| Investor Letter - Second Quarter 2008
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Dear
Client/Friend,
During the first six months of 2008, we are pleased to
deliver positive returns while the market was down
substantially. In these times, we remain primarily focused on
protecting our capital, while seeking new investment
opportunities using our value-oriented approach.
Thanks again for your trust and your referrals -- they
are the highest form of compliment.
Sincerely,
Charles Goldblum,
CFA
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Composite Of Hurley Capital Accounts Up 1.0%
Year-To-Date Versus An 11.9% Decline for the S&P
500
In the first half of 2008, the Hurley
Capital Core Equity Composite of accounts managed by Hurley
Capital rose 1.0% after all fees and expenses. In comparison,
the S&P 500 fell 11.9%, including dividends.

Our 2008 outperformance to date is due
strong second quarter returns:
Q208 Investment
Performance
Hurley Capital Core Equity
Composite + 6.02%
S&P 500, Total Return
-
2.73%
Our portfolio focus has been on strong
industries such as energy and hypermarkets and avoidance of
the weakest industries such as financials, telecoms, and
industrials. Leading gainers year-to-date include Chesapeake
Energy, Wal*Mart and our short position in Choice Hotels,
while our losses were largest in our short position in
Arkansas Best, and long positions in Avid Technology and SK
Telecom.
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Standing
On The Shoulders Of Giants
In past newsletters we've
discussed value investment strategies learned from established
and renowned mutual fund managers such as Marty Whitman of the
Third Avenue Value Fund (Low Risk Does
Not Mean Low Returns), Bruce Berkowitz of the Fairholme
Fund (How Can We
Lose?), and Wally Weitz of the Weitz Value Fund (Bird-In-The-Hand
Investing). We recently travelled to Memphis to attend the
annual meeting for the Longleaf Funds, managed by a team led
by Mason Hawkins. An example of how difficult this market has
been is the recent performance of these great investors. As
the below graphic shows, we've outperformed these managers so
far this year, and more importantly, over the last three
years.
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Behind The Numbers: Explaining Recent Performance
Our performance to date, including this
year's outperformance, is due to adhering to our
investment methodology, which centers on the following
disciplines:
- Macro Drives
Micro - Invest in industries with positive secular or
cyclical trends. Within those industries, find inexpensive
stocks. Our investment in Wal*Mart is taking advantage of
the cyclical trend of consumers "trading down" into more
affordable products. At recent prices, we believe
Wal*Mart trades at an 8-9% free cash flow yield, that will
grow in 2009. Importantly, avoiding struggling industries
has prevented us from "bottom-fishing" in home-builders,
financials or consumer discretionary sectors.
- Buy At
Discounts To Private Market Valuations - Loews Corp
trades at about a 25% discount to the value of its
investments. While these investments may fall in value, we
get the proven skills of the Tisch family at a discount and
the benefits of any value-creating transactions for free.
Chesapeake Energy trades at a about 12% free-cash-flow yield
on current 2009 estimates, not accounting for any of the
upside associated with ongoing exploration success. The
stock is up this month, on a recent announcement of a
partnership on a new natural gas find in Louisiana that
implies $10 billion of additional value to shareholders.
- Invest
Defensively - A company's underlying value, if not
its stock price, is defined by the level of free cash flow
it can produce. We believe that if we can find companies
with high and durable free cash flow, our investment can be
considered defensive. Leading Korean wireless telecom
provider SK Telecom should have a free cash flow yield of
over 12% this year based on current prices. With the sale of
its underperforming Helio wireless startup in the USA, we
believe this defensive investment should hold it's value.
Enbridge Energy Management and our prior ownership of
Stamps.com are other examples of defensive investments that
have held their value in these difficult market conditions.
Comparison Of Change In Value Of $10,000 Investment, Net Of Fees

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What To Watch For
We continue to spend our time building and maintaining
conservative, value-oriented portfolios for our clients;
talking to companies, their suppliers, customers and
competitors. We are pleased with the results so far and look
forward to providing good risk-adjusted returns for clients
over the long-term. For more information on Hurley Capital,
including previous newsletters, please visit our website: Hurley
Capital. Sincerely, Charles Goldblum,
CFA Hurley Capital
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| Important Disclosure
The Hurley Capital
Managed Accounts Composite represents all actual client
accounts invested in this strategy for the entire year.
The Hurley Capital Managed Accounts Composite allocates client
portfolios in equity and fixed income investments, weighted
according to Hurley Capital's proprietary investment
strategy.
Actual client
accounts utilizing the Hurley Capital Managed Accounts
Composite may have varying allocations between equities and
fixed income investments based on individual investment
preferences. The results of the Hurley Capital
Managed Accounts Composite are net-of-fees, brokerage
commissions, and other expenses. Hurley Capital's
investment advisory fees are described in the disclosure
statement of Part II of the Form ADV which is available upon
request.
The results of the
Hurley Capital Managed Accounts Composite include the
reinvestment of dividends. Comparison of the Hurley
Capital Managed Accounts Composite to the S&P 500 and
NASDAQ Composite is for illustrative purposes only and the
volatility of the indices used for comparison may be
materially different from the volatility of the Hurley Capital
Managed Accounts Composite due to varying degrees of
diversification and/or other factors.
Past performance of
the Hurley Capital Managed Accounts Composite may not be
indicative of future results and the performance of a specific
individual client account may vary substantially from the
composite results above in part because client accounts may be
allocated among several portfolios. Different types of
investments involve varying degrees of risk, and there can be
no assurance that any specific investment will be
profitable.
Performance is
expressed in US Dollars (USD). A complete list of current
recommendations is available upon request.
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Hurley Capital, LLCCore Equity CompositeAnnual Disclosure Presentation

Core Equity Composite
contains fully discretionary core equity accounts and for comparison
purposes is measured against the S&P 500. Since inception, the
minimum account size for this composite has been $50
thousand.
Hurley Capital, LLC has prepared and
presented this report in compliance with the Global Investment
Performance Standards (GIPSŪ).
Hurley Capital, LLC is an
independent registered investment adviser with the states of New
York and Connecticut. The firm maintains a complete list and
description of composites, which is available upon
request.
Results are based on fully discretionary accounts
under management, including those accounts no longer with the firm.
Prior to August, 2004, the composite had 100% non-fee paying
accounts in the composite. Composite performance is presented net of
foreign withholding taxes on dividends, interest income, and capital
gains. Withholding taxes may vary according to the investor's
domicile. Leverage/Derivatives may make up a material part of the
composite strategy which includes short selling, with the short
position covered by cash accounts that are marked to market on a
daily basis. Past performance is not indicative of future
results.
The U.S. Dollar is the currency used to express
performance. Returns are presented gross and net of management fees
and include the reinvestment of all income. Net of fee performance
was calculated using actual management fees. The annual composite
dispersion presented is an asset-weighted standard deviation
calculated for the accounts in the composite the entire year.
Additional information regarding the policies for calculating and
reporting returns is available upon request.
The investment
management fee schedule for the composite is 1.5% on the first $2
million, and negotiable thereafter, or 1% on all balances plus 10%
of annual investment gains, subject to high-water marks. Actual
investment advisory fees incurred by clients may vary.
The
Core Equity Composite was created August 31, 2003. Hurley Capital,
LLC's compliance with the GIPS standards has been verified for the
period of August 31, 2003 through December 31, 2007 by Ashland
Partners & Company LLP. In addition, a performance examination
was conducted on Core Equity Composite beginning August 31, 2003.
A copy of the verification report is available upon request.
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