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RECENT SEC REQUEST LISTS (Long Form and Short-Form Request Lists)

LONG-FORM Examination Information Request List


Firm Name: File No. Examination Period Information is requested for the period January 1, 2011 through March 31, 2012 (the "Examination Period") unless otherwise noted. Organizing the Information to be Provided In order to efficiently process the material assembled for the staff's review, please label the information so that it corresponds to the item number in the request list. This list is divided between Part I and Part II, in order to help the Registrant prioritize the collection of data for the staff. The information should be provided in the timeframes indicated at the outset of Part I and Part II, where possible. If information provided is responsive to more than one request item, you may provide it only once and refer to it when responding to the other request item numbers. If any request item does not apply to your business, please indicate N/A (not applicable). PART I: Information to be Provided by April 24, 2012 General Information 1. Advisers organization chart showing ownership percentages of the Adviser and control persons, and a schedule or chart of all affiliated entities. 2. Names of any of the Advisers officers and/or directors who resigned during the Examination Period and information regarding the reason for their departure. 3. List of current employees, partners, officers and/or directors and their respective titles. 4. Any threatened, pending and settled litigation or arbitration involving the Adviser or any supervised person (if it relates to the individuals association with the Advisers or a securities-related matter) including a description of the allegations, the status, and a brief description of any out of court or informal settlement. Note that supervised person is any partner, officer, director (or other person occupying a similar status or performing similar functions), or employee of an investment adviser, or other person who provides investment advice on behalf of the investment adviser and is subject to the supervision and control of the investment adviser (defined in Section 202(a)(25) of the Advisers Act). If none, please provide a written statement to that effect.

5. Current standard client advisory contracts or agreements. 6. All sub-advisory agreements executed with other investment advisers. 7. The Form ADV Part II furnished to clients during the Examination Period and any disclosure document used in conjunction with or in lieu of Part II, except for the Brochure which was available on the firms website as of April 9, 2012. 8. Please provide the staff with a list of all committees, the members of each committee, and the responsibilities of each committee. Information Regarding the Advisers Compliance Program, Risk Management and Internal Controls 9. Compliance policies and procedures that were in effect during the Examination Period for the Adviser and its affiliates. 10. Information relating to the firms compliance testing, including any compliance reviews, quality control analyses, surveillance, and/or forensic or transactional tests performed by the firm. This information should include any significant findings, both positive and negative, of such testing and any information about corrective or remedial actions taken regarding these findings. 11. Names of all fair-valued and any illiquid securities held by clients, a description of any fair value process employed including any testing and results and all fair value reports prepared or reviewed by a valuation committee. 12. A current inventory of the Advisers compliance risks that forms the basis for its policies and procedures, including any changes made to the inventory and the dates of the changes. 13. Any documents maintained that map the Advisers inventory of risks to its written policies and procedures. 14. Any written guidance that the Adviser has provided to its employees regarding its compliance risk assessment process and the process for creating policies and procedures to mitigate and manage compliance risks. 15. Any internal audit review schedules and completed audits including the subject and the date of the report for a three year period. 16. Any client complaints, and information about the process used for monitoring client correspondence and/or complaints, including the name of any third-party service provider used and the Advisers oversight of the service provider. 17. Documentation maintained regarding any reviews conducted of the Advisers policies and procedures, including any annual and/or interim reports.

18. A record of any non-compliance with the Advisers Compliance policies and procedures and of any action taken as a result of such non-compliance. 19. Information about the oversight process the Adviser uses for any remote offices and/or independent advisory contractors, and any policies and procedures with respect to such oversight. Information to Facilitate Testing with Respect to Advisory Trading Activities 20. A trade blotter (i.e., purchases and sales journal) for the examination period that lists transactions (including all trade errors, cancellations, re-bills, and reallocations) in securities and other financial instruments (including privately offered funds) for: current and former clients; proprietary and/or trading accounts and access persons. The preferred format for this information is to provide it in Excel as indicated in Exhibit 1. 21. Provide the information below for all advisory clients, including privately offered funds. The preferred format for this information is in Excel. A. Current advisory clients, indicating those that are wrap clients, including: a. the Account number, name and current balance, as of March 31, 2012; b. whether the client is a related person, affiliated person, or a proprietary account; c. the type of account (e.g., individual, defined benefit retirement plan, registered fund, or unregistered fund); d. the account custodian and location; e. whether or not the custodian sends periodic account statements directly to the client; whether or not the delivery is electronic, if so, a copy of the authorization; and the form of electronic delivery (e.g., email or website login); f. whether or not the Adviser has discretionary authority; g. whether the Adviser, an officer, an employee, or an affiliate acts as trustee, cotrustee, or successor trustee or has full power of attorney for the account; h. whether Adviser or related persons are deemed to have custody of, possession of or access to the clients assets, and if so, the location of the assets; i. the investment strategy (e.g., global equity, high-yield, aggressive growth, longshort, or statistical arbitrage) and the performance composite in which it is included, if any; j. the Account portfolio manager(s); k. whether client has a directed brokerage arrangement, including commission recapture (provide the name of broker(s), details of the arrangement and any reports used to monitor payments of commissions); l. the value of each client's account that was used for purposes of calculating its advisory fee for the most recent billing period; m. whether the client pays a performance fee and the most recent account performance figures;

n. whether or not advisory fees are paid directly from the clients custodial account; and o. for clients obtained during the Examination Period, provide account inception date and name(s) of consultant(s) related to obtaining the client, if any. B. Names of advisory clients lost, including the reason, termination date and asset value at termination. C. Names of any financial planning, pension consulting or other advisory clients not named in response to section A above. Portfolio Management 22. Names of securities held in all client portfolios (aggregate position totals for all instruments) as of March 31, 2012. This record should include the security name, name of each client holding an interest, the amount owned by each client, the aggregate number of shares or principal and/or notional amount held and total market value of the position. The preferred format for this information is in Excel. 23. For each Fund, portfolio, or client account managed by the Adviser during the Examination Period, provide monthly performance returns of each Fund/portfolio/client from January 1, 2011 to March 31, 2012, as well as the returns for the accounts comparable indices or benchmarks. In addition, with respect to the Funds managed by the Adviser, please provide the monthly or quarterly returns for the Funds peer group or category. If possible, provide this information electronically. Brokerage Arrangements 24. All affiliated broker-dealers including a description of the affiliation and of their clearing arrangements. 25. List of all principal transactions that took place during the examination period between current or former clients and/or proprietary or affiliated accounts. Please identify the security, number of shares, price, total dollar value, the client accounts and the reason for the principal transactions. 26. List all cross transactions that took place during the examination period between current or former clients and/or proprietary or affiliated accounts. Please identify the security, number of shares, execution price, pricing sources, total dollar value, the client accounts and the reason for the crosses. 27. Any restricted, watch or grey lists that were in effect for the examination period. 28. Soft dollar budget or similar document that describes the products and services the Adviser obtains using clients brokerage commissions.

29. Commission-sharing arrangements including the name of the broker-dealer and total dollars allocated to each arrangement during the preceding 12 months. Conflicts of Interest and/or Insider Trading 30. The Advisers and affiliates Code of Ethics and insider trading policies and procedures. 31. Any fee splitting or revenue sharing arrangements. Performance Advertising and/or Marketing 32. All pitch books, one-on-one presentations, pamphlets, brochures, and any other promotional and/or marketing materials furnished to existing and/or prospective clients for each investment strategy and/or mandate. 33. All advertisements used to inform or solicit clients. If information on services and investments is available on the Internet, such as websites and blogs, make all versions available as either printouts or electronic archives. Financial Records 34. Advisers balance sheet, trial balance, general ledger, cash receipts and disbursements journal, income statement, and cash flow statements as of the end of its most recent fiscal year and the most current year to date. 35. Any budgets prepared by management, with detail of compliance expenditures, as of the end of the most recent fiscal year and the most current year-to-date. 36. Any loans from clients, including promissory notes, to the Adviser, or sales of the Advisers or any affiliates stock to clients. Custody 37. Please request that the Custodian(s) provide an acknowledgement that it sends account statements directly to clients (rather than solely to the Adviser) at least quarterly and provide the names of these clients (if this is an accurate statement). The Custodian should send the acknowledgment directly to: U.S. Securities and Exchange Commission Attention: 38. For each client account, provide the name, account number, address, and contact information (e.g., contact name, mailing address, phone number and e-mail address), for the entities that maintained custody of the cash/securities of each clients account during the Examination Period. For any securities that were not maintained with a qualified custodian, please include a description of the security, security name, location of the security, and the 6

name of the clients who held such securities. For purposes of this request, you may exclude any assets held pursuant to a derivative or swap contract. Such information, if applicable, may be requested later. The staff may request that the custodian(s) specific client accounts provide the staff directly with a confirmation of all positions, including cash, short positions, and loans, held as of particular dates. Advisers Sponsoring or Managing Privately Offered Funds 39. For each private fund please provide the organization document and operating agreement (e.g., partnership agreement, private placement memoranda). 40. Names of current investors including total value of each investors equity interest in the fund as of March 31, 2012. 41. For each private fund please provide the financials, audited or unaudited, for its most recent fiscal year end. Advisers to Registered Investment Companies (RIC) RIC: General Information 42. A chart listing all Funds and the following information as of March 31, 2012 for each fund:
a. b. c. d. e. Registration number Net assets Total shares outstanding Maximum sales load Investment objective f. g. h. i. Number of shareholder accounts Name of portfolio manager(s) Commencement date of operations Portfolio turnover rate for last 2 years

43. A list of threatened, pending and settled litigation or arbitration to which the Fund was a party
during the inspection period. Provide a description of the allegations forming the basis for each issue, the status of each pending issue, and a brief description of any out of court or informal settlement. If none, please provide a written statement to that effect.

44. Any no-action letters or exemptive orders relied upon by the Fund. RIC: Compliance Policies and Procedures 45. The Fund's policies and procedures adopted pursuant to the Compliance Rule. 46. The annual report submitted to the Board by the CCO.
47. A current inventory of compliance risks. If changes were made to this inventory of risks during the inspection period, please indicate what these changes were and the corresponding date of the change. Please provide this information, if possible, in Word, Excel or the equivalent format.

RIC: Senior Securities 48. Please provide copies of any internal reports created and maintained as of March 31, 2012 that reflects the amount of exposure by securities product i.e., credit default swaps, total return swaps, etc. In addition, please also provide a report that demonstrates the securities that were segregated to cover any potential exposures created. RIC: Mutual Fund Financial Analysis 49. For each Fund, information about NAV errors of 1 cent or more per share, as well as those that were % or more of the NAV at any time the error was outstanding. 50. If any Fund or shareholder received compensation as a result of NAV/Pricing errors, provide information describing the compensation. RIC: Fund Corporate Governance The information below is requested in order to review the role and oversight of the Board of Directors/Trustees (Board) and Committees 51. Boards annual calendar reflecting proposed approvals. 52. Minutes of Board meetings for the 15-month period ended March 31, 2012, meeting agenda for each meeting and, the agenda and a draft of the minutes for the most recent Board meeting. 53. Minutes of any meetings held by the independent directors/trustees. 54. All Board committees and their members; and all committee minutes, if applicable (e.g., Audit Committee, Compliance Committee, etc.) for the 15-month period ended March 31, 2012. 55. Name of directors/trustees who either resigned or were terminated during the Examination Period and the reason for their departure. 56. The most recent annual self-assessment by the Board and Committees, if written. RIC: Market-Timing and Late Trading 57. Please provide a record of trading activity by access persons in Funds managed by the Adviser.

RIC: Conflicts of Interest/Insider Trading 58. The Funds and affiliates Code of Ethics and insider trading policies and those of participating affiliates, and a list of all access persons, including contract employees, required to report transactions. 59. If not stated in the Code, information about the process used to monitor and control the receipt, flow and use of non-public information, including any restricted, watch or grey lists. 60. If separate from the Funds Code of Ethics, a copy of its policy governing receipt by officers and employees of gifts and entertainment. PART II: Information to be Provided by April 30, 2012 (upon arrival) General Information 61. Names of employees who were disciplined and/or terminated during the Examination Period and information regarding the reason for the action. 62. Identify any employees of the Adviser that resigned or were terminated that filed or stated complaints against the firm or its employees, alleging potential violations of securities laws as the cause for the resignation or termination. 63. Current fee schedule(s), if not otherwise stated in advisory contracts or in Form ADV Part II. 64. Names of any joint ventures or any other businesses in which the Adviser or any officer, director, portfolio manager, or trader participates or has any interest (other than their employment with the Adviser), including a description of each relationship. 65. The names and location of all service providers and the services they perform and for both affiliated and unaffiliated providers, information about the due diligence process to initially evaluate and monitor thereafter the work provided and how potential conflicts and information flow issues are addressed. 66. Any power of attorney obtained from clients, if not otherwise stated in advisory contracts. Information Regarding the Advisers Compliance Program, Risk Management and Internal Controls 67. Names of all pricing services, quotation services, and externally-acquired portfolio accounting systems used in the valuation process and information about whether they are paid in hard or soft-dollars, or a combination.

68. A list of securities for which the price provided by a pricing service was overridden by the
Adviser, sub-adviser, or Board of Directors and the date of such override.

Portfolio Management 69. Describe the process used for cross trading between advised or affiliated accounts. Include a description of any changes to the process during the Examination Period. For the purposes of this response, cross trades are defined as transactions involving the transfer of a holding from one account to another account managed by the Adviser or managed by an affiliated person. 70. Names of any publicly traded companies for which employees of the Adviser or its affiliates serve as officers and/or directors, and the name(s) of such employees. 71. Names of companies for which employees of the Adviser or its affiliates, serve on creditors committees, and the name(s) of such employees. 72. The Advisers ten most profitable and ten least profitable (including unrealized gain or loss) investment decisions based on total return of positions opened and closed for each investment strategy or mandate offered to clients. Please include the purchase date, sale date, percentage of gain and/or loss, and dollar amount of the gain and/or loss. 73. Please provide a list of all securities for which the Adviser or its related persons made 13F, 13D and/or 13G filings for the relevant reporting dates with corresponding ownership percentages. In addition, please provide all 13D, 13F, and 13G filings made pursuant to Section 13 of the Securities Exchange Act of 1934 (the Exchange Act), preferably in an electronic format, by the Adviser or its related persons during the Examination Period. Brokerage Arrangements 74. Securities in which the Adviser or an affiliate was a market maker. 75. Securities purchased for any client in which the Adviser or an affiliate underwrote or participated as underwriting manager, purchase group and/or syndicate or selling group and the underwriting date(s). 76. Any documents created in the evaluation of brokerage arrangements and best execution. 77. Policies and procedures with respect to trade errors and information related to any errors. Trade Allocations 78. All initial public offerings and secondary offerings in which clients, proprietary accounts or access persons participated and, if not stated in policies and procedures or if the allocation did not follow standard policies and procedures, information regarding how allocation decisions were made. Include the trade date, security, symbol, total number of shares, and 10

participating accounts. For initial public offerings, indicate whether shares traded at a premium when secondary market trading began. The preferred format for this information is in Excel. Conflicts of Interest and/or Insider Trading 79. If not stated in policies and procedures, information about the process used to monitor and control the receipt, flow and use of non-public information, including any restricted, watch or grey lists. Performance Advertising and/or Marketing 80. All performance return composites including: description and investment objective, inception date, account minimum and whether or not it is used in marketing. 81. All accounts included in each composite as of March 31, 2012 and the dates each such client was initially included in each composite. 82. All accounts not included in a composite. 83. All terminated composites. 84. For each investment strategy, please provide the annualized performance returns of each client account and proprietary accounts during the period January 1, 2011 through March 31, 2012. Also include non-annualized quarterly performance returns for each quarter from January 1, 2011 through March 31, 2012. Please provide this information for each account separated by strategy. Additionally, please provide any performance dispersion analysis performed for accounts in similar strategies. If possible, provide this information electronically. 85. All requests for proposals (RFPs) and due diligence questionnaires (DDQs) completed. Advisers Sponsoring or Managing Privately Offered Funds 86. Information regarding each private investment fund, including: A. Name as shown in organizational documents (as amended). B. Domicile (country). C. Investment strategy (e.g., long-short, statistical arbitrage, fund of funds). D. If funds are part of a master/feeder fund structure, full name and domicile of each fund. E. Number of investors and total assets at the end of the Examination Period. F. Amount, if any, of Advisers equity interest in each fund as of March 31, 2012. G. Amount, if any, of Advisers affiliated persons interest as of March 31, 2012. H. Date the fund began accepting unaffiliated investors. I. Whether the fund is currently closed to new investors. J. Lock-up periods for both initial and subsequent investments.

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K. Specific exemption(s) from registration under the Securities Act of 1933 and/or the Investment Company Act of 1940 upon which each fund relies. L. Services the Adviser or an affiliate (e.g., general partner, adviser, managing member) is providing. M. Amount of leverage, both explicit (on-balance sheet) and off-balance sheet (futures and certain other derivatives), used by the fund as of March 31, 2012 as measured by the Adviser for risk-management purposes. Advisers to Registered Investment Companies RIC: General Information 87. Any correspondence with the staff of the Commission or other regulatory agencies. RIC: Mutual Fund Financial Analysis 88. For each Fund, provide the portfolio turnover rates for the years ending December 31, 2011. RIC: Senior Securities 89. Please provide a description of how the following investment strategies and products are
monitored for compliance: Short Sales, Futures, Options, and other derivatives including swaps, borrowings, and other forms of leverage.

90. A list of all senior securities issued or sold and all on-balance-sheet borrowings made by the
fund, including any shorts in ETFs. Please include information regarding the percentage of and arrangements for asset coverage for all borrowings.

RIC: Compliance Policies and Procedures 91. A copy of the minutes of any risk committee meetings that were held during the Examination
Period. Please note that advisers and funds are not required to have a risk committee.

RIC: Fund Corporate Governance 92. Identify any relationships that the Fund or any affiliate may have with any service provider,
including any custodian, transfer agent, administrator, pricing service, accountant or other service provider, and provide documents indicating that these relationships were disclosed to the Funds Board in connection with its review of the contract with the service provider or otherwise. This would include, for example, whether a broker-dealer affiliate has an investment banking relationship with a service provider; whether the Funds adviser manages the corporate pension plan of a service provider; whether the Fund or its adviser has investments in the service provider; whether the service provider also provides services to the Funds adviser or an affiliate, etc.

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93. Information regarding any compensation, whether direct or indirect, received by the Funds
adviser from any of the Funds service providers. Please include copies of information provided to the Board regarding this compensation.

94. Information about each claim made by the Fund or an affiliate under D&O/E&O insurance policies owned by a Fund. RIC: Market-Timing and Late Trading 95. If not already incorporated in the Codes, describe the process for monitoring employees trading in Fund shares and compliance violations found during the Examination Period, if any. 96. Provide information about any instances during the Examination Period when Policies and Procedures Regarding Shareholder Transactions may be/have been overridden; the circumstances under which they were/may be overridden, and the persons who are authorized to or did override them. Advisers Who Are Managers of Manager 97. If not covered in other items requested, provide the staff with information about all business activities between the Adviser and/or its affiliates and any sub-advisers and/or their affiliates (Sub-Advisers) recommended by the Adviser to manage client portfolios. Business activities include but are not limited to, securities lending, client referrals, principal trades, etc. Names of all Sub-Advisers recommended by the Adviser that effect securities transactions or conduct any other types of business with the Advisers affiliated broker-dealer. Provide relevant information if any of the underlying Sub-Advisers utilize the Advisers affiliated broker-dealer, if applicable, to effect transactions or conduct any other types of business with the affiliated broker-dealer.

98. 99.

100. Identify all underlying managers registered with the SEC.

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EXHIBIT 1 Layout and Instructions for Securities Trading Blotter/Purchase and Sales Journal In conjunction with the scheduled examination, the staff requests records for all purchases and sales of securities for portfolios of advisory clients and proprietary accounts being advised by Registrant. This record should include the fields of information listed in the table below. We recommend that someone from your Information Technology group contact the examination team to discuss the availability of data and formatting prior to compiling the data requested. If the data request exceeds 5 million lines of data, please contact the examination team to discuss alternative methods to respond to the request. The staff may request that certain transaction types related to the trade blotter be excluded to reduce the size of the file (e.g., dividends, dividend reinvestments, capital gains reinvestments, and other similar transactions). If possible, produce the dataset in a delimited flat file format (delimited text). Otherwise use a Microsoft Access, Microsoft Excel, or .csv (comma delimited) format. For each Data Field Name requested below, ensure your response file has the same matching Data Field Name. If the data provided does not match exactly to the data fields listed, or if the fields provided are spread over different data files, please provide a translation mapping document that shows how the data fields are mapped. Display a single transaction as one line of data. Do not split large datasets into multiple Excel worksheets, and do not include any special characters (&,"-", etc.) in non-text fields. Please ensure that the client account numbers in the client list (see request item IV.B.) match those in this trade blotter. If you are unable to comply, provide a translation table that will enable the staff to link the information in both files.
Data Field Name Account Name Account Number Accrued Interest Broker Dealer Code Broker Dealer Name Broker Dealer Number Cost Coupon Current Par Amount CUSIP Factor Gross Amount Data Field Short Description Name of account holder's account. Identifier or Number, which can include letters, assigned to identify an account. Interest accrued at the point of executed trade. The 4 letter OTC Symbol designating the broker that executed the trade. A firm may have multiple OTC Symbols designating different trading areas of the firm. The name of the broker dealer. The 4 character alphanumeric Clearing Number designating the broker that executed the trade. A firm may have multiple Clearing Numbers designating different trading areas of the firm. The original purchase cost of the instrument that is being sold or resold to a client (as in a principal trade, for example). Bond coupon at point of execution of the trade. Par amount is synonymous with face amount; amortizing securities, like mortgages, further define par amount according to original or current amount. Security identification number for the U.S. and Canada. The Committee on Identification Procedures number. The quotient of the current balance divided by the original balance. The principal/proceeds/notional value of a given transaction (typically equals quantity multiplied by price). Data Field Format Text Text Number Text Text Text Number Number Number Text Number Number

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Data Field Name ISIN Number Maturity Date Net Amount Original Face Amount Portfolio Manager Price Quantity Registered Representative Name Registered Representative Number Security Description 1 Security Description 2 Security Type Security/Ticker Symbol Sedol Settlement Date Total Commission Total Concession Total Markup Trade Date Trade Execution Time Trade Notes Traded Currency Trader Information 1 Trader information 2 Trading Fees Transaction Number Transaction Type

Data Field Short Description A twelve-character number assigned to a security by the local national numbering agency; the International Securities Identification. Bond Maturity date. Amount remaining after a deduction (i.e. commissions, exchange fees, etc.) from the transaction's gross amount. The security's original face amount and/or value. Indicates the individual/individuals responsible for managing the account. Executed price of a traded security. Number of units/shares of Financial Instruments Bought/Sold or held. Registered representative or trader's name. Number or ID associated with the RR. Full description of financial instrument; usually includes name of issuer and/or description of purpose. Additional description of financial instrument (e.g., for fixed income securities, this would typically include coupon, maturity, etc.). Indicates the type of security (e.g., equity, fixed income, etc.). A system of letters used to uniquely identify a stock or mutual fund A seven character alphanumeric code that is assigned to all securities trading on the London Exchange and other small exchanges in the United Kingdom. The date by which a buyer must pay for an executed security trade and the securities must be delivered by the seller. Total Commission listed in dollars ($). Total Concession listed in dollars ($). Registrant's mark up on the transaction in dollars. Date trade was executed. Time stamp of trade execution (milli or nano seconds). Information on special circumstances related to a particular trade. Currency in which the security is executed. Name/ID of the trader at the adviser placing the trade. Name/ID of the trader at the adviser placing the trade. All fees assessed related to a transaction. Firm or broker transaction number. Indicates trade transaction type (i.e. buy, sell, long, short, cover, cancel, rebook etc.).

Data Field Format Text Date Number Number Text Number Number Text Text Text Text Text Text Text Date Number Number Number Date Time Stamp Text Text Text Text Number Text Text

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SHORT-FORM

Examination Information Request List


Firm Name: File No.
The purpose of this letter is to inform you that the staff of the U.S. Securities and Exchange Commission is conducting a limited scope examination of risk factors present at your firm pursuant to Section 204 of the Investment Advisers Act of 1940 (the Advisers Act). As part of our process, we request that you provide us with the following items within two business days of your receipt of this letter. 1. The Advisers current organization chart showing ownership percentages of the Adviser, the names of officers or control persons, and a schedule or chart of all affiliated entities. Please indicate any changes in ownership that occurred in the twelve months prior to the date of this letter. 2. A list of the names of both the Advisers current employees and all employees terminated within the last 12 months, including reason for termination. Please include on this list each employees name, title, and areas of responsibility. 3. A copy of the Compliance Manual. 4. A copy of any current standard client advisory contracts or agreements used by the Adviser. 5. A copy of the Advisers financial statements (at a minimum balance sheet and income statement) as of the end of its most recent fiscal year, and also for the most recent quarter. The Advisers financial statements need not be audited but should be complete and accurate. 6. Assets under management and number of clients in each category as of April 30, 2012: Discretionary; Non-discretionary; Investment companies; Hedge funds; Other private funds; and Wrap fee programs; 7. The Advisers trade blotter (i.e., purchases and sales journal) that lists transactions (including all trade errors, cancellations, re-bills, and reallocations) in securities and other financial instruments (including privately offered funds) for the three months ended April 30, 2012. This information should be for all current and former clients; proprietary and/or trading accounts and access persons. 8. A list of any pooled investment vehicles managed by the Adviser. The list should include the following for each vehicle: Date the fund was organized; Total amount invested as of April 30, 2012;

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Number of investors; Whether the fund is audited; The name of the funds auditor or accountant; The name of the funds administrator; The name of the general partner or managing member; The name of the custodian; How often the NAV is calculated (monthly, quarterly, etc.); and Whether any holdings are fair valued. 9. If applicable, for the three month period ended April 30, 2012, copies of promotional brochures, pamphlets, or other materials routinely furnished to prospective clients for separate accounts or for investors in any pooled investment vehicles managed by the Adviser. 10. Provide the information below for all advisory clients as of April 30, 2012. The preferred format for this information is in Excel. the name and current balance; whether the client is a related person, affiliated person, or a proprietary account; the type of account (e.g., individual, defined benefit retirement plan, registered fund, or unregistered fund); the account custodian and location; whether or not the custodian sends periodic account statements directly to the client; whether or not the delivery is electronic, if so, a copy of the authorization; and the form of electronic delivery (e.g., email or website login); whether or not the Adviser has discretionary authority; whether the Adviser, an officer, or an affiliate acts as trustee, co-trustee, or successor trustee or has full power of attorney for the account; and whether Adviser or related persons are deemed to have custody of, possession of or access to the clients assets, and if so, the location of the assets. After reviewing the items provided, an examiner from our office may contact you to clarify our understanding of the information provided. Please be advised that if further on-site examination is required, you will be contacted by an examiner from our office. The examiner will let you know the date we anticipate the on-site examination will begin, will ask you for additional information about the Adviser, and will make a request for documents we would like the Adviser to provide us during the on-site portion of our examination. If you have any questions regarding the examination or requested items, please contact the undersigned at [ ]. Your cooperation in this matter is appreciated. Sincerely, Enclosures: Form 1661 Form 2389: Exam Brochure

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