This is not a very meaningful hurdle, though.
For example, let me pitch you on the Patio11 Hedgehog Fund. It uses complicated financial alchemy to produce market-beating returns, and you only pay if we beat the market. The fund has never lost money. Care to invest $10 million? You pay 2% per year and 20% of returns above the S&P 500.
Hypothetically suppose the S&P is up 10% next year. I deliver 20% returns. Alchemy, what can I say. You make $1.6 million, I make $0.4 million (from you), and since I did this in parallel with 100 other people life is pretty grand for me.
Now just between HN and me, my strategy is simple: I buy the S&P 500 as an index but I use 2X leverage.
What would have happened if the market went down 5% next year? Well, we would have lost 10%. That certainly sucks, and you need to make your $1 million back. Which is great, because I am now accepting new money on the Patio11 Chinchilla Fund. It uses complicated financial alchemy to produce market-beating returns, and you only pay if we beat the market. The fund has never lost money.