EFTA Document EFTA01451892

SOF III - 1081 Southern Financial LLC The Onshore Feeder Fund may also elect to be treated as an "electing investment partnership" ("RIP") if it is eligible to do so and, as a result, avoid making section 754 adjustments that otherwise would be mandatory with respect to certain transfers. If the Onshore Feeder Fund elects to be treated as an EIP, special partner-level loss limitation rules apply. In general, under these rules, a transferee Investor's distributive share of losses from the s