Inference Investigation

Claim investigated: The multi-year gap between established SEC filing dates (2010-07-26 to 2016-07-22) suggests either inconsistent filing or gaps in the documented record that warrant verification Entity: Clarium Capital Original confidence: inferential Result: STRENGTHENED → SECONDARY

Assessment

The inference is well-supported by documented evidence showing a clear 6-year gap in SEC filings between 2010-07-26 and 2016-07-22. This gap likely indicates Clarium fell below the $100 million AUM threshold requiring 13F quarterly filings, consistent with its documented decline from ~$7 billion to under $1 billion during this period. However, Form ADV filings may have continued throughout this period under different requirements.

Reasoning: The filing gap is documented in primary sources and aligns with known AUM decline patterns. The inference correctly identifies that different SEC forms have different filing thresholds - 13F requires $100M+ in equity assets while Form ADV has different triggers. The gap suggests operational but sub-threshold activity rather than complete cessation.

Underreported Angles

• The specific mechanisms by which hedge funds transition between SEC filing requirements as AUM crosses thresholds, particularly the interplay between 13F quarterly equity disclosures and Form ADV annual adviser registrations
• The potential for Clarium to have maintained operations through separately managed accounts or offshore structures that wouldn't trigger US reporting requirements during the gap period
• The timing correlation between Danzeisen's 2008 arrival and the fund's subsequent AUM decline, suggesting personnel changes may have coincided with strategic repositioning
• Whether Clarium maintained active trading during the filing gap period through structures that fell below disclosure thresholds, potentially including family office conversions

Public Records to Check

• SEC EDGAR: Form ADV filings for 'Clarium Capital Management LLC' between 2010-2016 Form ADV filings may have continued during the 13F gap period, confirming continued registration as an investment adviser even below equity disclosure thresholds.

• SEC EDGAR: Form PF filings for 'Clarium Capital Management LLC' 2012-2016 Form PF became required in 2012 for hedge fund advisers with $150M+ AUM, potentially capturing activity during the 13F gap period.

• SEC EDGAR: Form 13F amendments or corrections for Clarium Capital 2010-2016 Late or amended filings could indicate continued activity that wasn't captured in standard filing searches.

• Companies House: Clarium Capital entities or subsidiaries in UK jurisdiction 2010-2016 Offshore subsidiary structures could explain continued operations without triggering US disclosure requirements during the gap period.

Significance

SIGNIFICANT — This finding illuminates the operational mechanics of hedge fund decline and regulatory compliance, showing how firms navigate disclosure thresholds during asset decline. It also raises questions about what activities Clarium maintained during the gap period and whether the fund's later resumption of filings indicates partial recovery or restructuring.