EFTA01078403.pdf

FORM ADV UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS Primary Business Name: RED DOT TRADE FINANCE, LLC CRD Numbe Other-Than-Annual Amendment - All Sections Rev. 10/2012 WARNING: Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You must keep this form updated by filing periodic amendments. See Form ADV General Instruction 4. Item 1 Identifying Information Responses to this Item tell us who you are, where you are doing business, and how we can contact you. A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): RED DOT TRADE FINANCE, LLC B. Name under which you primarily conduct your advisory business, if different from Item S.A.: RED DOT TRADE FINANCE, LLC List on Section 1.5. of Schedule D any additional names under which you conduct your advisory business. C. If this filing is reporting a change in your legal name (Item S.A.) or primary business name (Item 1.B.), enter the new name and specify whether the name change is of r your legal name or r your primary business name: D. (1) If you are registered with the SEC as an investment adviser, your SEC file number: (2) If you report to the SEC as an exempt reporting adviser, your SEC file number: E. If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the LARD system, your CRD number If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates. F. Principal Office and Place of Business (1) Address (do not use a P.O. Box): Number and Street 1: Number and Street 2: City: State: Country: ZIP +4/Postal Code: WESTON Massachusetts UNITED STATES 02493 If this address is a private residence, check this box: I7 List on Section 1.F. of Schedule D any office, other than your principal office and place of business, EFTA01078403  at which you conduct investment advisory business. If you are applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, list the largest five offices in terms of numbers of employees. (2) Days of week that you normally conduct business at your principal office and place of business: Monday - Friday r Other: Normal business hours at this location: 8-5 (3) Tele hone number at this location: (4) Facsimile number at this location: G. Mailing address, if different from your principal office and place of business address: Number and Street 1: Number and Street 2: City: State: Country: ZIP+4/Postal Code: WESTON Massachusetts UNITED STATES 02493 If this address is a private residence, check this box: F H. If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.: Number and Street 1: Number and Street 2: City: State: Country: ZIP+4/Postal Code: Yes No I. Do you have one or more websites? r If "yes," list all website addresses on Section 1.I. of Schedule D. If a website address serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the other information. Some advisers may need to list more than one portal address. Do not provide individual electronic mail (e-mail) addresses in response to this Item. J. Provide the name and contact information of your Chief Compliance Officer: If you are an exempt reporting adviser, you must provide the contact information for your Chief Compliance Officer, if you have one. If not, you must complete Item 1.K. below. Name: Other titles, if any: JOSHUA LEVY PARTNER Telephone number: Facsimile number: Number and Street 1: Number and Street 2: EFTA01078404  86 MYLES STANDISH RD City: State: Country: ZIP+4/Postal Code: WESTON Massachusetts UNITED STATES 02493 Electronic mail (e-mail) address, if Chief Compliance Officer has one: K. Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, you may provide that information here. Name: Telephone number: Facsimile number: Number and Street 1: Number and Street 2: City: State: Country: ZIP+4/Postal Code: Electronic mail (e-mail) address, if contact person has one: Yes No L. Do you maintain some or all of the books and records you are required to keep under r Section 204 of the Advisers Act, or similar state law, somewhere other than your principal office and place of business? If "yes," complete Section 1.L. of Schedule D. Yes No M. Are you registered with a foreign financial regulatory authority? r Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes," complete Section 1.M. of Schedule D. Yes No N. Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange r r. Act of 1934? If "yes," provide your CIK number (Central Index Key number that the SEC assigns to each public reporting company): Yes No O. Did you have $1 billion or more in assets on the last day of your most recent fiscal year? r P. Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. In the first half of 2011, the legal entity identifier standard was still in development. You may not have a legal entity identifier. EFTA01078405 SECTION 1.B. Other Business Names List your other business names and the jurisdictions in which you use them. You must complete a separate Schedule D Section 1.5. for each business name. Name: ATORUS Jurisdictions ❑ AL ❑ ID ❑ MO ❑ PA ❑ AK OIL OMT ❑ PR r AZ ❑ IN ONE O RI F AR ❑ IA ❑ NV ❑ SO CA ❑ KS ❑ NH ❑ SD 1- co ❑ KY CT ❑ LA ❑ NM O-rx • DE r ME ❑ NY OUT • DC ✓ MD ❑ NC • FL F MA ❑ ND E GA ✓ MI 00H OVA • GU E MN ❑ OK ❑ WA ✓ HI ❑ ris ❑ OR O WV ❑ WI ❑ Other: SECTION 1.F. Other Offices No Information Filed SECTION 1.I. Website Addresses No Information Filed SECTION 1.L. Location of Books and Records No Information Filed SECTION 1.M. Registration with Foreign Financial Regulatory Authorities EFTA01078406 No Information Filed EFTA01078407 EFTA01078408 Item 3 Form of Organization A. How are you organized? ✓ Corporation ✓ Sole Proprietorship ✓ Limited Liability Partnership (LLP) r Partnership • Limited Liability Company (LLC) ✓ Limited Partnership (LP) ✓ Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4. B. In what month does your fiscal year end each year? DECEMBER C. Under the laws of what state or country are you organized? State Country Delaware UNITED STATES If you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state or country where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. EFTA01078409 Item 4 Successions Yes No A. Are you, at the time of this filing, succeeding to the business of a registered investment r r. adviser? If "yes", complete Item 4.8. and Section 4 of Schedule D. B. Date of Succession: (MM/DD/YYYY) If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4. SECTION 4 Successions No Information Filed EFTA01078410 Item 5 Information About Your Advisory Business - Employees, Clients, and Compensation Responses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1A Instruction 5.a. provides additional guidance to newly formed advisers for completing this Item 5. Employees If you are organized as a sole proprietorship, include yourself as an employee in your responses to Item S.A. and Items SAW, (2), (3), (4), and (5). If an employee performs more than one function, you should count that employee in each of your responses to Items 5.8.(1), (2), (3), (4), and (5). A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers. 2 B. (1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)? 2 (2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer? 0 (3) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives? 2 (4) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for an investment adviser other than you? 0 (5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency? 0 (6) Approximately how many firms or other persons solicit advisory clients on your behalf? 0 In your response to Item 5.6.(6), do not count any of your employees and count a firm only once - do not count each of the firm's employees that solicit on your behalf. Clients In your responses to Items S.C. and S.D. do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. C. (1) To approximately how many clients did you provide investment advisory services during your most recently completed fiscal year? EFTA01078411  r1-10 r 11-25 r 26-100 r More than 100 If more than 100, how many? (round to the nearest 100) (2) Approximately what percentage of your clients are non-United States persons? 0% D. For purposes of this Item S.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not include businesses organized as sole proprietorships. The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, check "None" in response to Item 5.D.(1)(d) and do not check any of the boxes in response to Item 5.D.(2)(d). (1) What types of clients do you have? Indicate the approximate percentage that each type of client comprises of your total number of clients. If a client fits into more than one category, check all that apply. Unto 11- 26- 51- 76- None 10% 25% 50% 75% 99% 100% (a) Individuals (other than high net worth r r e r r r individuals) (b) High net worth individuals ✓ r r r r r a (c) Banking or thrift institutions r r r r r r (d) Investment companies r. r r r r r r (e) Business development companies r r r r r r (f) Pooled investment vehicles (other than r r r r r r investment companies) (g) Pension and profit sharing plans (but not r. r e r r r r the plan participants) (h) Charitable organizations r. r e r r r r (i) Corporations or other businesses not listed r r r r r r above (j) State or municipal government entities r r r r r r (k) Other investment advisers r r r r r r (I) Insurance companies r r r r r r (m) Other: r r r r r r (2) Indicate the approximate amount of your regulatory assets under management (reported in Item S.F. below) attributable to each of the following type of client. If a client fits into more than one category, check all that apply. EFTA01078412  None UD to UD to UD to >750/0 25% 50% 75% (a) Individuals (other than high net worth individuals) a r r r r (b) High net worth individuals r r r r a (c) Banking or thrift institutions a r r r r (d) Investment companies a r r r r (e) Business development companies C.- r r r r (f) Pooled investment vehicles (other than a r r r r investment companies) (g) Pension and profit sharing plans (but not the r. r r r r plan participants) (h) Charitable organizations a r r r r (i) Corporations or other businesses not listed a r r r r above (j) State or municipal government entities a r r r r (k) Other investment advisers a r r r r (I) Insurance companies a r r r r (m) Other: a r r r r Compensation Arrangements E. You are compensated for your investment advisory services by (check all that apply): Fo (1) A percentage of assets under your management ✓ (2) Hourly charges ✓ (3) Subscription fees (for a newsletter or periodical) ✓ (4) Fixed fees (other than subscription fees) ✓ (5) Commissions P- (6) Performance-based fees ✓ (7) Other (specify): Item 5 Information About Your Advisory Business - Regulatory Assets Under Management Regulatory Assets Under Management Yes No F. (1) Do you provide continuous and regular supervisory or management services to r r. securities portfolios? (2) If yes, what is the amount of your regulatory assets under management and total number of accounts? U.S. Dollar Amount Total Number of Accounts Discretionary: (a) $ (d) Non-Discretionary: (b) $ (e) Total: (c) $ EFTA01078413  Part 1A Instruction 5.b. explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item. Item 5 Information About Your Advisory Business - Advisory Activities Advisory Activities G. What type(s) of advisory services do you provide? Check all that apply. F (1) Financial planning services Ft (2) Portfolio management for individuals and/or small businesses ✓ (3) Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the Investment Company Act of 1940) ✓ (4) Portfolio management for pooled investment vehicles (other than investment companies) ✓ (5) Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles) 1 11 -11 "1-1 (6) Pension consulting services (7) Selection of other advisers (including private fund managers) (8) Publication of periodicals or newsletters (9) Security ratings or pricing services (10) Market timing services (11) Educational seminars/workshops (12) Other(specify): Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advice in Section 5.G.(3) of Schedule D. H. If you provide financial planning services, to how many clients did you provide these services during your last fiscal year? ✓ 1-10 • 11 - 25 ✓ 26 - 50 ✓ 51 - 100 ✓ 101 - 250 ✓ 251 - 500 ✓ More than 500 If more than 500, how many? (round to the nearest 500) In your responses to this Item S.H., do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. EFTA01078414 I. If you participate in a wrap fee program, do you (check all that apply): r (1) sponsor the wrap fee program? r (2) act as a portfolio manager for the wrap fee program? If you are a portfolio manager for a wrap fee program, list the names of the programs and their sponsors in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program, do not check either Item 5.I.(1) or 5.I.(2). Yes No 3. In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide r investment advice only with respect to limited types of investments? SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development Companies No Information Filed SECTION 5.I.(2) Wrap Fee Programs No Information Filed EFTA01078415 Item 6 Other Business Activities In this Item, we request information about your firm's other business activities. A. You are actively engaged in business as a (check all that apply): ✓ (1) broker-dealer (registered or unregistered) ✓ (2) registered representative of a broker-dealer ✓ (3) commodity pool operator or commodity trading advisor (whether registered or exempt from registration) 1 -11-11 -1 -1 -11 -1 -1 (4) futures commission merchant (5) real estate broker, dealer, or agent (6) insurance broker or agent (7) bank (including a separately identifiable department or division of a bank) (8) trust company (9) registered municipal advisor (10) registered security-based swap dealer (11) major security-based swap participant (12) accountant or accounting firm (13) lawyer or law firm (14) other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.8, complete Section 6.A. of Schedule D. Yes No B. (1) Are you actively engaged in any other business not listed in Item 6.A. (other than r giving investment advice)? (2) If yes, is this other business your primary business? r. r If "yes," describe this other business on Section 6.8.(2) of Schedule D, and if you engage in this business under a different name, provide that name. Yes No (3) Do you sell products or provide services other than investment advice to your r advisory clients? If "yes," describe this other business on Section 6.8.(3) of Schedule D, and if you engage in this business under a different name, provide that name. SECTION 6.A. Names of Your Other Businesses No Information Filed SECTION 6.B.(2) Description of Primary Business Describe your primary business (not your investment advisory business): WE PROVIDE BUSINESS CONSULTING SERVICES ON AN OPPORTUNISTIC BASIS. If you engage in that business under a different name, provide that name: EFTA01078416 SECTION 6.B.(3) Description of Other Products and Services Describe other products or services you sell to your dient, You may omit products and services that you listed in Section 6.B.(2) above. If you engage in that business under a different name, provide that name. EFTA01078417 Item 7 Financial Industry Affiliations and Private Fund Reporting In this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you and your clients. A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and any person that is under common control with you. You have a related person that is a (check all that apply): 1 (1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered) (2) other investment adviser (including financial planners) -11111 (3) registered municipal advisor (4) registered security-based swap dealer (5) major security-based swap participant (6) commodity pool operator or commodity trading advisor (whether registered or exempt from registration) 11 -1 - 111- 111 (7) futures commission merchant (8) banking or thrift institution (9) trust company (10) accountant or accounting firm (11) lawyer or law firm (12) insurance company or agency (13) pension consultant (14) real estate broker or dealer (15) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles r (16) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory services you provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related person does not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe that your relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act. 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 D, except in certain circumstances described in the next sentence and in Instruction 6 of the Instructions EFTA01078418  to Part 1A. If another adviser reports this information with respect to any such private fund in Section 7.8.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser), do not complete Section 7.5.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.11(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 7.8.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.A. Financial Industry Affiliations No Information Filed SECTION 7.B.(1) Private Fund Reporting No Information Filed SECTION 7.B.(2) Private Fund Reporting No Information Filed EFTA01078419 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. 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 r clients (principal transactions)? (2) buy or sell for yourself securities (other than shares of mutual funds) that you also r recommend to advisory clients? (3) recommend securities (or other investment products) to advisory clients in which you r or any related person has some other proprietary (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 ✓ r. trades for brokerage customers in which advisory client securities are sold to or bought from the brokerage customer (agency cross transactions)? (2) recommend purchase of securities to advisory clients for which you or any related ✓ r. person serves as underwriter, general or managing partner, or purchaser representative? (3) recommend purchase or sale of securities to advisory clients for which you or any ✓ r. related person has any other sales interest (other than 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 (2) amount of securities to be bought or sold for a client's account? r. 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 • r transactions? 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 r. r than execution from a broker-dealer or a third party ("soft dollar benefits") in EFTA01078420  connection with client securities transactions? (2) If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons r receive eligible "research or brokerage services" under section 28(e) of the Securities Exchange Act of 1934? H. Do you or any related person, directly or indirectly, compensate any person for client r referrals? I. Do you or any related person, directly or indirectly, receive compensation from any person r for client referrals? In responding to Items 8.H and 8.L, consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.fr) or received from (in answering Item 8.0 any person in exchange for client referrals, including any bonus that is based, at least in par₹, on the number or amount of client referrals. EFTA01078421 Item 9 Custody In this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940) assets and about your custodial practices. A. (1) Do you have custody of any advisory clients': Yes No (a) cash or bank accounts? r (b) securities? r r. If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from your clients' accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that you are not operationally independent (pursuant to Advisers Act rule 206(4)-(2)(d)(5)) from the related person. (2) If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody: U.S. Dollar Amount Total Number of Clients (a)$ (b) If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients' accounts, do not include the amount of those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provide to clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that information in your response to Item 9.8.(2). B. (1) In connection with advisory services you provide to clients, do any of your related Yes No persons have custody of any of your advisory clients': (a) cash or bank accounts? r (b) securities? r You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b). (2) If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons have custody: U.S. Dollar Amount Total Number of Clients C. If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply: (1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage. EFTA01078422  (2) An independent public accountant audits annually the pooled investment vehicle(s) r that you manage and the audited financial statements are distributed to the investors in the pools. (3) An independent public accountant conducts an annual surprise examination of client r funds and securities. (4) An independent public accountant prepares an internal control report with respect to r custodial services when you or your related persons are qualified custodians for client funds and securities. If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an internal control report. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect to the private funds you advise in Section 7.8.(1) of Schedule D). D. Do you or your related person(s) act as qualified custodians for your clients in connection Yes No with advisory services you provide to clients? (1) you act as a qualified custodian (2) your related person(s) act as qualified custodian(s) If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)) must be identified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act. E. If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide the date (MM/YYYY) the examination commenced: F. If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act as qualified custodians for your clients in connection with advisory services you provide to clients? SECTION 9.C. Independent Public Accountant No Information Filed EFTA01078423 Item 10 Control Persons In this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C. Yes No A. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, r control your management or policies? If yes, complete Section 10.A. of Schedule D. B. If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934, please complete Section 10.B. of Schedule D. SECTION 10.A. Control Persons No Information Filed SECTION 10.B. Control Person Public Reporting Companies No Information Filed EFTA01078424 Item 11 Disclosure Information In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine whether to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser, and to identify potential problem areas to focus on during our on-site examinations. One event may result in "yes" answers to more than one of the questions below. Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you are a "separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are. If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following the date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years following the date of an event only in responding to Items 11.A.(1), 11.A.(2), 11.8.(1), 11.8.(2), 11.D.(4), and 11.1-1.(1)(a). For purposes of calculating this ten-year period, the date of an event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed. You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11. Yes No Do any of the events below involve you or any of your supervised persons? r For "ves" answers to the following questions, comolete a Criminal Action DRP: A. In the past ten years, have you or any advisory affiliate: Yes No (1) been convicted of or pled guilty or nob contendere ("no contest") in a domestic, r foreign, or military court to any felony? (2) been charged with any felony? r r. If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to charges that are currently pending. B. In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nob contendere ("no contest") in a domestic, r foreign, or military court to a misdemeanor involving: investments or an investment- related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses? (2) been charged with a misdemeanor listed in Item 11.B.(1)? r r. If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.8.(2) to charges that are currently pending. EFTA01078425 For "yes" answers to the following questions, complete a Reaulatory Action DRP: C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: Yes No (1) found you or any advisory affiliate to have made a false statement or omission? r (2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC r regulations or statutes? (3) found you or any advisory affiliate to have been a cause of an investment-related r business having its authorization to do business denied, suspended, revoked, or restricted? (4) entered an order against you or any advisory affiliate in connection with investment- r related activity? (5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any r advisory affiliate to cease and desist from any activity? D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: (1) ever found you or any advisory affiliate to have made a false statement or omission, or r been dishonest, unfair, or unethical? (2) ever found you or any advisory affiliate to have been involved in a violation of r investment-related regulations or statutes? (3) ever found you or any advisory affiliate to have been a cause of an investment-related r business having its authorization to do business denied, suspended, revoked, or restricted? (4) in the past ten years,