EFTA01358780.pdf

as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold to or bought from the brokerage customer (agency cross transactions)? recommend purchase of securities to advisory clients for which you or any related person serves as underwriter, general or managing partner, or purchaser representative? recommend purchase or sale of securities to advisory clients for which you or any 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. 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 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 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 ("soft dollar benefits") in connection with client securities transactions? (2) If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under • r 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 referrals? r. r I. Do you or any related person, directly or indirectly, receive compensation from any person for client referrals? ✓ r. In responding to Items 8.11 and B.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H) or received from (in answering Item 8.1) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals. 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? (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 (0 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) $ 0 (b) 0 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 9.11(2). B. (1) In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients': Yes No (a) cash or bank accounts? r. 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 9.6.(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: CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0046722 CONFIDENTIAL SDNY_GM_00192906 EFTA01358780