Barely Investible Capital Management Ltd

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Barely Investible Capital Management Ltd

Barely Investible Capital Management Ltd

@LowAlphaHighVol

Hedge fund allocator on an island. Got 99 problems but backtested returns ain’t one.

Heard and McDonald Island 🐧 가입일 Ağustos 2019
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Shobhit Bakliwal
Shobhit Bakliwal@shobhitic·
saw this interview of founder of delve yesterday on instagram
Ryan@ohryansbelt

Delve, a YC-backed compliance startup that raised $32 million, has been accused of systematically faking SOC 2, ISO 27001, HIPAA, and GDPR compliance reports for hundreds of clients. According to a detailed Substack investigation by DeepDelver, a leaked Google spreadsheet containing links to hundreds of confidential draft audit reports revealed that Delve generates auditor conclusions before any auditor reviews evidence, uses the same template across 99.8% of reports, and relies on Indian certification mills operating through empty US shells instead of the "US-based CPA firms" they advertise. Here's the breakdown: > 493 out of 494 leaked SOC 2 reports allegedly contain identical boilerplate text, including the same grammatical errors and nonsensical sentences, with only a company name, logo, org chart, and signature swapped in > Auditor conclusions and test procedures are reportedly pre-written in draft reports before clients even provide their company description, which would violate AICPA independence rules requiring auditors to independently design tests and form conclusions > All 259 Type II reports claim zero security incidents, zero personnel changes, zero customer terminations, and zero cyber incidents during the observation period, with identical "unable to test" conclusions across every client > Delve's "US-based auditors" are actually Accorp and Gradient, described as Indian certification mills operating through US shell entities. 99%+ of clients reportedly went through one of these two firms over the past 6 months > The platform allegedly publishes fully populated trust pages claiming vulnerability scanning, pentesting, and data recovery simulations before any compliance work has been done > Delve pre-fabricates board meeting minutes, risk assessments, security incident simulations, and employee evidence that clients can adopt with a single click, according to the author > Most "integrations" are just containers for manual screenshots with no actual API connections. The author describes the platform as a "SOC 2 template pack with a thin SaaS wrapper" > When the leak was exposed, CEO Karun Kaushik emailed clients calling the allegations "falsified claims" from an "AI-generated email" and stated no sensitive data was accessed, while the reports themselves contained private signatures and confidential architecture diagrams > Companies relying on these reports could face criminal liability under HIPAA and fines up to 4% of global revenue under GDPR for compliance violations they believed were resolved > When clients threaten to leave, Delve reportedly pairs them with an external vCISO for manual off-platform work, which the author argues proves their own platform can't deliver real compliance > Delve's sales price dropped from $15,000 to $6,000 with ISO 27001 and a penetration test thrown in when a client mentioned considering a competitor

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Marco Castelli
Marco Castelli@macastel3·
Kim having the time of his life! Atomic bomb+no oil, he is safe!
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Zhu Su
Zhu Su@zhusu·
The idea that society needs a high birth rate only makes sense if you are a consumer goods company, a boomer hoping someone will buy a house for a much higher price, or planning to conscript people into war. Otherwise, lower population vs national resources will be a major edge. UBI will be cheaper and quality of life will be higher. You can also turn on and off the immigration spigot selectively.
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Tyler
Tyler@TylerDurden·
I’m currently in Viet Nam and rumours on the street is they have almost run out of fuel. 40% increase in price overnight. They asked China to lend them jet fuel and they’ve said no.
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@NickNemo17 @RichWheelahan It looks more precarious than ever. I've learnt not to underestimate the immense creativity of the PE industry to come up with new solutions to keep it going a while longer. And I gotta say, on the allocator side, PE is still really really cool. Time will tell.
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Nick Nemeth (Mispriced Assets)
TLDR: I am a recovering alcoholic with no fund, no credentials, and no lobbyist. I rebuilt myself from nothing. Then I broke into finance with no degree, no pedigree, and no permission. I parsed SEC filings for a $31.5 billion private credit fund called Cliffwater. Not because anyone asked me to. Because nobody else would. The filings are public, but they are buried in footnotes that are not indexed, not searchable, and not structured for analysis. I have been told by fund managers that nobody even attempts this. Billions of dollars in pension capital, and the people who manage money for a living do not bother to read the filings. So I read them. Every loan. Every amendment. Every semi-annual PIK disclosure. 2,330 positions. I hand-researched fifty. I found 189 loans where borrowers are paying interest with more debt instead of cash. I found over 50 loans that are not generating enough cash to service their debt at all — carried at par on the books of a fund that has never reported a losing month in 41 months. The fund's Sharpe ratio is 3.75. Bernie Madoff — who was fabricating returns and could pick any number he wanted — ran a 3.5. He got caught because the numbers were too smooth by Markopolos. The greatest quant fund in history, Renaissance Technologies, runs a five or six. Cliffwater is claiming risk-adjusted returns that would be impossible even if you insider-traded with perfect information every single time, because the volatility of the underlying markets would still prevent it. Nobody asked questions. Bloomberg confirmed 14% redemptions 48 hours after I published. S&P cut the fund's outlook to negative this week. Cash on hand fell 76% in six months. This is not an isolated fund. This is the structure. $9.4 trillion in private equity. $3.5 trillion in private credit. They all pay their own valuation agents. The valuation agents decide what the funds are worth. No valuation agent has ever been fired for saying the number was too high. The marks produce the NAV. The NAV produces the fees. The fees come from pensions. The pensions come from firefighters and teachers and nurses in Oregon and California and Illinois who will never read a private placement memorandum in their lives. Wall Street ran out of rich people. The endowments were full. The sovereign wealth funds were tapped. So they went downstream — to 401(k)s, to retirement accounts, to interval funds sold to people who have no idea what they own. 1. Direct the SEC and FSOC to examine Level 3 fair value practices across interval funds and BDCs. 2. Require that valuation agents be independent of the funds they mark. 3. State publicly that the current self-marking regime creates systemic risk. 4. Mandate position-level mark disclosure for every fund that accepts pension capital. There are two ways this ends. It breaks all at once like 2008 and we fix it. Or it rots slowly like Japan: one fund blows up, six weeks of quiet, another one, and nobody connects it for a decade while a generation of retirees gets destroyed. I am not asking anyone to take my word for it. I am asking them to read the filings. If you know someone in the administration, a regulator, or anyone on a legislative committee, please send this to them. One person learned this from a one-bedroom apartment. Your government can too. The will is what is missing.
Nick Nemeth (Mispriced Assets)@NickNemo17

x.com/i/article/2034…

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@NickNemo17 @RichWheelahan Thanks, good stuff. I think most PE investors know it's all fantasy so you look at the cash on cash returns at the end of the day (yes, you may overpay mgmt fee on inflated marks in between but eh). If cash on cash returns are ok, nobody cares. Issue is if exits stop.
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@yieldsearcher Unless the volume is larger than the $1.8 trillion underlying market I doubt we will run into a CDO-squared type of leverage situation. Those institutions were happy to bet against someone betting against the housing market (decades of bias). Don't see PC having the same allure.
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One of my issues with PC funds is that they even bother with monthly marks. When I get a HF letter I know the marks are based on actual markets. And even then, they will often qualify it by underlying book liquidity. Best practice is to MARK TO LIQUIDITY. Rest is 🌈🦄
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@NickNemo17 Agree. Not a glamour job either. Actually the bigger question is when a fund sends out a factsheet with NAV marks what are they marking towards? Mark to market would imply there’s a market. Net asset value would imply value is absolute 🤔 you’ve inspired me to write a post.
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Rui Ma
Rui Ma@ruima·
In China, there is a joke going around right now that, 2026 is apparently the Year One 元年 of literally everything: 1/ autonomous driving 2/ liquid cooling 3/ domestic HBM 4/ on-device AI 5/ solid-state batteries 6/ AI applications 7/ quantum computing 8/ compute-memory integrated chips 9/ brain-inspired computing 10/ the low-altitude economy 11/ commercial space 12/ humanoid robots 13/ silicon photonics 14/ controllable nuclear fusion Is there a frontier technology that ISN'T going to hockey stick / cambrian explode this year???
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NIK
NIK@ns123abc·
🚨BREAKING: SUPER MICRO CO-FOUNDER ARRESTED FOR SMUGGLING $2.5B IN NVIDIA GPUs TO CHINA >SMCI co-founder Yih-Shyan "Wally" Liaw arrested today >personally holds $464 MILLION in SMCI stock >charged with smuggling BILLIONS in Nvidia servers to china >used a southeast asian shell company to funnel $2.5B in servers to chinese buyers >$510 million worth shipped in just THREE WEEKS in spring 2025 >built thousands of fake dummy servers to fool U.S compliance auditors >caught on surveillance camera using a HAIR DRYER to swap serial number stickers >coordinated the whole thing over encrypted group chats >SMCI down 12% after hours >faces up to 30 years in federal prison ITS SO OVER…
NIK tweet mediaNIK tweet media
National Security Division, U.S. Dept of Justice@DOJNatSec

Three Charged with Conspiring to Unlawfully Divert Cutting Edge U.S. Artificial Intelligence Technology to China “The indictment unsealed today details alleged efforts to evade U.S. export laws through false documents, staged dummy servers to mislead inspectors, and convoluted transshipment schemes, in order to obfuscate the true destination of restricted AI technology—China,” said John A. Eisenberg, Assistant Attorney General for National Security. “These chips are the product of American ingenuity, and NSD will continue to enforce our export-control laws to protect that advantage.” 🔗: justice.gov/opa/pr/three-c…

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@rev_cap Some people sell, some people buy. I think the rotations under the surface are more important. Also, genuine q, if stocks haven't dipped yet, have dip buyers bought the dip yet? A q for a higher power.
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Rev Cap
Rev Cap@rev_cap·
A 5 sigma selling day and stocks are down 25bps
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@gnoble79 "Too much money, too much leverage, too little discipline, and a financial product sold as "safe" to people who didn't understand what they owned." I'm not a pod shop doom boy but the first two definitely apply to the pods. Second two not so much (yet). Sorry, off topic.
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George Noble
George Noble@gnoble79·
Private credit didn't blow up because of Blue Owl or bad software loans or AI disruption. Those were SYMPTOMS. The disease is the same one I've seen 3 times in 45 years on Wall Street: Too much money, too much leverage, too little discipline, and a financial product sold as "safe" to people who didn't understand what they owned. Private credit grew to $3 trillion on a simple lie - that you could earn 9-10% yields with "semi-liquidity" on assets that have no liquid market. That's not investing. That's volatility laundering. And the Street dressed it up beautifully. "Private credit." Sounds so exclusive, so sophisticated. Illiquid loan sharking would be more accurate. And don't get me started on "private equity", another Wall Street rebrand designed to make LEVERAGED BUYOUTS sound like fine wine. They changed the name because the old one scared people. The risk didn't change. Just the marketing. Wall Street has always been brilliant at one thing: rebranding risk as exclusivity and selling it to people who don't know what they're buying. Now add oil at $113 a barrel and watch the whole thing come apart. The Strait of Hormuz is shut. The IEA is calling it the largest supply disruption in the history of the global oil market. The Fed held rates steady yesterday and the market just RIPPED AWAY expectations for even a single cut this year. Oil is the fuse. But the TNT was packed years ago. Oil above $100 means inflation stays sticky. No rate cuts. Every overleveraged borrower inside these private credit portfolios gets squeezed harder every single month. Interest coverage ratios deteriorate. Defaults tick up. Valuations get marked down. And when valuations drop, the leverage stacked on top of that leverage (the "back-leverage" that banks provide using those same loans as collateral) starts to unwind. And JPMorgan already started. They marked down software loan collateral and restricted lending to private credit funds. When the biggest bank in America pulls back, that's a SIGNAL. High-yield spreads just surged to 470 basis points. The widest in years. Credit markets are screaming what equity markets haven't fully heard yet. I've watched this exact pattern before. - Junk bonds in the '80s - Dot-com leverage in 2000 - Structured mortgage products in 2007 The product changes every time but the architecture never does: Wall Street creates something complex, sells it as safe, layers leverage on top, markets the yields to retail investors, and collects enormous fees on the way in. Then something breaks and the gates go up. The people who built the machine are fine - they already got paid. The people who bought the brochure are trapped behind locked doors. $265 billion in market cap already wiped from the major PE firms. I don't think we're close to done. And you know what? That's FANTASTIC. Perhaps we'll finally get some real price discovery. Just say no to mark to model. Holders of this fine merchandise will get the returns they deserve. The pension funds, endowments, and insurance companies that piled into this garbage should take the hit. No bailouts. NONE. This nonsense has gone on far too long and moral hazard is the predictable result. The only way to end this insanity is to let Mr. Market operate. Allow price discovery. Allow bankruptcy. No more money printing. No more crony capitalism. No more extend and pretend. Blow it all up. That is the only way. "But what about the individuals who get hurt!" Better to take the hit now and reset than continue down this road. Hyper-financialization is destroying our economy and enriching the fortunes of the few. This must stop. NOW. But I have little confidence it will. We'll get more of the same: Rule changes. Special accommodations. The inevitable big ease will come. Count on it. AND BUY GOLD
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Rui Ma
Rui Ma@ruima·
The “genius girl” who previously worked at DeepSeek and was recruited by Lei Jun for Xiaomi AI is now on Twitter as well. It feels like more Chinese AI talent is realizing they can come here, speak for themselves, and build influence directly. I’m all for the added interaction and transparency.
Fuli Luo@_LuoFuli

MiMo-V2-Pro & Omni & TTS is out. Our first full-stack model family built truly for the Agent era. I call this a quiet ambush — not because we planned it, but because the shift from Chat to Agent paradigm happened so fast, even we barely believed it. Somewhere in between was a process that was thrilling, painful, and fascinating all at once. The 1T base model started training months ago. The original goal was long-context reasoning efficiency. Hybrid Attention carries real innovation, without overreaching — and it turns out to be exactly the right foundation for the Agent era. 1M context window. MTP inference for ultra-low latency and cost. These architectural decisions weren't trendy. They were a structural advantage we built before we needed it. What changed everything was experiencing a complex agentic scaffold — what I'd call orchestrated Context — for the first time. I was shocked on day one. I tried to convince the team to use it. That didn't work. So I gave a hard mandate: anyone on MiMo Team with fewer than 100 conversations tomorrow can quit. It worked. Once the team's imagination was ignited by what agentic systems could do, that imagination converted directly into research velocity. People ask why we move so fast. I saw it firsthand building DeepSeek R1. My honest summary: — Backbone and Infra research has long cycles. You need strategic conviction a year before it pays off. — Posttrain agility is a different muscle: product intuition driving evaluation, iteration cycles compressed, paradigm shifts caught early. — And the constant: curiosity, sharp technical instinct, decisive execution, full commitment — and something that's easy to underestimate: a genuine love for the world you're building for. We will open-source — when the models are stable enough to deserve it. From Beijing, very late, not quite awake.

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@gothburz 😂 Brilliant, the 401k scene killed me. For a guy who loses way too much money I'm glad to see you keep coming up with more of it for the next 'frontier' investments. Onwards and upwards as they say. Will refrain from adding rocket emojis.
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Peter Girnus 🦅
Peter Girnus 🦅@gothburz·
My net worth peaked at $1.2 million. None of it was real. I don't mean that philosophically. I mean it was located on servers that have since been turned off. I own eleven properties in the metaverse. Three in Decentraland. Four in The Sandbox. Two in Voxels. One in Otherside. And a beachfront villa in Horizon Worlds that I bought for $214,000 because Mark Zuckerberg called it "the next frontier." The frontier closed last week. It's a mobile app now. Last year I mass DM'd 340 people the phrase "you don't understand how early we are." I have since stopped doing that. Not because I was wrong. Because most of them blocked me. I got into metaverse real estate in November 2021. Everyone was buying. Someone paid $450,000 to be Snoop Dogg's neighbor. In a video game. With no legs. The avatars didn't have legs. I thought that was bullish. "The legs are coming," I told my Discord. "Legs are a roadmap item." Three hundred people reacted with rocket emojis. I called myself a "digital land baron." I put it in my Twitter bio. I put it in my LinkedIn headline. I said it on a podcast that had eleven listeners. Three of them were bots. The rest were my alts. My virtual property has more square footage than my actual apartment. My actual apartment has furniture. Location, location, location. My most valuable asset was a plot next to a virtual Gucci store. Gucci left in 2023. The store is still there. Nobody's in it. It's like a mall in Ohio but with worse graphics and no food court. I held. Diamond hands. That's what we said. "Diamond hands." It means refusing to sell while your investment loses 94% of its value. We turned financial paralysis into a personality trait. A guy in my Discord paid $2.4 million for a 618-parcel estate in Decentraland. Prime district. High foot traffic. I asked him what "foot traffic" meant when the platform had 38 daily active users. He said I didn't understand the technology. I didn't. I still bought more. We had a DAO. A decentralized autonomous organization. That means we voted on decisions. There were nine of us. Three never showed up. Two voted on everything without reading it. The other four were me and my alts. We voted to "acquire strategic parcels." The vote passed unanimously. I voted four times. My portfolio peaked at $1.2 million. I told everyone. I made a spreadsheet. I projected 40x returns by 2025. I made a pitch deck. The pitch deck had a slide that said "WE ARE BUILDING THE DIGITAL ECONOMY." The slide had a rocket emoji. That was my entire financial model. In 2023 I bought a Bored Ape for $189,000. It's worth $14,000 now. I don't talk about the Ape. I still use it as my profile picture. People ask me about it. I say "I'm long-term bullish." Long-term bullish means I can't sell it without crying in a Panera. My mom asked me what a Bored Ape was. I said "digital art on the blockchain." She asked why it cost more than her car. I said "you don't understand Web3." She said "I understand you live in a studio apartment." She's not in my Discord. Justin Bieber bought one for $1.3 million. It's worth about $90,000 now. I felt better about mine after I heard that. That's community. WAGMI. We're All Gonna Make It. We said that every day. In the group chat. While the floor dropped. While the volume dried up. While 95% of all NFT collections went to zero. We're all gonna make it. None of us made it. But we said it with conviction and a laser-eye profile picture. That counts for something. It doesn't. But we said it did. That's decentralized consensus. Meta spent $84 billion on the metaverse. I need to say that again. $84 billion. More than the GDP of Luxembourg. More than the GDP of Iceland, Luxembourg, and Malta combined. They spent it on a platform where the avatars had no legs, the graphics looked like a 2006 Wii game, and the peak user count was lower than the lunch rush at a Chipotle in Des Moines. They just pulled Horizon Worlds from VR headsets. It lives on as a mobile app. My beachfront villa is now a mobile app. Location, location, location. Zuckerberg renamed the entire company for this. Facebook became Meta. A $900 billion company changed its legal name because the CEO watched Ready Player One and said "I want that." Reality Labs lost $10 billion in 2021. $14 billion in 2022. $16 billion in 2023. $18 billion in 2024. $19 billion in 2025. That's not a strategy. That's a speedrun. They laid off 1,500 Reality Labs employees this year. Shut down three VR studios. Killed Supernatural. Put the entire VR social vision in a casket and said "we're pivoting to AI and wearables." The pivot took four years and $84 billion. I pivoted too. I'm an AI real estate investor now. I bought a virtual plot in an AI-generated world that doesn't exist yet. The founder said it was "the intersection of spatial computing and large language models." I don't know what that means. I gave him $40,000. He has a whitepaper. It's 47 pages. I read the title and the tokenomics section. The tokenomics section is a pie chart. I love pie charts. They make everything look like a plan. The project has a roadmap. Q1: "Build community." Q2: "Launch beta." Q3: "Scale ecosystem." Q4 is blank. Q4 is always blank. That's where the exit scam goes. My accountant asked me to value my metaverse portfolio for tax purposes. I said $1.2 million. He said "current market value." I said $6,400. He stared at me for eleven seconds. I know because I counted. He asked if I had any other investments. I showed him my NFTs. He stared for longer. I told him they were "cultural artifacts with long-term provenance." He asked if I'd considered a 401k. I told him a 401k was "legacy finance." He told me to leave his office. The metaverse is dead. I don't accept that. I am a digital land baron. I own eleven properties across four platforms. I have a beachfront villa in a mobile app, a plot next to an empty Gucci store, and a cartoon monkey that cost me more than my actual car. Location, location, location. The location is nowhere. But I'm early. I'm always early. That's the same as being wrong except you get to say it with confidence.
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Morgan Stanley Survey: 2026 investor sentiment rose to the highest level in a decade as HF industry hits peak AUM $5.2Tr, sentiment driven by rise in the % of investors that expect to allocate MORE to HFs rising and the % of investors that plan to allocate LESS to HFs declining.
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