Many of our clients use the fund as a long-term savings plan by making regular contributions to the fund.
The founders of AAM dedicate themselves to a single focus on clients by delivering stellar investment results that would enable them to meet their goals of retirement, wealth preservation or leaving a legacy for future generations. Unlike most other funds out there, the founders are personally invested in the fund. They contributed capital at startup, and have re-invested their returns into the fund. Their financial well-being is tied to the growth of the fund, aligning their interests with clients. They worry when clients worry and rejoice along with clients when the fund does well. In other words, the founders are eating from the same pot that they are cooking for their clients.
Professor Kishore Mahbubani, a Professor in the Practice of Public Policy at the National University of Singapore, served as the Founding Dean of the Lee Kuan Yew School of Public Policy from 2004 to 2017. He currently also serves on the Boards and Councils of institutions around the world, including the Yale President's Council on International Activities (PCIA) and the Social Science Research Council of Singapore. Prior to NUS, he enjoyed a long, illustrious career with the Singapore Foreign Service from 1971 to 2004. He had postings in Cambodia (where he served during the war in 1973-74), Malaysia, Washington DC and New York, where he served two stints as Singapore’s Ambassador to the UN and as President of the UN Security Council in January 2001 and May 2002. He was Permanent Secretary at the Foreign Ministry from 1993 to 1998.
He has authored seven books: Can Asians Think?, Beyond the Age of Innocence, The New Asian Hemisphere, The Great Convergence (selected by the Financial Times as one of the best books of 2013), Can Singapore Survive?, and The ASEAN Miracle (co-authored with Jeffery Sng). His latest book, Has the West Lost it?, was published in April 2018.
Wong has more than 15 years of experience in auditing, accounting, taxation and investment research and management. He was a tax associate and auditor with KPMG Malaysia and Ernst and Young Singapore. His experience includes auditing listed companies on the stock exchange of Singapore and complex business transactions such as IPOs, RTOs and M&A. His last position before co-founding Aggregate Asset Management in 2012 was with a local boutique investment management firm where he co-managed investments for high net worth individuals and a sovereign investment fund.
Kevin is responsible for marketing, client acquisition and client relations. He has extensive experience in financial planning and marketing of financial products, after having spend 20 years with AIA as a District Director prior to co-founding Aggregate Asset Management. Kevin understands the concerns of individuals in the area of estate planning and wealth transfer.
Kevin is a Chartered Financial Consultant (ChFC) and Certified Financial Planner (CFP). He graduated from Nanyang Technology University with a degree in Business specializing in Insurance. His early school years were at The Chinese High School and Raffles Junior College.
Eric has more than 15 years experience in fund management. His previous work experience includes the Ministry of Defence, Motorola, Citibank and United Overseas Bank before he founded Aggregate Asset Management. He earned his BSc in Computer Science from the National University of Singapore and completed his CFA Charter in 2002.
Jean is a Bachelor of Arts graduate from NUS. Prior to joining Aggregate Asset Management, she was in the financial services industry for more than 15 years. She is a Chartered Financial Consultant (ChFC) and is adept at insurance and financial planning, and had represented major insurance companies such as AIA and Manulife.
Jenny brings a great deal of versatility through her 15 years of working experience, She was previously with Motorola, Boeing & Munich Reinsurance.
Ji Ming is a Bachelor of Science (Hons) graduate from NUS. He has passed CFA Level 3. Prior to joining Aggregate Asset Management, he was an investment analyst with a family office researching global stocks primarily in the consumer and healthcare sectors. And in another life prior to that, he was a pharmaceutical executive having spent time in the healthcare industry with companies like GSK, AstraZeneca. He had responsibilities in sales, product management and business development..
Liana has more than 14 years of working experience in accounting, finance and auditing across many industries. Among the industries that she had worked in include banking, nickel mining and rubber planting. She started her career as a Junior Auditor at the accounting firm, Amir Abadi Jusuf & Aryanto, which is a member firm of RSM International. Subsequently, she worked as a Senior Auditor at Prasetio, Sarwoko & Sandjaja - a member firm of Ernst & Young (E&Y). Her current responsibilities in Aggregate Asset Management include managing accounts, financial reporting and compliance.
Maggie has more than 10 years of experience in accounting and administrative works across different industries. At Aggregate Asset Management she is responsible for preparing company accounts and financial reports as well as general administrative duties.
Serena worked at a fund management company for six years before joining Aggregate Asset Management. She brings her experiences in various administrative roles from various industries like electronics, oil & gas, hospitality and banking.
Graduated from University of London in Accounting and Finance. In university, he has learned several modules such as valuations and securities analysis and is keen to put his theory knowledge to practical use. Belfort is also a person with tons of interests. These include coding, investing, physics, life sciences and badminton. In AAM, he is responsible for updating portfolio valuation, company result updates and stock recommendation.
Wee Kiang is responsible for idea generation and quantitative screening in Aggregate Asset Management. Before joining Aggregate Asset Management, Wee Kiang has experience in Risk, Performance, and data management in a local asset management firm for 5 years. He enjoys learning online and is an avid reader of financial journals, blogs, and investment-related books.
Woon Huei is responsible for quantitative research at AAM. Prior to joining AAM, Woon Huei has more than 5 years of experience in quantitative research, data analytics and software development. Woon Huei is currently a PhD candidate in Computer Science in NTU. He earned his Bachelor of Eng (First Class Honours) in 2009 with two-year dean’s listed student certificates.
During his younger days, he achieved two awards in national mathematics Olympiad (Senior High School Level) and national physics competition (Pre-University Level) in Malaysia.
To download the month to month NAV and index data pls click here
All our investment ideas are generated in-house from our stock screens and public news flow. We do not follow what the big boys are doing, or try to predict where the investment herd is going next. We are not closet bench-markers – investing in blue chips and popular stocks like everyone else. Our ideas are mostly unheard of, and contrarian.
Our philosophy is value. The search for bargain value stocks is an ongoing process. What attract us are companies that have fallen off the radar of investors, or those that have suffered a temporary decline in their fortunes.
We believe that to succeed in investing, we cannot be investing like everyone else – we have to be contrarian, and seek the unpopular, fallen or neglected stock – which often comes undervalued.
Our material for analysis is a company’s current and past financial statements, company announcements and any available public information. We look at these closely, and come up with a preliminary valuation which gives us an indication of the attractiveness of a stock or its “margin of safety”. The “margin of safety” is the difference between a stock’s market price and its true or intrinsic value. If we buy a portfolio of stocks at prices which are below its true value, – we believe our portfolio is a safe portfolio, and protects us from permanent impairment. A bear market may wreak havoc on a portfolio’s mark-to-market valuations temporarily, but a true investor can ignore that, and have the conviction that a carefully chosen and constructed portfolio will not suffer permanent impairment. He would be vindicated in the next up cycle, where valuations would be restored, perhaps to higher levels. This is a test that differentiates a speculator and an investor. An investor would welcome bear markets as an opportunity to accumulate even more stocks at attractive prices.
We are proponents that a bird in hand is worth two in the bush. We like to buy stocks with strong balance sheets, and relish the opportunity if we can buy them at steep discounts to net assets. In Asia, there are plenty of such opportunities during bear markets, and some at mid-market valuations. Benjamin Graham’s classic net-net working capital case, where companies can be acquired at less than their net current asset values, are seldom found in developed markets, except in the most dire situations, but such gems can still be found in Asia. We enjoy hunting for them – and to poke and examine them – to unravel whether they are truly good investments, or value traps. Yes, the more sophisticated value investor may scoff at these cigar butts ie. dirt-cheap value stocks, but we have found them to be a worthy and rewarding addition to our portfolio.
The earnings-based approach to valuation is more an art than science, as it requires forecasting earnings into the future. A wise man once said, “The forecast tells us more about the forecaster, than the future”. Here we tread with caution and trepidation – we resist all attempts to justify a rosy scenario and run the danger of overpaying for growth. A deep understanding of the business model and its operating environment and determining the quality of management is paramount when one is trying to see the future – and meetings with the management is mandatory.
We use both approaches – but are mindful of the price we pay for assets or future earnings.
If there is sufficient margin of safety. and the risk/reward ratio is in our favour, we will acquire the stock for our portfolio. At initial entry, we never allocate more than 1% of our funds into a new idea. We would increase our allocations as our understanding increases, up to a limit of 5% of our portfolio. But so far, we have found the allocation of approximately 1% to each stock is optimal.
Why not allocate more than 20% or more to a single idea? No, – we don’t do that – that is called gambling.
Our holding period for our stocks is five years or more (or in investment parlance – a turnover ratio of 20%) – as value stocks typically take some time to pick themselves out of a rut, dust off the cobwebs of neglect, get up and start cracking, before finally earning their place in the sunshine. Graham’s quote on the first page of Security Analysis says it best: “Many shall be restored that now are fallen, and many shall fall that are now in honour”.
We will dispose of a stock when its price is fair, or when more attractive investments present themselves.
There are no limits on cash holdings. If the market is overvalued, and we find nothing worthwhile to buy, we either hold cash, or return money back to our clients.
Our objective is to achieve net of fee returns of 10% p.a. for our clients who are invested with us for five years and more.
A return of 10% p.a. would mean a doubling of the investment amount in 7 years and a quadrupling in 14 years. For example, an initial investment of $250,000 would be worth $500,000 in 7 years, and $1,000,000 in 14 years at a 10% compounded rate of return. (And of course, the targeted returns do not come in like clockwork – there will be crashes, panics, euphoria, bears and bulls in the stock market – it is part and parcel of a double digit return).
Investing in the stock market is risky, and we expect our clients to stay with us over the long term and possess the fortitude to ignore market fluctuations. It is even better to load up on stocks when the stock market is at its most bearish, despite one being in the depths of despair!
What do you invest in?
We invest in listed equities (stocks) in Asia. If we are not fully invested – we hold cash.
Isn’t investing in stocks risky?
Yes it is.
To succeed in stocks, one must invest with a time horizon of at least 5 years. We do not think it is possible to do well in investing by trading and timing the market. This only makes your broker rich. Only invest money you can put away for 5 years.
Is this a good time to invest?
It is always a good time to invest, provided that the markets are not sky-high. The markets are not sky-high today – so it is a good time. Asia is trading well below its historical Price to Book range at 1.5X. When it is not a good time to invest – we will stop subscription to the fund.
What about the China Slowdown, easing of QE, Euro crisis, Japanese exports, Trump, Brexit, Kling-ons, oil price, deflation etc…?
We are not experts in such matters and cannot forecast what will happen. A wise man once said, “Forecasts may tell you a great deal about the forecaster; they tell you nothing about the future”. We agree. We concentrate on buying good businesses at a discount. When there is nothing of value to buy, we stop, or we sell.
How do you manage risk?
We diversify. We don’t put all our eggs in one basket. We study our stocks carefully and value them using fundamental analysis. Our usual allocation per stock is approximately 1% of total portfolio.
Where do you get your stock ideas?
We get them from our stock screeners which we build ourselves. Our stock screeners use a scoring model to help us shortlist ideas.
What kind of reports do I get?
You will get a monthly report from Crowe Horwath the fund administrator. The monthly report will show you the total amount of your investment in terms of the number of units and the NAV per share. The fund managers will provide a quarterly update. They might give their views on the economy and where it is heading (usually wrong) – and tell you a bit on the stocks that they have purchased (usually right).
Is there a risk where you can run away with my money?
Not at all.
Your money and your stocks will be in a pool of funds under the care of DBS Custody. We do not handle your money or your stocks – we just issue instructions to buy/sell. The fund auditor is Ernst and Young – it audits the fund to make sure that everything is fit and proper. Reporting and valuation is done by Crowe Horwath, an international accounting and auditing firm. They make sure all subscriptions/redemptions and computation of NAVs, number of shares and performance fees are done accurately.
Also, we are regulated by the Monetary Authority of Singapore. We fear them and wouldn't want to mess with them.
Is this a scam?
What kind of question is that?
What kind of returns can I expect?
We aim to achieve a net return of 10% p.a. over the long term. Long term means at least five years. We have been quietly achieving this since our inception in Dec 2012. By right, we should blow our own trumpet. Here goes: "Toot! Toot!"
One word of caution - Can you stomach a decline of 50% in the stock market and stay invested? If you can – welcome on board. If you can’t, better stay out of stocks, it will be detrimental to your health.
Do you visit companies you invest in?
Nope. We invest based on studying the financial statements of companies.
Who are you? And what kind of experience do you have?
Combined, the fund managers have more than 30 years experience in the financial industry. Eric was a CFA Charterholder and Wong is a CPA and an ex-auditor with the Big Four. Eric and Wong have worked together before – managing money for high net worth individuals and sovereign funds. Eric was an ex-partner in a local boutique firm before founding Aggregate.
How do you manage currency risk?
We do not use overlays or hedge currency risks. We are not experts in currencies. Hedging here, there, everywhere only makes your banker rich, and subtracts from performance over the long term. Our portfolio of stocks across Asia with businesses in different countries earning different currencies provides somewhat of a hedge – but not completely though. We can live with that.
What do you mean by interest alignment? What is this zero management fee model?
We believe that we should only be rewarded when our clients make money. We also believe that we can add value for our clients over the long term. That is why we have come up with the 0% management fee. For all the other products out there, the charges are: Sales charge of 3-5%, Management Fee of 1-2% p.a. and if your account is under a wrap account, there is a wrap fee of 1% p.a. Is there any surprise that most of the products out there are not meeting your expectations?
How do I subscribe?
Don’t just subscribe – we like to talk to you first. We expect our investors to know what they are doing – and we do not mind spending time and effort in telling you what we do and explaining to you what you are in for. Our experience tells us that 99% clients stay for life. We cannot fathom why the 1% leave.
What is the worst thing that can happen?
Not investing. And timing the market. And flitting from opportunity to opportunity. And wasting precious time which can be used to invest, reap dividends, and watch the NAV grow.
How is the NAV of the fund determined?
The NAV for the fund is determined by Crowe Horwath – they are an independent accounting and fund administration firm.
Who can invest in the fund?
The fund is only for accredited investors. Accredited investors mean individuals with a net asset of SGD$2M or an annual income of $300,000. For companies, they need at least a net asset of SGD$10M.
Is there any lock-in period for my investment?
Yes. We expect you to keep your money there for at least 3 years. If you redeem before the 3 years is up, you have to pay an exit fee of 5%. Please only invest money you do not need. After 3 years, all redemptions have no exit charges.
How can I use this fund for my retirement?
Generally, you can make a withdrawal of 5% of the initial subscription for your retirement needs. For example, for every $1M you have invested, you can make a yearly redemption of $50,000. There is no redemption charge. This is ideal for clients who want an income, and yet have a need to beat inflation.
Can I make subsequent subscriptions in the fund?
Yes. The secret to really making serious money over the long term: Subscribe whenever you have spare cash. Subsequent subscriptions are pegged at a minimum of $10,000 and do not carry any charges. The FULL amount is put to work – there are no bloodsuckers at Aggregate Asset Management leeching out your precious blood.
Isn’t nett returns of 10% p.a. a lofty goal? Is it realistic?
10% p.a. is achievable – our experience tells us so. We will be happy to tell you how.
Do you use technical analysis?
No, we don’t do witchcraft. We don't like hocus-pocus.
Will I lose all my money?
No, not all – but you might lose 50% of it, momentarily. Stay out of stocks if you cannot accept that. In the past 3 big crisis (1985, 1997, 2008), all stocks were annihilated. So if you were to meet with a market crisis (surely it will happen again) – sit tight – do not sell and if possible, invest some more. It will recover, barring a global thermonuclear war.
You do not charge any management fees and sales charge – how do you survive, pay your bills and feed your kids? Are you going to close down anytime soon?
Ahem, we are financially independent. But we are not tycoons with Ferraris. Two of us live in HDBs, and we know how much is enough. We definitely have enough money to go on forever…….or as long as it takes to earn a performance fee.
How do you compute the performance fee? And what is this High Water Mark?
Aggregate Value Fund does not charge annual management fees or sales charges. We only charge a performance fee of 20% on profit based on a high water mark. Let’s assume that you invest at $100 and after some time its value increases to $110. The performance fee is $2 (profit of S$10 x 20%). The net value is $108 after deducting the performance fee of $2. This $108 is a high water mark, as profit is made, and performance fee is taken. Later it goes down to $97. There will be no performance fee, since it’s a loss. Subsequently it rises to $105. There will be no performance fee, since it has not exceeded its high water mark set earlier at $108. Further on, the value rises from $105 to $118. There is a new profit of $10. This is computed by taking the new value $118 minus the old high water mark $108. A performance fee of $2 is charged (20% * $10). Now, the new high water mark is $116. This high water mark mechanism demands that the fund managers earn an absolute profit for the clients before they are rewarded.
What is this $2000 subscription charge? I thought you say no other fees, only performance fees?
The $2000 charge is a one-time flat charge for new clients. You do not need to pay any more for further top-ups. In contrast, there is a 2-5% sales charge that most financial service providers levy on the amount invested or top-up. Whether you invest $200,000 or $2M, our charge is flat at $2000. So why the $2000? This is to cover our admin fee, documentation and subsidize a small part of our audit and compliance fee.
You make it sound so simple……
Value investing is simple to understand, but very hard to implement.
|Management Fee||0% per annum|
|Fund Subscription Charge||SGD 2,000 (one-off)|
|Performance Fee||20% with High Water Mark|
|Early Exit Charges within 1st |
|5% (waived for annual withdrawal of less than 5% of subscription amount)|
|Minimum Investment||SGD 150,000|
|Valuation||Last Trading Day Monthly|
|Subscription||Monthly on 1st Dealing Day|
|Redemption||Quarterly on 1st Dealing Day|
|Auditor||Ernst & Young|
|Fund Administrator||Crowe Horwath First Trust Fund Services|
Aggregate Value Fund is only for accredited investors as stipulated by the Monetary Authority of Singapore.
Check out our latest videos! We have recently added the presentation clips taken during our Client Appreciation Breakfast Seminar that took place in Mar 2019. With the exception of our chairman, it is obvious that we are poor presenters. But believe us, if you sit through the entire thing, you should find something useful. Failing that, you might use it as an aid if you have trouble sleeping. Enjoy...
Our non-executive chairman Professor Kishore Mahbubani kicks off our Client Appreciation Breakfast Seminar held on 23rd Mar 2019 by sharing his insights on relations between the world's two superpowers.
During our Client Appreciation Breakfast Seminar - Investment Made Simple - held on 23rd Mar 2019, Eric makes a strong case for having a basket of only equities in one's investment portfolio.
Seak Eng shares the benefits of value investing for the long-term and how a little difference in returns can make a world of difference in the long run. This is an interesting presentation that was shared during our Client Appreciation Breakfast Seminar on 23rd Mar 2019.
One of our very own clients, David shares the results of some of the work he has been doing alongside Eric during our Client Appreciation Breakfast Seminar on 23rd March 2019.
Eric shows how you can generate cash flows from your stock portfolio for your retirement expenses. Most people structure their retirement based on a mix of equities/bonds/real estates – this may not provide sufficient cash flows if one’s nest egg is too small. The talk was held in June 2015 during the Singapore Investment Week organized by Securities Investors Association Singapore (SIAS).
At our very own first investment seminar - Retirement Made Simple - held on 30th July 2016, Eric shares how retirement can be made simple and building a substantial retirement nest egg made achievable through value investing.
At the BigFatPurse Investors Conference 2016 held on 5th Nov 2016, Seak Eng shares on investing through the "Aggregate" way.
Professor Kishore Mahbubani shares his views on Asia as our keynote speaker during our first investment seminar held on 30th July 2016.
Aggregate Asset Management became the first company to be listed on the private securities exchange, 1exchange (“1X”). 1X is Singapore’s first and only regulated private securities exchanged with a Recognized Market Operator licence granted by the Monetary Authority of Singapore and backed by Singapore Exchange.
After a short six-week campaign where hundreds of investors – from our own clients to the general public – showed their support for us by committing bids, we successfully listed on 1X on 10 July 2019 with over S$5.6 million worth of tradeable private equities representing approximately 5% of the company’s share equity.
Our listing was commemorated by a gong-striking ceremony held in conjunction with SGX’s Daily Securities Market Opening in SGX Centre and graced by distinguished representatives from 1X, Singapore Exchange, etc.
Mohamed Nasser Ismail, SVP and Head Equity Capital Markets, SGX, said, “We recognize that companies in an earlier growth stage may need access to capital before they are ready for a public listing. We supported 1exchange to create a virtuous ecosystem of capital flow catering to companies in the mid-late stages of growth, adding to the vibrancy of the capital markets in Singapore. With 1exchange, companies such as Aggregate Asset Management now have more fundraising options, as well as a means to provide shareholders and other interested investors a market for these tradeable private equities. We are pleased to support this pipeline of private listings and look forward to helping companies prepare for an eventual public listing when they are ready.”
Our very own Kevin Tok, one of the company’s co-founders, said, “When we founded our company, we were among the very first fund managers not to charge a management fee. Today, we are again breaking new ground and making history as Singapore’s first privately-listed company on 1exchange. This private listing kicks off the next chapter of growth for us, and we look forward to bringing more value to our unitholders and shareholders.”
Choo Haiping, CEO of 1X, said, “1X is grateful for the support of our many stakeholders, including regulators, SGX, our partners in the financial industry, and the companies and investors who continue to believe in our mission to create a dynamic and vibrant private capital market through tradeable private equities.”
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