Jim Grant, author of Grant’s Interest Rate Observer, first hinted last week that not all is well when it comes to the world’s biggest hedge fund, Ray Dalio’s $160 billion Bridgewater (of which one half is the world’s biggest risk-parity juggernaut). Speaking to Bloomberg last week, Grant said he was “bearish” on Bridgewater because founder Dalio has become “less focused on investing, while the firm lacks transparency and has produced lackluster returns.”

Grant slammed Dalio’s transition from investor to marketer, and in a five-page critique of the world’s largest hedge fund, said Dalio has been preoccupied with his new book, sitting for media interviews and sending Tweets.

“Such activities have one thing in common: They are not investing,” Grant writes in the Oct. 6 issue of his newsletter. “Yet here he is, laying it all out to the world again, Tweeting, promoting his book, attacking the press — necessarily doing less of his day job than he would otherwise do.”

Grant continued his scathing critique, accusing Bridgewater of “lately performed no better than the typical hedge fund.” Grant is right: since the start of 2012, Bridgewater’s Pure Alpha II Fund has posted an annualized return of 2.5% vs its historic average of 12%, and is down 2.8% this year through July.

The underperformance may be explainable: after all the polymath billionaire has been busy opining in recent months on subjects from the rise of populism to his affinity for China, “which are distraction from making money” Grant said.

But if Grant had limited himself to merely Dalio’s stylistic drift, it would be one thing: to be sure, the fund’s billionaire founder may simply have lost a desire to manage money and has instead discovered a flair for writing books and being in the public spotlight.

However, Grant – or rather his colleague Evan Lorenz – went deeper, and as he writes in the latest Grants letter, he raises several troubling points, which go not to the hedge fund’s recent underprofmrance – which can be perfectly innocuous -but implicitly accuse the world’s biggest hedge fund of borderline illegal activities and, gasp, fraud. Some of the more troubling points brought up by Lorenz are the following:

  • Bridgewater has directly lent money to its auditor, KPMG, to which KPMH’s response is that “these lending relationships . . . do not and will not impair KMPG’s ability to exercise objective and impartial judgment in connection with financial statement audits of the Bridgewater Funds.”
  • Bridgewater has 91 ex-employees working at its custodian bank, Bank of New York.
  • Only two of Bridgewater’s 33 funds have a relationship with Prime Brokers. In these two funds, Bridgewater Equity Fund, LLC and Bridgewater Event Risk Fund I, Ltd., 99% of the investors are Bridgewater employees.
  • Opaque ownership concerns: “Two entities—Bridgewater Associates Intermediate Holdings, L.P. and Bridgewater Associates Holdings, Inc.—are each noted as holding 75% or more of Bridgewater.”
  • Why the massive, and expensive, ETF holdings: “The June 30 13-F report shows U.S. equity holdings of $10.9 billion. The top-16 holdings, worth $9.5 billion, or 87% of the reported total, come wrapped in ETFs, including the Vanguard FTSE Emerging Markets ETF, the SPDR S&P500 ETF Trust and the iShares MSCI Emerging Markets ETF. Beyond the fact that Bridgewater reports holding few U.S. equities, you wonder why such a sophisticated shop would stoop to such a retail stratagem. Surely the Bridgewater brain trust could replicate the ETFs at a fraction of the cost that the Street charges.”
  • And perhaps most troubling, is the SEC in cahoots with Bridgewater? “Lorenz asked the SEC how Bridgewater’s answers comply with the requirement to “[p]rovide your fee schedule.” Via email, the agency replied, “Decline comment, thanks.
  • And so on. There is much more in the full Grant’s note, transcribed below which everyone who has even a passing interest in Bridgewater should read (and of course subscribe to Grant’s, which together with 13-D, are the two best newsletters on Wall Street).

    * * *

    The face on the Wall Street milk carton

    Ray Dalio, founder, chairman and co-chief investment officer of Bridgewater Associates, L.P., is going public—personally. He has written a book, given a TED talk, sat for interviews, dueled with journalists (or, as he styles them, “journalists”) and paid money—actually paid—to promote his tweets. Such activities have one thing in common: They are not investing.

    Distraction, sycophancy, mystery and, of course, interest rates are the topics at hand. In preview, Grant’s is bearish on the world’s biggest and most client-enriching hedge-fund organization.

    As Bridgewater is closely held, this must be a conceptual short-sale. It’s no less important for that reason, we think. At major market inflection points, someone is revealed to have zigged when he should have zagged. One thinks, in recent years, of Lehman Brothers Holdings, Inc. (2008), Long-Term Capital Management, L.P. (1998) and Drexel Burnham Lambert, Inc. (1990); and in ancient times, in the City of London, of Overend, Gurney & Co. (1866) and Baring Brothers & Co. (1890). Nobody knows when today’s credit-enhanced, central-bank-infused, interest-rate-inflated updraft in asset prices will run its course, still less the name of the firm with which history will associate that inflection point. For the latter distinction, Grant’s is penciling in the name of the firm that Dalio built.

    Bridgewater’s success is a matter of figures, its eccentricity a matter of opinion. Anyway, “eccentricity” is a relative term in the investment business. On the one hand, the man who displaces George Soros at the top of the heap as the all-time net money-maker, as Dalio is said to have done in 2015, is allowed to tape-record all the meetings he wants (it’s just what Ray does). On the other hand, if that same man, in a setting of mediocre returns and declining assets under management, chooses to persist in tape-recording his meetings, people may start to wonder if something isn’t off. We say that something is.

    Dalio’s new book, Principles (we’ve purchased copies for distribution at the Oct. 10 Grant’s Conference —advt.), documents not just the oddity of the firm and its founder, though there’s plenty of that to marvel at. The reader may remark, too, at Dalio’s affinity for the People’s Republic of China and its communist kingpins. Concerning Wang Qishan, one of the senior head-knockers in the ruling politburo, for instance, Dalio has this to say: “Every time I meet with Wang, I feel as if I get closer to cracking the unifying code that unlocks the laws of the universe.”

    Compound rates of return are apolitical. Left-wing crotchets were neither here nor there when Soros broke the Bank of England in 1992. Nor do Dalio’s politics count, whatever they might be. What matters are facts, returns and—a particular touchstone at Bridgewater—transparency.

    “Mr. Dalio,” reported The Wall Street Journal on Sept. 8, “has repeatedly instructed Bridgewater’s hundreds of investment researchers to be careful about writing outright negative outlooks about China, reminding them that he is sanguine about its long-term prospects.”

    Dalio, who sat at the head of a Bridgewater executive committee he called the “politburo” and who (again according to the Journal) is a frequent visitor to China, a donor of “tens of millions of dollars” to Chinese charities and the would-be manager of a new fund to manage billions in domestic Chinese assets, is in no position of intellectual flexibility with respect to what might prove the world’s No. 1 macroeconomic problem. There’s no such thing as a kowtowing analyst.

    “In one long sentence,” Dalio summarized the message of his new book in a Sept. 23 blog post on LinkedIn, “our success occurred because we created a real idea meritocracy in which the goal was to have meaningful work and meaningful relationships and the way we went after them was through radical truthfulness and radical transparency” (Dalio supplied the emphasis).

    Seventy-four comments were overwhelmingly positive. Queried one: “Is there a platform to vote Ray Dalio as president of planet earth? These principles will do our world a lot of good.” Raved another: “Wow! Great masterpiece. Very inspiring and informative. Will definitely get a copy.”

    Dalio’s book proceeds from a view of the supposed duality of the human mind, the base portion and the elevated one. The trick is to beat back the former and unlock the latter. Which leads to such principles as, “Understand the great brain battles and how to control them to get what ‘you’ want” and “Realize that the conscious mind is in a battle with the subconscious mind” and “Know that most constant struggle is between feeling and thinking.”

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