📄 Extracted Text (565 words)
section 54 of the Investment Company Act of 1940)
r (4) Portfolio management for pooled investment vehicles (other than investment companies)
r (5) Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and
other pooled investment vehicles)
(6) Pension consulting services
1 111111
(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) 0ther(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.
11. If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?
G 0
✓ 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 5.H., do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship
with those investors.
Yes No
I. (1) Do you participate in a wrap fee program? r
(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:
(a) sponsor to a wrap fee program
(b) portfolio manager for a wrap fee program?
(c) sponsor to and portfolio manager for the same wrap fee program?
If you report an amount in Item 5.1.(2)(c), do not report that amount in Item 5.1.(2)(a) or Item 5.L (2)(b).
If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.L (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 Item 5.L(1) or enter any amounts in response to Item 5.I.(2).
Yes No
J. (1) In response to Item 4.8. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of ✓ it
investments?
(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your r
regulatory assets under management?
K. Separately Managed Account Clients
Yes No
(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed r it
account clients)?
If yes, complete Section 5.K.(1) of Schedule D.
(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise? ✓ r
If yes, complete Section 5.K.(2) of Schedule D.
(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise? ✓ r
If yes, complete Section 5.K.(2) of Schedule D.
CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0066061
CONFIDENTIAL SDNY_GM_00212245
EFTA01372367
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