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sd-10-EFTA01372366Dept. of JusticeOther

EFTA Document EFTA01372366

attributable to each of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item 5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the

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attributable to each of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item 5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the

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EFTA Disclosure
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attributable to each of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item 5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registered investment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable. Type of Client (1) Number of Client(s) (2) Fewer than 5 Clients (3) Amount of Regulatory Assets under Management (a) Individuals (other than high net worth individuals) r $ (b) High net worth individuals r $ (c) Banking or thrift institutions r $ (d) Investment companies 1 $ 0 (e) Business development companies $ (f) Pooled investment vehicles (other than investment companies and business development companies) $ (g) Pension and profit sharing plans (but not the plan participants or government pension plans) r $ (h) Charitable organizations r $ (i) State or municipal government entities (including government pension plans) r $ (j) Other investment advisers r $ (k) Insurance companies r $ (I) Sovereign wealth funds and foreign official institutions r $ (m) Corporations or other businesses not listed above r $ (n) Other: r Compensation Arrangements E. You are compensated for your investment advisory services by (check all that apply): F r r r r r r (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 (6) Performance-based fees (7) Other (specify): Item 5 Information About Your Advisory Business - Regulatory Assets Under Management Regulatory Assets Under Management F. (1) Do you provide continuous and regular supervisory or management services to securities portfolios? (2) If yes, what is the amount of your regulatory assets under management and total number of accounts? U.S. Dollar Amount Discretionary: (a) $ (d) Non-Discretionary: (b) $ (e) Total: (c) $ (0 Total Number of Accounts Part IA Instruction 5.b. explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item. Yes No C ft (3) What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United States persons? $ 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.  (1) Financial planning services  (2) Portfolio management for individuals and/or small businesses P. (3) Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to CONFIDENTIAL - PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0066060 CONFIDENTIAL SDNY_GM_00212244 EFTA01372366

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