The manager of a hedge fund has to have at least passed the Series 7 examination and Costello isn't listed as a broker dealer with FINRA - plus the pdf document was for assets below $150 million.
"RIN 3235-AK81 Exemptions for Advisers to Venture Capital Funds, Private Fund Advisers With Less Than $150 Million in Assets Under Management, and Foreign Private Advisers"
I advise anyone to contact the SEC Enforcement Division - Complex Financial Instruments Unit - and ask them if a hedge fund with over a Billion dollars in assets has to register with the SEC.
And ask if a limo driver with no securities trading etc can manage the fund with self regulation.
Costello doesn't meet the ?private adviser exemption.