...What I am missing here is the SEC (or any variation of it)...
As some participants might be aware, up until a certain threshold fund size, the SEC does not require that hedge funds disclose their holdings or their trading activity; thus, analogies based on whether the SEC or some variant is present or "missing" don't seem to bear directly on the question of disclosure for a fund of this size.
The SEC also doesn't allow non-qualified investors to invest in Hedge Funds either.