EFTA01372464.pdf

Item 7 Private Fund Reporting Yes No B. Are you an adviser to any private fund? r If "yes," then for each private fund that you advise, you must complete a Section 7.8.(1) of Schedule O, except in certain circumstances described in the next sentence and in Instruction 6 of the Instructions to Part IA. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-registered adviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser), do not complete Section 7.8.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.8.(2) of Schedule D. In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similar designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.8.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting No Information Filed SECTION 7.B.(2) Private Fund Reporting No Information Filed Item 8 Participation or Interest in Client Transactions In this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occur between you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the next year. Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates. Proprietary Interest in Client Transactions A. Do you or any related person: Yes No (1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)? ✓ r• (2) buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients? • r (3) recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary ✓ r. (ownership) interest (other than those mentioned in Items 8.A.(1) or (2))? Sales Interest in Client Transactions B. Do you or any related person: Yes No (1) as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory ✓ r. client securities are sold to or bought from the brokerage customer (agency cross transactions)? (2) recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for ✓ r. which you or any related person serves as underwriter or general or managing partner? (3) recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than r the receipt of sales commissions as a broker or registered representative of a broker-dealer)? Investment or Brokerage Discretion C. Do you or any related person have discretionary authority to determine the: Yes No (1) securities to be bought or sold for a client's account? r. r (2) amount of securities to be bought or sold for a client's account? r (3) broker or dealer to be used for a purchase or sale of securities for a client's account? ✓ r (4) commission rates to be paid to a broker or dealer for a client's securities transactions? • r D. If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons? ✓ r. E. Do you or any related person recommend brokers or dealers to clients? • r F. If you answer "yes" to E. above, are any of the brokers or dealers related persons? r G. (1) Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party r. r ("soft dollar benefits") in connection with client securities transactions? CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0066173 CONFIDENTIAL SDNY_GM_00212357 EFTA01372464