Bank of America Merrill Lynch Hedge Fund Consulting

Bank of America Merrill Lynch Hedge Fund Consulting

Overview of the Form PF Service Provider Landscape

Revised November 2012

All information provided herein is for discussion purposes only, and is

not intended to be nor should it be construed or used as investment,

tax or legal advice. All recipients should consult with their legal counsel,

tax, financial and other advisors with respect to any information provided

herein. Given the continuously evolving nature of the new regulations,

hedge fund managers should be following the situation closely.

As a result of the Dodd-Frank Act, the SEC has created a new regulatory

filing for registered investment advisors to hedge funds and other private

funds: Form PF. With the data reported on Form PF, the SEC is gathering

information to more actively monitor and track systemic risk across the

private fund industry. Completing a Form PF filing can be a daunting task,

especially for managers with minimal staff. As a result, a niche industry

is rapidly emerging within the hedge fund service provider community

to provide assistance. The purpose of this paper is to provide an overview

of the Form PF service providers and their offerings, as of the date of this

publication (September, 2012). This is the third iteration of this survey.

Given the rapidity of development, we will be publishing updates periodically.

1Overview of the Form PF Service Provider Landscape

Form PF represents the most significant regulatory requirement imposed to date on private fund advisors.

Completing it requires an extensive data aggregation, normalization and reporting exercise for most

managers. Requiring some 2,000 individual data points, the manager must identify and disclose information

on a wide range of topics. The scope and frequency of filing, as well as specific sections, is dependent

on the type and amount of an investment advisor’s Regulatory Assets Under Management (RAUM).1

Calculating RAUM is a new requirement and critical to properly understanding your filing obligations.

Please consult your legal counsel to ensure all relevant assets are included in your calculation.

Regulatory AUM Threshold

Type of Fund

Filing Frequency

Due Date

Effective Date Required Sections

1 2* 3 4

$150M All Annual120 days after fiscal year end

Q4 2012 l

$1B Liquidity Fund Quarterly15 days after quarter end

Q4 2012 l l l

$1.5B Hedge Fund Quarterly60 days after quarter end

Q4 2012 l l

$5B Hedge Fund Quarterly60 days after quarter end

Q2 2012 l lInitial Filing Completed

$2B Private Equity Annual120 days after fiscal year end

Q4 2012 l l l

Examples of Key Data Elements By Form PF Section

Section 1

• Regulatory AUM, gross and net asset value, and breakdown of managed accounts

• Sources and levels of borrowing/leverage

• Liability on Level 1/2/3 assets

• Ownership and investor details

Section 2

• Usage of OTC and centrally cleared derivatives

• Exposure and monthly turnover by asset class

• Counterparties and posted collateral

• Risk metrics

Section 3

• Side pocket and investor gate info

• Investor liquidity

• Portfolio liquidity by asset class

Section 4

• Applicable only to private equity funds, and therefore out of scope of this document

1 Regulatory AUM includes gross assets in co-mingled funds, managed accounts, borrowings for trading leverage, and other items. For details on calculating regulatory AUM, consult the SEC’s website on Form PF (http://sec.gov/rules/final/2011/ia-3308-Form PF.pdf) and the Release of Final Rules on Form PF (http://sec.gov/rules/final/2011/ia-3308.pdf)

2 November 2012

Key Observations from the First Filing

The first round of Form PF filers (those with $5b+ in RAUM) completed their initial filings on August 29,

2012. Some key observations from the experiences of these firms include:

• A number of $5b+ managers produced their initial PF filing manually,

but plan to systematize the process for subsequent filings

• Prior to the initial filing, the SEC released two rounds of FAQs.2 The SEC

may issue further guidance prior to the next filing deadline.

• The SEC has instructed managers to utilize Question 4 in the form to elaborate

on any assumptions made when answering specific questions3

As these firms are required to file quarterly, they must now begin preparing their Q3 filing

(due November 29, 2012). Additionally, managers with $1.5b+ in RAUM are beginning

to prepare for their initial filing (due March 1, 2013).

Where Is the Data?

The necessary data to complete Form PF is spread across fund administrators, prime brokers,

counterparties, and a manager’s internal systems.

Fund Administrators: Most advisers work with a third-party fund administrator to maintain their official

books and records. As a result, it is advisable to source as much data as possible from the fund

administrator. A fund administrator may have a substantial majority of the necessary data including:

• Portfolio holding

• Position detail and trade activity

• Counterparty exposure

• Pricing/valuation data

• Investor data from the shareholder registry

In addition, some fund administrators may calculate or be able to provide risk data as well.

Prime Brokers/Swap Counterparties: A fund’s prime brokers and swap counterparties can be

the source of data on:

• Borrowings and unencumbered cash

• Financing terms

• Mark-to-market counterparty exposure

• Trading and clearing activity

• Asset rehypothecation

• Collateral posted

2 http://www.sec.gov/divisions/investment/pfrd/pfrdfaq.shtml 3 SEC Form PF Frequently Asked Questions – A4.1, http://www.sec.gov/divisions/investment/pfrd/pfrdfaq.shtml


Internal Systems: Depending on the sophistication of a fund advisor and the complexity

of the funds managed, risk calculations and aggregated data may be sourced from internally

operated and maintained systems. Typical source systems include:

• Risk management systems

• Portfolio management systems

• Data warehouses

Key Drivers of Complexity

Form PF represents a new type of regulatory filing in that it reports activity at the investment

manager level rather than the individual fund level. Since an investment manager may advise

multiple funds or private pools of capital, the data must be normalized and aggregated across

a wide range of disparate sources. Factors that impact the complexity of this exercise include:

• Number of funds and/or separately managed accounts

• Number of prime brokers (per fund or managed account)

• Number of administrators

• Asset classes traded by each fund

Creating a Form PF Filing Program

As Form PF will need to be filed quarterly or annually, depending on a fund manager’s size and type,

it is advisable to develop a defined and repeatable process. Although the time and effort required

will be driven by complexity, most managers should benefit from the following steps:

1. Identify Reportable Entities and Data Sources: Take inventory of all funds and separately

managed accounts advised by the manager. Note all prime brokers, counter-parties and fund

administrators used. Also, meet with legal counsel to review and understand the applicable

level of Form PF reporting requirements.

2. Data Gap Analysis: Before answering any of the Form PF questions, it will be necessary to review

each one and determine the specific source data necessary to derive the answer. This step will be

most onerous during the initial filing. However, it should also be conducted at the start of each filing

period to capture any new requirements or data sources.

3. Data Collection and Normalization: Once the specific source data has been identified, it will

need to be collected into a central repository. The data from disparate sources will then need to be

normalized for consistency across the entire data set. The SEC has also created a new classification

scheme for data to be used in Form PF. Categories including strategy, country, asset type, and region

have specific options. This classification scheme will likely be different from what the investment

manager uses internally, so an extra mapping step may be necessary.

4 November 2012

4. Data Aggregation and Form Population: With the data collected and normalized across reporting

entities, it is then possible to aggregate into the composite values requested by the form and

answering specific questions. This step may also involve performing risk calculations such

as VaR and historical scenarios. Best practices in this step include an audit trail that captures

inputs and decisions made in the normalization process, as it could be important to provide

clarification to investors or the SEC at some point in the future.

5. Test Run(s): Creating a “test filing” prior to final submission will pinpoint the questions/sections

where source data has not been completely captured or normalized. Repeat steps 2 – 5 as often

as necessary until each question has been answered satisfactorily.

6. Submit and Archive the Filing: Form PF must be submitted electronically to FINRA’s PFRD (Private

Fund Reporting Depository). Once submitted, the filing should be archived internally, as subsequent

filings will require explanations on values that have changed between filing periods.

7. Update Disaster Recovery/Business Continuity Plan: Once the initial filing has been completed,

it is important to ensure the investment manager’s disaster recovery/business continuity plan is

updated to include the Form PF filing process.

Indicative project plan for quarterly filers:

Once the initial filing has been completed, it is important to ensure the investment manager’s

disaster recovery/business continuity plan is updated to include the Form PF filing process.

1. Identify Reportable Entities and Data Sources

2. Data Gap Analysis

3. Data Collection and Normalization

1. Identify Reportable Entities and Data Sources

Jan. 2013 Feb. 2013 Mar. 2013 Apr. 2013

Jun. 2012 Jul. 2012 Aug. 2012 Sept. 2012 Oct. 2012 Nov. 2012 Dec. 2012 Jan. 2013 Feb. 2013

6. Submit and Archive the Filing

7. Update Disaster Recovery/Business Continuity Plan

6. Submit and Archive the Filing

3. Data Collection and Normalization

2. Data Gap Analysis

4. Data Aggregation and Form Population

4. Data Aggregation and Form Population

5. Test Runs

5. Test Runs

7. Update Disaster Recovery/Business Continuity Plan

Indicative project plan for annual filers:


Who Can Help With Filing Form PF?

Prior to the initial August 2012 filing, many service providers rolled out offerings to assist their

private investment manager clients. The participants and offerings in this segment continue

to evolve rapidly, but they can generally be grouped into 3 categories:

Fund Administrators

Form PF offerings from fund administrators come in two flavors:

• Full Service: The “full service” fund administration Form PF offering will

take data the administrator already has, combine it with additional data

provided by the manager and other external sources, perform the aggregation,

normalization, and calculation steps, and submit the completed filing.

• Extract Only: Alternatively, many fund administrators are choosing to provide

only an extract of the data they have to their client. This extract can be

combined with internal data or handed off to an external provider

(e.g. third-party technology firm or data aggregator) to complete the filing.

Technology Firms and Data Aggregators

Many software firms catering to hedge funds have expanded their products to address

the requirements of Form PF. Again, the technology offerings fall into 2 categories:

• Data Aggregation Tools: Data aggregation tools typically take the form of a data

warehouse which stores the relevant source data (trades, positions, prices,

security information, classification categories, etc.) for each fund over time.

• Workflow Tools: Workflow tools provide a project management context around the

compiling of source data and answering each question in the form. These tools

allow specific questions or sections to be assigned to individuals, track completion

progress, and maintain an audit trail with supporting detail behind each answer.

Consulting Firms

Several consulting firms are now prepared to assist managers in creating a repeatable process

for completing and filing Form PF. These projects will include the initial analysis to determine

where each input can be sourced from, normalizing the data across the various sources, and

establishing the steps for using the data to answer each question. Some consulting firms offer

their own software-based workflow tools to help clients manage the process. Others have formed

partnerships with technology firms/data aggregators. Consulting firms active in this space range

from the traditional “Big 4” management consulting firms to boutiques that specialize in working

with alternative investment managers.

It is important to have a method for maintaining an audit trail

and track the inputs and decisions that are used in each answer.

6 November 2012

Case Studies

As illustrative examples, below are three case studies on fund managers of varying complexity and considerations.

Simple Medium Complexity High Complexity

Commingled Funds

Number of Funds and/or Strategies

2 2 3

AUM (millions) $100 $250 $1,000

Managed Accounts

Number of Accounts 0 1 5

AUM (millions) $ – $50 $150

Regulatory AUM (millions)

Long Market Value – Commingled Funds

$200 $500 $2,000

Short Market Value – Commingled Funds

$200 $500 $2,000

Borrow For Leverage – Commingled Funds

$100 $250 $1,000

Long Market Value – Managed Accounts

$ – $100 $300

Short Market Value – Managed Accounts

$ – $100 $300

Borrow For Leverage – Managed Accounts

$ – $50 $150

Total $500 $1,500 $5,750

Number of Prime Brokers 2 3 3

Number of Fund Administrators

1 2 3

Filing Requirements

Filing Frequency Annually Quarterly Quarterly

Initial Filing Deadline Q1 2013 Q1 2013 Q2 2012

Strategy/Asset Classes

U.S. fundamental equity long/short Global convertible bond arbitrage with CBs, equities, equity options, CDS

Global multi-strat; trades equities, credit, futures, FX, listed and OTC derivatives, bank debt

Key Considerations Note the impact of short balances and leverage on the Regulatory AUM calculation

Must file Form PF since Regulatory AUM is greater than $150 million, even though AUM is only $100 million

Note the impact of short balances, leverage and managed account balances on Regulatory AUM

Must file quarterly since Regulatory AUM is $1.5B

Note the impact of short balances, leverage and managed account balances on Regulatory AUM

Initial filing is 2012 since Regulatory AUM > $5B

Potential Approaches If transaction volume is high, consider data warehouse-based solution

If transaction volume is low, consider fund administrator or outsourced technology solution

With a single administrator for both the funds and the managed account, consider that particular administrator’s Form PF offering, if available and compatible

Complexity from product mix plus multiple prime brokers and fund admins

Consider a full solution with:• Advanced multi-use workflow• A robust data warehouse• Potential consulting engagement

Estimated Cost Range

$10,000 – $50,000 (single annual filing) $40,000 – $250,000 (annually) $250,000+ (one-time cost of warehouse installation and/or consulting engagement)


Service Provider Overview

As the requirements and implications of Form PF become better understood, new participants are

continuously entering the fledgling Form PF vendor/service provider industry, and their offerings are

evolving. The data in the following service provider summaries is as of September 2012 and has

been self-reported directly by the providers. Bank of America Merrill Lynch accepts no responsibility

for any such data and cautions each investment manager to make proper inquiries of each vendor

as to the accuracy of such information.

Fund Administrators, Technology Providers and Data Aggregators

Topics to consider when evaluating a fund administrator, technology provider or data aggregator’s

Form PF offering:

• How similar is the advisor’s strategy/size/complexity to other

Form PF clients serviced by the administrator or provider

• Will the solution accept and aggregate data provided by outside administrators?

• Can the solution perform risk calculations, or require the results to be provided?

• What people resources does the provider make available to help compile Form PF?

• What workflow tools are provided to track progress and manage assignment of

questions/sections?

• Financial stability of the administrator or provider

Consulting Firms

Topics to consider when evaluating Consulting Firms

• How similiar is the advisor’s strategy/size/complexity to the consulting firm’s other

Form PF clients?

• Does the firm have a Form PF-specific methodology?

• What is the level of experience of the proposed project team with Form PF and related topics?

• What systemized tools and/or calculators does the consulting firm provide?

• Ensure that the proposed Project Team is the team that comes to execute the project

• Look to reduce the risk of cost overruns through fixed billing proposals

How Can Bank of America Merrill Lynch Hedge Fund Consulting Help?

As you prepare for Form PF, the Bank of America Merrill Lynch Hedge Fund Consulting team

can assist in a number of ways:

• Providing a framework and assistance with establishing a Form PF filing program

• Reviewing applicable vendor/service provider offerings in the marketplace

• Advising on best practices for sourcing and aggregating data

8 November 2012

Fund Administrators

The data in the above service provider summaries is as of September 2012 and has been self-reported directly by the providers. Bank of America Merrill Lynch accepts no responsibility for any such data and cautions each investment manager to make proper inquiries of each vendor as to the accuracy of such information.

New Vendors and Updated Information Highlighted AIS Citco Fund Services HedgeServ Kaufman Rossin Fund Services SEI SS&C GlobeOp

Contact Info Firm Contact/Lead Name Scott Syracuse William Andreoni Julie McGlynn Josh Altchek SEI/James Cipriano Michael Megaw

Email Address [email protected] [email protected] [email protected] [email protected] [email protected] [email protected]

Phone # 201 708 9741 610 232 1730 212 920 3545 305 857 6734 610 676 1230 212 455 6333

Address 433 Hackensack Ave. Hackensack, NJ 07601

83 General Warren Blvd., Suite 200 Malvern, PA 19355

1251 Avenue of the Americas, 21st Fl. New York, NY 10020

2699 S. Bayshore Dr, 9th Fl. Miami, FL 33133

Oaks, PA 675 Third Avenue

Data Sources Import data from external fund administrator Yes Yes Yes Yes Yes Yes

List of administrators tested as of March 1 AIS clients only Not reported N/A N/A Not reported Accepts data files from any source

Administrators planned for integration in 2012 AIS clients only Not reported N/A N/A Not reported Accepts data files from any source

Import data from prime broker or swap counter parties Yes Yes Yes N/A-source data is obtained from our reconciled systems, not from prime brokers

Yes Yes

List of brokers tested as of March 1 AIS works with all prime brokers Not reported None N/A Not reported Accepts data files from any source

Brokers planned for integration in 2012 As required by clients Not reported All major brokers supported N/A All major brokers supported

Import data from risk tool or external risk vendor Yes Yes Yes No Yes Yes

List of risk tools tested as of March 1 Risk analytics provided through ConceptOne

Not reported None N/A Not reported Accepts data files from any source

Risk tools planned for integration in 2012 As required by clients Not reported All major providers supported N/A Not reported Support for both SS&C proprietary risk system as well as all major external risk providers

Sources of pricing data Bloomberg, IDC, Markit, Superderivatives, and other commonly used sources

Major pricing vendors and some smaller vendors

Bloomberg, Reuters, WM Company, Markit, CMA, Super Derivatives, Monis, IDC

Various pricing vendors Not reported All major pricing vendors

Allow export of data to client/external administrator/vendor Yes Yes Yes Yes Yes Yes

Data Input Spreadsheet-based data import supported Yes Yes Yes Yes Yes Yes

Web-based input supported Yes Yes Yes No Yes Yes

Proprietary, Enterprise system for data input Yes Yes Yes Yes Yes Yes

Describe Other Data Input mechanisms (if any) Anything machine readable Not reported N/A N/A Not reported XML, Data Feeds

Single/multi-user front-end Multi-user Multi-User Multi-User Multi-User Multi-User Multi-User

Graphical Workflow and Reporting

Web-based or local client Web-based Web-based Web-based Web-based Web-based Web-based

Permissioning to specific questions/sections Yes Yes Yes Yes Yes Yes

Question level locking Yes Yes Yes Yes Yes Yes

Progress reporting and tracking (e.g. Dashboard) Yes Yes Yes Yes Yes Yes

Number of Pre-built Management Reports 15+ 10+ Yes In process Not reported 10+ reports and dashboards

Ability to output Form PF in SEC type format Yes Yes Yes Yes Yes Yes

Drill down from an answer to position/trade level detail Yes Yes Yes Yes Yes Yes


Fund Administrators


Contact Info Firm Contact/Lead Name Scott Syracuse William Andreoni Julie McGlynn Josh Altchek SEI/James Cipriano Michael Megaw


Phone # 201 708 9741 610 232 1730 212 920 3545 305 857 6734 610 676 1230 212 455 6333

Address 433 Hackensack Ave. Hackensack, NJ 07601

83 General Warren Blvd., Suite 200 Malvern, PA 19355

1251 Avenue of the Americas, 21st Fl. New York, NY 10020

2699 S. Bayshore Dr, 9th Fl. Miami, FL 33133

Oaks, PA 675 Third Avenue

Data Sources Import data from external fund administrator Yes Yes Yes Yes Yes Yes

List of administrators tested as of March 1 AIS clients only Not reported N/A N/A Not reported Accepts data files from any source

Administrators planned for integration in 2012 AIS clients only Not reported N/A N/A Not reported Accepts data files from any source

Import data from prime broker or swap counter parties Yes Yes Yes N/A-source data is obtained from our reconciled systems, not from prime brokers

Yes Yes

List of brokers tested as of March 1 AIS works with all prime brokers Not reported None N/A Not reported Accepts data files from any source

Brokers planned for integration in 2012 As required by clients Not reported All major brokers supported N/A All major brokers supported

Import data from risk tool or external risk vendor Yes Yes Yes No Yes Yes

List of risk tools tested as of March 1 Risk analytics provided through ConceptOne

Not reported None N/A Not reported Accepts data files from any source

Risk tools planned for integration in 2012 As required by clients Not reported All major providers supported N/A Not reported Support for both SS&C proprietary risk system as well as all major external risk providers

Sources of pricing data Bloomberg, IDC, Markit, Superderivatives, and other commonly used sources

Major pricing vendors and some smaller vendors

Bloomberg, Reuters, WM Company, Markit, CMA, Super Derivatives, Monis, IDC

Various pricing vendors Not reported All major pricing vendors

Allow export of data to client/external administrator/vendor Yes Yes Yes Yes Yes Yes


Web-based input supported Yes Yes Yes No Yes Yes

Proprietary, Enterprise system for data input Yes Yes Yes Yes Yes Yes

Describe Other Data Input mechanisms (if any) Anything machine readable Not reported N/A N/A Not reported XML, Data Feeds

Single/multi-user front-end Multi-user Multi-User Multi-User Multi-User Multi-User Multi-User


Web-based or local client Web-based Web-based Web-based Web-based Web-based Web-based


Question level locking Yes Yes Yes Yes Yes Yes

Progress reporting and tracking (e.g. Dashboard) Yes Yes Yes Yes Yes Yes

Number of Pre-built Management Reports 15+ 10+ Yes In process Not reported 10+ reports and dashboards

Ability to output Form PF in SEC type format Yes Yes Yes Yes Yes Yes

Drill down from an answer to position/trade level detail Yes Yes Yes Yes Yes Yes

10 November 2012

Fund Administrators



Calculation Support

Audit Trail with ability to modify supporting calculations Yes Yes Yes Yes Yes Yes

Regulatory AUM Yes Yes Yes Yes Not reported Yes

Calculate “turnover” values based on transaction data Yes Yes Yes Yes Yes Yes

Calculate “portfolio liquidity” based on transaction and market data

Yes Yes Yes No Not reported Yes

Calculate VaR Yes Yes Yes No Yes Yes

Calculate Scenarios Yes Yes Yes No Yes Yes

Describe other calculations supported All Form PF calculations are supported including full aggregation

Yes HedgeServ has the ability to support all form PF required calculations.

N/A Ability to use manager preferred or SEI calculations

Duration, WAT, net/gross performance

Technical Infrastructure

Hosted, Software as Service or Installed Infrastructure Hosted/SaaS Hosted/SaaS Hosted/SaaS Hosted/SaaS Hosted/SaaS Hosted/SaaS

Underlying database technology SQL Server Oracle Sequel MYSQL, SQL SERVER, GENEVA DATABASE

SQL Server SQL Server

Separate regulatory database Yes Yes Yes No No Yes

Multi-tenant or separate instance for each client Both Yes Yes Multi-tenant Yes Yes

Customizable front-end Yes Yes Yes In process Yes Yes

Open reporting for generating ad-hoc reports Yes Yes Yes No Yes Yes

Resources Number of staff members dedicated to Form PF support AIS and ConceptOne 40+ 15 Not reported Not supplied in detail. Over 25.

Technical support for 3rd party integration AIS and ConceptOne Not reported 4 7 Not reported Not reported

CFA/Accountant AIS Not reported 10 7 Not reported Not reported

Legal/regulatory advisory ConceptOne Not reported Using third-party advisor 1 Not reported Not reported

Project consulting ConceptOne Not reported 1 5 Not reported Not reported

Cost/Pricing Model

Per Filing Variable; client specific Customizable Evaluated on a client by client basis generally $7,500 per filing Not reported Not supplied

BPS on AUM No No N/A N/A Not reported Not reported

Project Fee based Yes Customizable Flat fee N/A Not reported Not reported

Describe any other cost drivers/levers Complexity, asset types, number of funds

N/A N/A Complexity & volume will affect fees Not reported Not reported

Affiliations/Partnerships

Firm Name ConceptOne Not reported Advise Technology N/A Not reported Not reported

Function/Nature of service Complete aggregation coupled with web-based data management and filing tools

Not reported PW Workbook and Workflow Tools N/A Not reported Not reported

Bundled offering or requires separate contract Variable Not reported Evaluated on a client by client basis N/A Not reported Not reported


Fund Administrators


Calculation Support

Audit Trail with ability to modify supporting calculations Yes Yes Yes Yes Yes Yes

Regulatory AUM Yes Yes Yes Yes Not reported Yes

Calculate “turnover” values based on transaction data Yes Yes Yes Yes Yes Yes


Yes Yes Yes No Not reported Yes

Calculate VaR Yes Yes Yes No Yes Yes

Calculate Scenarios Yes Yes Yes No Yes Yes

Describe other calculations supported All Form PF calculations are supported including full aggregation

Yes HedgeServ has the ability to support all form PF required calculations.

N/A Ability to use manager preferred or SEI calculations

Duration, WAT, net/gross performance


Hosted, Software as Service or Installed Infrastructure Hosted/SaaS Hosted/SaaS Hosted/SaaS Hosted/SaaS Hosted/SaaS Hosted/SaaS

Underlying database technology SQL Server Oracle Sequel MYSQL, SQL SERVER, GENEVA DATABASE

SQL Server SQL Server

Separate regulatory database Yes Yes Yes No No Yes

Multi-tenant or separate instance for each client Both Yes Yes Multi-tenant Yes Yes

Customizable front-end Yes Yes Yes In process Yes Yes

Open reporting for generating ad-hoc reports Yes Yes Yes No Yes Yes

Resources Number of staff members dedicated to Form PF support AIS and ConceptOne 40+ 15 Not reported Not supplied in detail. Over 25.

Technical support for 3rd party integration AIS and ConceptOne Not reported 4 7 Not reported Not reported

CFA/Accountant AIS Not reported 10 7 Not reported Not reported

Legal/regulatory advisory ConceptOne Not reported Using third-party advisor 1 Not reported Not reported

Project consulting ConceptOne Not reported 1 5 Not reported Not reported

Cost/Pricing Model

Per Filing Variable; client specific Customizable Evaluated on a client by client basis generally $7,500 per filing Not reported Not supplied

BPS on AUM No No N/A N/A Not reported Not reported

Project Fee based Yes Customizable Flat fee N/A Not reported Not reported

Describe any other cost drivers/levers Complexity, asset types, number of funds

N/A N/A Complexity & volume will affect fees Not reported Not reported


Firm Name ConceptOne Not reported Advise Technology N/A Not reported Not reported

Function/Nature of service Complete aggregation coupled with web-based data management and filing tools

Not reported PW Workbook and Workflow Tools N/A Not reported Not reported

Bundled offering or requires separate contract Variable Not reported Evaluated on a client by client basis N/A Not reported Not reported

12 November 2012



Firms A – H New Vendors and Updated Information Highlighted Advise Technologies AxiomSL Black Mountain Systems ConceptOne Data Agent Eze Castle Software Hazel Tree

Contact Info Firm Contact/Lead Name Doug Schwenk Eugene Young Brian Guarini Dan Connell Kelli Brown Mike Hutner Stephen Casner

Email Address [email protected] [email protected] [email protected]

[email protected] [email protected] [email protected]

[email protected]

Phone # 212 576 1174 212 248 4188, ext.137 646 400 0717 646 840 4996 415 229 9190 646-346-1123 646 837 9450

Address 10 E 39th St., Suite 925-D New York, NY 10016

45 Broadway New York, NY 10006

1001 Ave of Americas New York, NY 10018

527 Madison Ave. New York, NY 10022

2000 Hearst Ave., Suite 304 Berkeley, CA 94709

1633 Broadway, 48th Fl. New York, NY 10019

150 W. 30th St., 18th Fl. New York, NY 10001

Data Sources Import data from external fund administrator Yes Yes Yes Yes Yes Yes Yes

List of administrators tested as of March 1 11 4 State Street, BONY, LaCrosse Citco, SEI, AIS, MSFS, Admiral, Caceis

16 Accepts data from any source, including all major admins

All major administrators

Administrators planned for integration in 2012 Approx 35 Yes, NDA in place Globe Op and as directed by customers

We have taken data for existing reporting services from the majority of Fund Administrators to date

TBD (see above) Various

Import data from prime broker or swap counter parties Yes Yes Yes Yes Yes Accepts data from any source including all major PBs

Yes

List of brokers tested as of March 1 5 2 Credit Suisse, Deutsche Bank, Goldman Sachs

We have taken data for existing reporting Services from the majority of Prime Brokers to date

Various The data within Eze Regulatory Filing Manager's standardized mappings can be sourced from any PB file

MS,GS,JPM,CS, UBS, DB,Bar,Citi,Fid,BofAML, BNP

Brokers planned for integration in 2012 Approx 15 Yes, NDA in place As directed by customers All TBD (see above) Any ISDA counterparty

Import data from risk tool or external risk vendor Yes Yes Yes Yes Yes Yes Yes

List of risk tools tested as of March 1 6 Axiom SL Risk Monitor N/A Not reported MSCI RiskMetrics, Nirvana Portfolio Science, Imagine, Riskmetrics

Algorithmics

Risk tools planned for integration in 2012 Approx 8 Axiom SL Risk Monitor, Client driven requests

R2 Not reported TBD Investor Analytics Various

Sources of pricing data 3 Any Source Bloomberg, Markit, Thomson Reuters, LPC, IDC

Multiple market data providers Bloomberg, IDC, Reuters, Markit, and others

Any Source All

Allow export of data to client/external administrator/vendor Yes Yes Yes Yes Yes Yes Yes

Data Input Spreadsheet-based data import supported Yes Yes Yes Yes Yes Yes Yes

Web-based input supported Yes Yes Yes Yes Yes No Yes

Proprietary, Enterprise system for data input Yes Yes Yes Yes Yes Yes Yes

Describe Other Data Input mechanisms (if any) XML, CSV, ETL, API, Link to Spreadsheet, Custom

From any data source Our product has an incredibly open interface to import data from virtually any format and any technology

Not reported Comprehensive suite of ETL services

Databases, CSV, EXCEL, API Proprietary ETL technology; all other custom feeds supported

Single/multi-user front-end Multi-User Multi-user Multi-User Multi-User Multi Users internally and externally

Multi-User Multi-User




Contact Info Firm Contact/Lead Name Doug Schwenk Eugene Young Brian Guarini Dan Connell Kelli Brown Mike Hutner Stephen Casner

Email Address [email protected] [email protected] [email protected]

[email protected] [email protected] [email protected]

[email protected]

Phone # 212 576 1174 212 248 4188, ext.137 646 400 0717 646 840 4996 415 229 9190 646-346-1123 646 837 9450

Address 10 E 39th St., Suite 925-D New York, NY 10016

45 Broadway New York, NY 10006

1001 Ave of Americas New York, NY 10018

527 Madison Ave. New York, NY 10022

2000 Hearst Ave., Suite 304 Berkeley, CA 94709

1633 Broadway, 48th Fl. New York, NY 10019

150 W. 30th St., 18th Fl. New York, NY 10001

Data Sources Import data from external fund administrator Yes Yes Yes Yes Yes Yes Yes

List of administrators tested as of March 1 11 4 State Street, BONY, LaCrosse Citco, SEI, AIS, MSFS, Admiral, Caceis

16 Accepts data from any source, including all major admins

All major administrators

Administrators planned for integration in 2012 Approx 35 Yes, NDA in place Globe Op and as directed by customers

We have taken data for existing reporting services from the majority of Fund Administrators to date

TBD (see above) Various

Import data from prime broker or swap counter parties Yes Yes Yes Yes Yes Accepts data from any source including all major PBs

Yes

List of brokers tested as of March 1 5 2 Credit Suisse, Deutsche Bank, Goldman Sachs

We have taken data for existing reporting Services from the majority of Prime Brokers to date

Various The data within Eze Regulatory Filing Manager's standardized mappings can be sourced from any PB file

MS,GS,JPM,CS, UBS, DB,Bar,Citi,Fid,BofAML, BNP

Brokers planned for integration in 2012 Approx 15 Yes, NDA in place As directed by customers All TBD (see above) Any ISDA counterparty

Import data from risk tool or external risk vendor Yes Yes Yes Yes Yes Yes Yes

List of risk tools tested as of March 1 6 Axiom SL Risk Monitor N/A Not reported MSCI RiskMetrics, Nirvana Portfolio Science, Imagine, Riskmetrics

Algorithmics

Risk tools planned for integration in 2012 Approx 8 Axiom SL Risk Monitor, Client driven requests

R2 Not reported TBD Investor Analytics Various

Sources of pricing data 3 Any Source Bloomberg, Markit, Thomson Reuters, LPC, IDC

Multiple market data providers Bloomberg, IDC, Reuters, Markit, and others

Any Source All

Allow export of data to client/external administrator/vendor Yes Yes Yes Yes Yes Yes Yes

Data Input Spreadsheet-based data import supported Yes Yes Yes Yes Yes Yes Yes

Web-based input supported Yes Yes Yes Yes Yes No Yes

Proprietary, Enterprise system for data input Yes Yes Yes Yes Yes Yes Yes

Describe Other Data Input mechanisms (if any) XML, CSV, ETL, API, Link to Spreadsheet, Custom

From any data source Our product has an incredibly open interface to import data from virtually any format and any technology

Not reported Comprehensive suite of ETL services

Databases, CSV, EXCEL, API Proprietary ETL technology; all other custom feeds supported

Single/multi-user front-end Multi-User Multi-user Multi-User Multi-User Multi Users internally and externally

Multi-User Multi-User

14 November 2012





Web-based or local client Both Yes Both Web-based Web-based local client Both

Permissioning to specific questions/sections Yes Yes Yes Yes Yes Yes Yes

Question level locking Yes Yes Yes Yes Yes Yes Yes

Progress reporting and tracking (e.g. Dashboard) Yes Yes Yes Yes Yes Yes Yes

Number of Pre-built Management Reports 11 Numerous, Variance, Scoping x3, Recon x2

Customized on a client by client basis

Yes 12 Customizable; PDF export of filing

15

Ability to output Form PF in SEC type format Yes Yes Yes Yes Yes Yes Yes

Drill down from an answer to position/trade level detail Yes Yes Yes Yes Yes Yes Yes

Calculation Support

Audit Trail with ability to modify supporting calculations Yes Yes Yes Yes Yes Yes Yes

Regulatory AUM Yes Yes Yes No Yes Yes Yes

Calculate “turnover” values based on transaction data Yes Yes, client configurable Yes Yes Yes Yes Yes


Yes Yes, client configurable Yes Yes Yes Yes Yes

Calculate VaR No Avail function in Axiom SL Risk Monitor No Yes Yes Yes No

Calculate Scenarios No Avail function in Axiom SL Risk Monitor Yes Yes Yes Yes No

Describe other calculations supported All others in Form PF Netting, Optimization, AxiomSL has the ability to support all Form PF required calculations.

We support Yield, DV01, Duration, STW, as well all Excel based calculations, and a customizable library of functions

client specific calculations depending on pricing policies of a given client; Complete aggregation

Customizable Unlimited; highly configurable All Other Form PF Calculations


Hosted, Software as Service or Installed Infrastructure Local Installation Hosted or installed Both Both Both Hosted or installed available Both

Underlying database technology SQL-Server Choice of client - Oracle, DB2, MS-SQL …

SQL Server MS SQL Server Microsoft SQL SQL Server Microsoft SQL server

Separate regulatory database Yes Configurable Yes Yes Yes Yes Yes

Multi-tenant or separate instance for each client Yes Configurable Yes Yes Yes Separate instance Yes

Customizable front-end Yes Yes Yes Yes Yes Yes No

Open reporting for generating ad-hoc reports Yes Yes Yes Yes Yes Yes Yes

Resources Number of staff members dedicated to Form PF support 40 20 1 35+ 22 21 20

Technical support for 3rd party integration 20 Yes 5 10 10 76 15

CFA/Accountant 4 No 0 10 0 4 2

Legal/regulatory advisory 4 Partner Services 0 10 1 0 0

Project consulting 5 Yes 20 5 5 117 4





Web-based or local client Both Yes Both Web-based Web-based local client Both

Permissioning to specific questions/sections Yes Yes Yes Yes Yes Yes Yes

Question level locking Yes Yes Yes Yes Yes Yes Yes

Progress reporting and tracking (e.g. Dashboard) Yes Yes Yes Yes Yes Yes Yes

Number of Pre-built Management Reports 11 Numerous, Variance, Scoping x3, Recon x2

Customized on a client by client basis

Yes 12 Customizable; PDF export of filing

15

Ability to output Form PF in SEC type format Yes Yes Yes Yes Yes Yes Yes

Drill down from an answer to position/trade level detail Yes Yes Yes Yes Yes Yes Yes

Calculation Support

Audit Trail with ability to modify supporting calculations Yes Yes Yes Yes Yes Yes Yes

Regulatory AUM Yes Yes Yes No Yes Yes Yes

Calculate “turnover” values based on transaction data Yes Yes, client configurable Yes Yes Yes Yes Yes


Yes Yes, client configurable Yes Yes Yes Yes Yes

Calculate VaR No Avail function in Axiom SL Risk Monitor No Yes Yes Yes No

Calculate Scenarios No Avail function in Axiom SL Risk Monitor Yes Yes Yes Yes No

Describe other calculations supported All others in Form PF Netting, Optimization, AxiomSL has the ability to support all Form PF required calculations.

We support Yield, DV01, Duration, STW, as well all Excel based calculations, and a customizable library of functions

client specific calculations depending on pricing policies of a given client; Complete aggregation

Customizable Unlimited; highly configurable All Other Form PF Calculations


Hosted, Software as Service or Installed Infrastructure Local Installation Hosted or installed Both Both Both Hosted or installed available Both

Underlying database technology SQL-Server Choice of client - Oracle, DB2, MS-SQL …

SQL Server MS SQL Server Microsoft SQL SQL Server Microsoft SQL server

Separate regulatory database Yes Configurable Yes Yes Yes Yes Yes

Multi-tenant or separate instance for each client Yes Configurable Yes Yes Yes Separate instance Yes

Customizable front-end Yes Yes Yes Yes Yes Yes No

Open reporting for generating ad-hoc reports Yes Yes Yes Yes Yes Yes Yes

Resources Number of staff members dedicated to Form PF support 40 20 1 35+ 22 21 20

Technical support for 3rd party integration 20 Yes 5 10 10 76 15

CFA/Accountant 4 No 0 10 0 4 2

Legal/regulatory advisory 4 Partner Services 0 10 1 0 0

Project consulting 5 Yes 20 5 5 117 4

16 November 2012




Cost/Pricing Model

Per Filing $0 Under consideration N/A 25,000-100,000 $5,000 to $10,000 per filing Annual vs. Quarterly pricing No Cost per filing

BPS on AUM $0 N/A N/A flexible N/A N/A Costs are not based on AUM

Project Fee based In Some Cases License fee and consulting services Time and Materials yes N/A N/A Monthly Fee based on counterparties & users

Describe any other cost drivers/levers Per Install AxiomSL suite provides add-ons Installation of Everest product deployed or hosted; quality of data; number of assumptions and other custom calculations; number of data sources

Set up fees ranging from approximately 5K to 25K depending on complexity

Installation can include standalone Form PF tool or integration with existing Data Management product

Standalone vs. multi user system


Firm Name HazelTree Fund Services; Paladyne Systems

KPMG N/A Rothestein Kass Yes - 2 top tier compliance consulting firms. Formal agreements to be finalized.

Portfolio Science Advise Technologies

Function/Nature of service Integration with HazelTree data warehouse; Hosting on Paladyne platform and integration with Paladyne data warehouse

Sales - Consulting N/A Regulatory advisory services Compliance consulting services

Risk Analytics Data loading and integration with Advise Form PF workbooks

Bundled offering or requires separate contract Separate contract One license contract, separate contracts for services

N/A Either bundled or separate contract

Separate contract Bundled or Separate Contract Separate Contract

Firms I – Z New Vendors and Updated Information Highlighted Indus Valley Partners Paladyne MIK Fund Solutions MSCI Risk Metrics NorthPoint Solutions Viteos Fund Services

Contact Info Firm Contact/Lead Name Gurvinder Singh Jason Meklinsky Marshall Saffer Ron Papanek Joseph Amarante/Dileep Bhat Jonathan White


[email protected]

Phone # 201 984 1045 646 214 3737 212 468 2002 212 981 1085 212 819 1700 646 861 3409, ext. 202

Address 1350 Broadway, Suite 601 New York, NY 10018, USA

420 Lexington Avenue New York, NY 10170

1633 Broadway, 28th Floor New York, NY 10019

130 West 42nd St. New York, NY 10036

441 Lexington Ave New York, NY 10017




Cost/Pricing Model

Per Filing $0 Under consideration N/A 25,000-100,000 $5,000 to $10,000 per filing Annual vs. Quarterly pricing No Cost per filing

BPS on AUM $0 N/A N/A flexible N/A N/A Costs are not based on AUM

Project Fee based In Some Cases License fee and consulting services Time and Materials yes N/A N/A Monthly Fee based on counterparties & users

Describe any other cost drivers/levers Per Install AxiomSL suite provides add-ons Installation of Everest product deployed or hosted; quality of data; number of assumptions and other custom calculations; number of data sources

Set up fees ranging from approximately 5K to 25K depending on complexity

Installation can include standalone Form PF tool or integration with existing Data Management product

Standalone vs. multi user system


Firm Name HazelTree Fund Services; Paladyne Systems

KPMG N/A Rothestein Kass Yes - 2 top tier compliance consulting firms. Formal agreements to be finalized.

Portfolio Science Advise Technologies

Function/Nature of service Integration with HazelTree data warehouse; Hosting on Paladyne platform and integration with Paladyne data warehouse

Sales - Consulting N/A Regulatory advisory services Compliance consulting services

Risk Analytics Data loading and integration with Advise Form PF workbooks

Bundled offering or requires separate contract Separate contract One license contract, separate contracts for services

N/A Either bundled or separate contract

Separate contract Bundled or Separate Contract Separate Contract


Contact Info Firm Contact/Lead Name Gurvinder Singh Jason Meklinsky Marshall Saffer Ron Papanek Joseph Amarante/Dileep Bhat Jonathan White


[email protected]

Phone # 201 984 1045 646 214 3737 212 468 2002 212 981 1085 212 819 1700 646 861 3409, ext. 202

Address 1350 Broadway, Suite 601 New York, NY 10018, USA

420 Lexington Avenue New York, NY 10170

1633 Broadway, 28th Floor New York, NY 10019

130 West 42nd St. New York, NY 10036

441 Lexington Ave New York, NY 10017

18 November 2012




Data Sources Import data from external fund administrator Yes Yes Yes Yes Yes. Pre-defined Form PF loader templates allows clients to map to any internal or 3rd party data source

Yes

List of administrators tested as of March 1 Citco/Statestreet/GlobeOps/Lacrosse Paladyne is currently working with 4 fund administrators to deliver a Form PF solution to their clients for the June 30 filing. Paladyne has developed standard adaptors for pulling data from 3rd party systems (e.g.; Advent Geneva, Risk Metrics, etc.) Most fund administrators leverage Advent Geneva which would be a standard extract.

Not reported All major Administrators Multiple major administrators via the application Loader Templates

Currently 7, dynamic mapping tool allows for data integration with any data source

Administrators planned for integration in 2012 MSFS/Hedgeserv/NT 4 administrators to be discussed at a later date. Paladyne is selling its Form PF solution to fund administrators, but it is also available for use by the individual fund managers as well.

Not reported Not reported Open based on client needs.Clients can utilize the Loader Templates for any data uploads

Client driven

Import data from prime broker or swap counter parties Yes Yes Yes Yes Yes. This is also accomplished through mapping to the Loader Templates

Yes

List of brokers tested as of March 1 MS/GS/DB/CS/BofAML/Fidelity Paladyne has created a standard set of templates for gathering all data required in Form PF. Paladyne may accept any generic broker feed or may work with brokers to comply with Paladyne’s standard template.

Not reported Multiple existing Multiple major brokers via the Loader Templates

All major prime brokers and counter parties. Most 2nd tier PBs and CPs. Existing integration through fund administration and middle office Business.

Brokers planned for integration in 2012 MSFS/Hedgeserv/NT Client Driven Not reported Not reported Open based on client needs. Clients can utilize the Loader Templates for any data uploads.

Import data from risk tool or external risk vendor Yes Yes Yes Yes Yes. Yes

List of risk tools tested as of March 1 Risk Metrics/Imagine/Front Arena/R2 Paladyne has developed a standard adaptor with Risk Metrics or may take a generic risk file from a client or provide a client with a standard risk template to be populated by the client.

Not reported RiskMetrics Multiple, including the NorthPoint/CurAlea RiskSuite application

Algorithmics

Risk tools planned for integration in 2012 Not reported Client driven Not reported RiskMetrics Open based on client needs. Clients can utilize the Loader Templates for any data uploads.

RiskMetrics, Imagine, Investor Analytics

Sources of pricing data Bloomberg, Reuters, Factset, IDC,Markit, Adaptor Tool available to on-board others

Paladyne supports all sources of pricing data.

Any Source 50 vendors; Markit, LPC, Reuters etc. Multiple market data providers Additionally, clients using the NorthPoint Market Data Service can utilize this for pricing information. Product Roadmap includes full integration of the Form PF application with the NorthPoint Market Data Service

Bloomberg, IDC, MarkIT

Allow export of data to client/external administrator/vendor Yes Yes Yes Yes Yes. This can be accomplished through Exportable Grid Views

Yes




Data Sources Import data from external fund administrator Yes Yes Yes Yes Yes. Pre-defined Form PF loader templates allows clients to map to any internal or 3rd party data source

Yes

List of administrators tested as of March 1 Citco/Statestreet/GlobeOps/Lacrosse Paladyne is currently working with 4 fund administrators to deliver a Form PF solution to their clients for the June 30 filing. Paladyne has developed standard adaptors for pulling data from 3rd party systems (e.g.; Advent Geneva, Risk Metrics, etc.) Most fund administrators leverage Advent Geneva which would be a standard extract.

Not reported All major Administrators Multiple major administrators via the application Loader Templates

Currently 7, dynamic mapping tool allows for data integration with any data source

Administrators planned for integration in 2012 MSFS/Hedgeserv/NT 4 administrators to be discussed at a later date. Paladyne is selling its Form PF solution to fund administrators, but it is also available for use by the individual fund managers as well.

Not reported Not reported Open based on client needs.Clients can utilize the Loader Templates for any data uploads

Client driven

Import data from prime broker or swap counter parties Yes Yes Yes Yes Yes. This is also accomplished through mapping to the Loader Templates

Yes

List of brokers tested as of March 1 MS/GS/DB/CS/BofAML/Fidelity Paladyne has created a standard set of templates for gathering all data required in Form PF. Paladyne may accept any generic broker feed or may work with brokers to comply with Paladyne’s standard template.

Not reported Multiple existing Multiple major brokers via the Loader Templates

All major prime brokers and counter parties. Most 2nd tier PBs and CPs. Existing integration through fund administration and middle office Business.

Brokers planned for integration in 2012 MSFS/Hedgeserv/NT Client Driven Not reported Not reported Open based on client needs. Clients can utilize the Loader Templates for any data uploads.

Import data from risk tool or external risk vendor Yes Yes Yes Yes Yes. Yes

List of risk tools tested as of March 1 Risk Metrics/Imagine/Front Arena/R2 Paladyne has developed a standard adaptor with Risk Metrics or may take a generic risk file from a client or provide a client with a standard risk template to be populated by the client.

Not reported RiskMetrics Multiple, including the NorthPoint/CurAlea RiskSuite application

Algorithmics

Risk tools planned for integration in 2012 Not reported Client driven Not reported RiskMetrics Open based on client needs. Clients can utilize the Loader Templates for any data uploads.

RiskMetrics, Imagine, Investor Analytics

Sources of pricing data Bloomberg, Reuters, Factset, IDC,Markit, Adaptor Tool available to on-board others

Paladyne supports all sources of pricing data.

Any Source 50 vendors; Markit, LPC, Reuters etc. Multiple market data providers Additionally, clients using the NorthPoint Market Data Service can utilize this for pricing information. Product Roadmap includes full integration of the Form PF application with the NorthPoint Market Data Service

Bloomberg, IDC, MarkIT

Allow export of data to client/external administrator/vendor Yes Yes Yes Yes Yes. This can be accomplished through Exportable Grid Views

Yes

20 November 2012





Web-based input supported Yes Yes Yes Yes The client desktop application is deployed through Microsoft Click Once. It is also accessible through many of today’s standard remote access platforms, such as Citrix.

Yes

Proprietary, Enterprise system for data input No Yes Yes No Yes. The solution is designed and developed as a feature rich desktop application for performing all Form PF data management and reporting processes

Yes

Describe Other Data Input mechanisms (if any) Not reported Paladyne has developed a standard set of templates for collecting all Form PF data and has a proprietary ETL tool for managing all external data.

Not reported XML, CSV, RM3D The NorthPoint Form PF application allows a number of ways to accomplish data management processes. Users can enter data through a variety of user friendly front ends. Additionally, for one-time reference data setup (such as fund names and associated IDs), users can easily cut and paste information into the grid based data management views. For mid-sized data management routines, users have the ability to upload files that conform to the Loader Templates through a point/click interface. For larger data sources, clients can customize “Extract, Translate & Load” processes, utilizing SQL Server Integration Services.

Manual (if required)

Single/multi-user front-end Multi-User Multi-User Multi-User Multi-User The application support full multi-user capabilities for proper distribution of Form PF related tasks

Yes





Web-based input supported Yes Yes Yes Yes The client desktop application is deployed through Microsoft Click Once. It is also accessible through many of today’s standard remote access platforms, such as Citrix.

Yes

Proprietary, Enterprise system for data input No Yes Yes No Yes. The solution is designed and developed as a feature rich desktop application for performing all Form PF data management and reporting processes

Yes

Describe Other Data Input mechanisms (if any) Not reported Paladyne has developed a standard set of templates for collecting all Form PF data and has a proprietary ETL tool for managing all external data.

Not reported XML, CSV, RM3D The NorthPoint Form PF application allows a number of ways to accomplish data management processes. Users can enter data through a variety of user friendly front ends. Additionally, for one-time reference data setup (such as fund names and associated IDs), users can easily cut and paste information into the grid based data management views. For mid-sized data management routines, users have the ability to upload files that conform to the Loader Templates through a point/click interface. For larger data sources, clients can customize “Extract, Translate & Load” processes, utilizing SQL Server Integration Services.

Manual (if required)

Single/multi-user front-end Multi-User Multi-User Multi-User Multi-User The application support full multi-user capabilities for proper distribution of Form PF related tasks

Yes

22 November 2012





Web-based or local client Web-based Web-based Web-based Web-based Local Client Web-based


Question level locking Yes Yes Yes On Product RoadMap. Yes

Progress reporting and tracking (e.g. Dashboard) Yes Yes Yes Not reported Yes, NorthPoint Form PF application features a graphical based progress tracker that also allows task sign-off and locking as users upload and verify question and section information. The applciation provides a number of data validation processes to make sure all fund, position, trade and security information is complete and accurate. Additionally, the application automatically creates Form PF sections and filing tasks based on how the client chooses to aggregrate fund structures.

No

Number of Pre-built Management Reports 10 Paladyne has developed a set of data views to support all calculations in Form PF.

Not reported Not reported Workflow and progress is easily tracked through the feature rich desktop application. The application provides easy generation of Form PF completed templates, along with XML previewer capability

Currently 5, unlimited (custom report generation)

Ability to output Form PF in SEC type format Yes Yes Yes Yes Yes, and also includes preview capability

Yes

Drill down from an answer to position/trade level detail Yes Yes Yes Yes On Product RoadMap Yes

Calculation Support

Audit Trail with ability to modify supporting calculations Yes Yes Yes Yes Yes, The system requires comments to be entered if any calculated data is overridden.

Yes

Regulatory AUM No Yes Yes Yes No Yes

Calculate “turnover” values based on transaction data Yes Yes Yes No Yes. The Transaction Template Loader is the basis for the data used in these calculations

Yes


Yes Yes Yes Yes Yes. Position level liquidity values can be aggregated and rolledup.

No

Calculate VaR No No No Yes No. An add-on risk platform, RiskSuite, can be integrated that calculates VaR and can then be uploaded.

Yes (Algorithmics)

Calculate Scenarios No No No Yes No Yes (Algorithmics)

Describe other calculations supported Ability to import Paladyne supports all calculations in Form PF with the exception of Risk. Paladyne would require a third party data source for calculated risk information. All calculations and static data are stored historically in the Paladyne data warehouse and may be extracted into the Form PF GUI, XML format, or EXCEL-based on client requirements.

Not reported Complete portfolio risk statistics and scenario analysis

All aggregrate level calculations required for filing and customizable per client.

Full custom derivation/calculation support at the point of import. Custom calculation on RAUM, GAV, etc.





Web-based or local client Web-based Web-based Web-based Web-based Local Client Web-based


Question level locking Yes Yes Yes On Product RoadMap. Yes

Progress reporting and tracking (e.g. Dashboard) Yes Yes Yes Not reported Yes, NorthPoint Form PF application features a graphical based progress tracker that also allows task sign-off and locking as users upload and verify question and section information. The applciation provides a number of data validation processes to make sure all fund, position, trade and security information is complete and accurate. Additionally, the application automatically creates Form PF sections and filing tasks based on how the client chooses to aggregrate fund structures.

No

Number of Pre-built Management Reports 10 Paladyne has developed a set of data views to support all calculations in Form PF.

Not reported Not reported Workflow and progress is easily tracked through the feature rich desktop application. The application provides easy generation of Form PF completed templates, along with XML previewer capability

Currently 5, unlimited (custom report generation)

Ability to output Form PF in SEC type format Yes Yes Yes Yes Yes, and also includes preview capability

Yes

Drill down from an answer to position/trade level detail Yes Yes Yes Yes On Product RoadMap Yes

Calculation Support

Audit Trail with ability to modify supporting calculations Yes Yes Yes Yes Yes, The system requires comments to be entered if any calculated data is overridden.

Yes

Regulatory AUM No Yes Yes Yes No Yes

Calculate “turnover” values based on transaction data Yes Yes Yes No Yes. The Transaction Template Loader is the basis for the data used in these calculations

Yes


Yes Yes Yes Yes Yes. Position level liquidity values can be aggregated and rolledup.

No

Calculate VaR No No No Yes No. An add-on risk platform, RiskSuite, can be integrated that calculates VaR and can then be uploaded.

Yes (Algorithmics)

Calculate Scenarios No No No Yes No Yes (Algorithmics)

Describe other calculations supported Ability to import Paladyne supports all calculations in Form PF with the exception of Risk. Paladyne would require a third party data source for calculated risk information. All calculations and static data are stored historically in the Paladyne data warehouse and may be extracted into the Form PF GUI, XML format, or EXCEL-based on client requirements.

Not reported Complete portfolio risk statistics and scenario analysis

All aggregrate level calculations required for filing and customizable per client.

Full custom derivation/calculation support at the point of import. Custom calculation on RAUM, GAV, etc.

24 November 2012





Hosted, Software as Service or Installed Infrastructure Local Installation Hosted/SaaS Local Installation Hosted/SaaS Installed Infrastructure Both

Underlying database technology SQL Microsoft SQL Oracle Microsoft SQL Server SQL Server

Separate regulatory database No No Yes No Yes. A separate database objects for managing all Form PF question attributes. All historical information is maintained in timeseries for easy access to past filing, question and client data for audit and control processes.

No

Multi-tenant or separate instance for each client No Yes Yes Yes Separate instance for each client Separate instance

Customizable front-end Yes Yes Yes Yes Yes. Customizable per client requirements.

No

Open reporting for generating ad-hoc reports Yes Yes Yes Yes Yes. Grid exports provide easy extracts and an open database model supports client customized reporting. On Product RoadMap for side-by-side and Executive Dashboard summaries.

Yes

Resources Number of staff members dedicated to Form PF support 10 10 4 developers for just Form PF experience

6 7+ 10

Technical support for 3rd party integration 5 7 47 developers 6 3 N/A

CFA/Accountant 0 3 Not reported Not reported 2 10

Legal/regulatory advisory 0 0 Not reported Not reported N/A N/A

Project consulting 5 3 1 project lead dedicated 10+ 3 4

Cost/Pricing Model

Per Filing Not reported N/A Filing software is provided free of charge

Not reported No cost per filing $10-15k (service) or annual license

BPS on AUM Not reported N/A n/a Not reported No cost per filing N/A

Project Fee based Not reported Each implementation would have a services and license fee component to overall pricing.

Time and Material cost for implementation

Not reported One time licensing cost (70K) Time and Materials on initial setup (optional)

Describe any other cost drivers/levers Annual (25-40K) depending on sections applicable

Paladyne charges an annual support fee and a license fee for various product components. In addition, Paladyne sub-licenses Advise as an optional component of the overall solution which would be an additional charge.

Have to Install the warehouse Not reported Implementation, Integration (Time & Materials) and $25K yr maintenance & support

None


Firm Name Not reported Advise Technologies N/A Advise Technologies/MIK/Red Swan/Indus Valley/Paladyne

Rothstein Kass Algorithmics

Function/Nature of service Not reported Web-based instance of Form PF N/A Risk Analytics IT & Business Consulting services for implementation and integration of Form PF software solution

Risk services/reporting

Bundled offering or requires separate contract Not reported Sub-licensing arrangement allows for a single contract with Paladyne.

N/A Both Separate contract Additional charge for risk data through Viteos.





Hosted, Software as Service or Installed Infrastructure Local Installation Hosted/SaaS Local Installation Hosted/SaaS Installed Infrastructure Both

Underlying database technology SQL Microsoft SQL Oracle Microsoft SQL Server SQL Server

Separate regulatory database No No Yes No Yes. A separate database objects for managing all Form PF question attributes. All historical information is maintained in timeseries for easy access to past filing, question and client data for audit and control processes.

No

Multi-tenant or separate instance for each client No Yes Yes Yes Separate instance for each client Separate instance

Customizable front-end Yes Yes Yes Yes Yes. Customizable per client requirements.

No

Open reporting for generating ad-hoc reports Yes Yes Yes Yes Yes. Grid exports provide easy extracts and an open database model supports client customized reporting. On Product RoadMap for side-by-side and Executive Dashboard summaries.

Yes

Resources Number of staff members dedicated to Form PF support 10 10 4 developers for just Form PF experience

6 7+ 10

Technical support for 3rd party integration 5 7 47 developers 6 3 N/A

CFA/Accountant 0 3 Not reported Not reported 2 10

Legal/regulatory advisory 0 0 Not reported Not reported N/A N/A

Project consulting 5 3 1 project lead dedicated 10+ 3 4

Cost/Pricing Model

Per Filing Not reported N/A Filing software is provided free of charge

Not reported No cost per filing $10-15k (service) or annual license

BPS on AUM Not reported N/A n/a Not reported No cost per filing N/A

Project Fee based Not reported Each implementation would have a services and license fee component to overall pricing.

Time and Material cost for implementation

Not reported One time licensing cost (70K) Time and Materials on initial setup (optional)

Describe any other cost drivers/levers Annual (25-40K) depending on sections applicable

Paladyne charges an annual support fee and a license fee for various product components. In addition, Paladyne sub-licenses Advise as an optional component of the overall solution which would be an additional charge.

Have to Install the warehouse Not reported Implementation, Integration (Time & Materials) and $25K yr maintenance & support

None


Firm Name Not reported Advise Technologies N/A Advise Technologies/MIK/Red Swan/Indus Valley/Paladyne

Rothstein Kass Algorithmics

Function/Nature of service Not reported Web-based instance of Form PF N/A Risk Analytics IT & Business Consulting services for implementation and integration of Form PF software solution

Risk services/reporting

Bundled offering or requires separate contract Not reported Sub-licensing arrangement allows for a single contract with Paladyne.

N/A Both Separate contract Additional charge for risk data through Viteos.

26 November 2012

Consulting Firms


New Vendors and Updated Information Highlighted ACA Compliance GroupAvalon Lake Partners, LLC (formerly known as WTP Advisors) Deloitte Ernst & Young Gravitas Rothstein Kass SEC3 Sindex Financial Systems

Contact Info Firm Contact/Lead Name Jack Rader Jessica Huelbig

Ilicia Silverman Partner & Head of Business Development

Karl Ehrsam Samer Ojjeh Anita Bafna

Timothy Hamel Gary S. Kaminsky, Principal Janaya Moscony Michael Schully

Email Address [email protected] [email protected]

[email protected] [email protected] [email protected] [email protected]


Phone # 973 631 1085 917 655 0051 212 436 3153 212 773 6486 212 773 3938

212 607 8243 917 438 3648 212 706 4029 646 291 6163

Address 2180 Headquarters Plaza East Tower, Suite 205 Morristown, NJ 07960

400 Madison Ave, Suite 7D New York, NY 10017

1 World Financial Center New York, NY 10281

5 Times Square New York, NY 10036

1350 Avenue of the Americas New York, NY 10019

1140 Avenue of the Americas, 9th Floor New York, NY 10036

158 West 23rd Street, 2nd Floor New York, NY 10011

Deliverables Form PF Project Methodology N/A Working off of our comprehensive matrix of Form PF to corresponding data sources, Avalon Lake Partners conducts a discovery diagnostic where we take an inventory of your data and where it resides (service providers vs. internal systems). We then prepare a Form PF blueprint comprised of a diagnostic report with full gap analysis, preliminary Form PF outline and recommendations.

The Deloitte standard approach breaks down Form PF initiatives into four basic phases: Requirements Analysis, Gap Assessment, Solution Design, and Implementation. The method ultimately chosen depends largely on client need and goals, particularly if they are seeking a more strategic solution that addresses challenges related not only to Form PF, but also to provide consistency of data with other data and reporting needs (e.g., Form ADV, international large position disclosure, 13F/G reporting, marketing, client transparency reporting). Deloitte brings to engagements tools and templates, including requirements gathering questionnaire, gap assessment template and Form PF project management template. We also bring specialists in subjects that we find particularly challenging for Form PF, including risk management, data management and valuation

Ernst & Young has tailored its regulatory reporting methodology to apply to Form PF reporting. We work closely with our clients to determine scope of services and customize our approach, but our standard approach to Form PF reporting model consists of the following phases: survey and planning, data analysis, solution design and implementation assistance. In addition we can introduce and leverage many of our Form PF accelerators (Fund Scoping Template, Fund Shadow Filer, Form PF Data Dictionary, Baseline Plan, Form PF reporting flows, etc.) to quickly kick-off the initiative. Survey and Planning: During this phase, we assist our clients to determine eligible fund population and applicable Form PF sections, documentation including Form PF assumptions, construct Form PF data dictionary and co-develop high-level implementation roadmap related to any tactical or strategic solution including vendor selection activities Data Analysis: In parallel, we work with our clients to conduct a rapid current state assessment and data gathering to understand data sourcing with an aim of identifying gaps and applicable reconciliation. Solution Design: Assist with the design and development of data aggregation processes, workflows, reporting processes and controls , calculations and mock reporting, vendor integration (as applicable) Implementation Assistance: Assist with mock filing, Form PF completion, review and filing

Gravitas BCS first defines the firm’s initiative based on specific form requirements, assigning responsibilities to a working group. Once established, a formal project plan is written to organize data mapping and aggregation.

Access to RKBAS library of Form PF definitions, interpretations and institutional knowledge. During the discovery stage, delivery of a fully customized Form PF road map outlining the adviser’s reporting requirements. To supplement the review and the implementation of a repeatable process, a tailored compliance and risk management tool to store the client’s specific methodologies and interpretations used to respond to questions in the Form. Includes guidance on a full inventory of regulatory filings in addition to Form PF for which the adviser has a filing requirement.

SEC3 will assist its clients with the interpretation of Form PF requirements and will assist mid-sized fund managers with filing Form PF. SEC3 offers a cost-effective solution to smaller and mid-sized advisers.

Sindex’s staff has taken its project management methodology, successfully used for complex data-driven initiatives such as portfolio management systems, security master, order management systems, data warehouse and reporting implementation, and customized it for adaption to Form PF needs.

Analysis of required data inputs and sources for each section/question

N/A Leveraging our subject matter expertise, we provide full data discovery and analysis for each question on the form. This includes: identifying the sources, normalizing and aggregating the data (including performing additional calculations if required) and full mapping into the appropriate sections/questions.

Deloitte will work with your legal counsel to perform an analysis of data inputs that are available from existing client systems and those that will need to be enriched from outside or other sources.

Manage data sourcing, mapping and verification from multiple sources, standardization of data dictionary, design of the workflow, definition and review of calculations

Gravitas BCS gap analysis focuses on making connections between disparate data and a final, reportable product. Mapping each section through staging tables for calculations and importing allows for a reliable, automatable filing process.

RKBAS utilizes a compliance and risk management tool which stores the client’s methodologies for answering each question in Form PF (provided as an approval audit trail and links to underlying data sets). Other regulatory filings can be built on to this platform to enable alignment of all third-party reporting and disclosures. RKBAS provides a detailed analysis of required data inputs. RKBAS will conduct a customized data mapping and gap analysis to assist firms in completing all Form PF data requirements. Our process facilitates the aggregation, enrichment and tagging of data necessary for population of responses.

N/A Sindex has reviewed, organized and documented the more than seventeen hundred data elements that are included in preparing the Form PF filing.


Consulting Firms


Contact Info Firm Contact/Lead Name Jack Rader Jessica Huelbig

Ilicia Silverman Partner & Head of Business Development

Karl Ehrsam Samer Ojjeh Anita Bafna

Timothy Hamel Gary S. Kaminsky, Principal Janaya Moscony Michael Schully

Email Address [email protected] [email protected]



Phone # 973 631 1085 917 655 0051 212 436 3153 212 773 6486 212 773 3938

212 607 8243 917 438 3648 212 706 4029 646 291 6163

Address 2180 Headquarters Plaza East Tower, Suite 205 Morristown, NJ 07960

400 Madison Ave, Suite 7D New York, NY 10017

1 World Financial Center New York, NY 10281

5 Times Square New York, NY 10036

1350 Avenue of the Americas New York, NY 10019

1140 Avenue of the Americas, 9th Floor New York, NY 10036

158 West 23rd Street, 2nd Floor New York, NY 10011

Deliverables Form PF Project Methodology N/A Working off of our comprehensive matrix of Form PF to corresponding data sources, Avalon Lake Partners conducts a discovery diagnostic where we take an inventory of your data and where it resides (service providers vs. internal systems). We then prepare a Form PF blueprint comprised of a diagnostic report with full gap analysis, preliminary Form PF outline and recommendations.

The Deloitte standard approach breaks down Form PF initiatives into four basic phases: Requirements Analysis, Gap Assessment, Solution Design, and Implementation. The method ultimately chosen depends largely on client need and goals, particularly if they are seeking a more strategic solution that addresses challenges related not only to Form PF, but also to provide consistency of data with other data and reporting needs (e.g., Form ADV, international large position disclosure, 13F/G reporting, marketing, client transparency reporting). Deloitte brings to engagements tools and templates, including requirements gathering questionnaire, gap assessment template and Form PF project management template. We also bring specialists in subjects that we find particularly challenging for Form PF, including risk management, data management and valuation

Ernst & Young has tailored its regulatory reporting methodology to apply to Form PF reporting. We work closely with our clients to determine scope of services and customize our approach, but our standard approach to Form PF reporting model consists of the following phases: survey and planning, data analysis, solution design and implementation assistance. In addition we can introduce and leverage many of our Form PF accelerators (Fund Scoping Template, Fund Shadow Filer, Form PF Data Dictionary, Baseline Plan, Form PF reporting flows, etc.) to quickly kick-off the initiative. Survey and Planning: During this phase, we assist our clients to determine eligible fund population and applicable Form PF sections, documentation including Form PF assumptions, construct Form PF data dictionary and co-develop high-level implementation roadmap related to any tactical or strategic solution including vendor selection activities Data Analysis: In parallel, we work with our clients to conduct a rapid current state assessment and data gathering to understand data sourcing with an aim of identifying gaps and applicable reconciliation. Solution Design: Assist with the design and development of data aggregation processes, workflows, reporting processes and controls , calculations and mock reporting, vendor integration (as applicable) Implementation Assistance: Assist with mock filing, Form PF completion, review and filing

Gravitas BCS first defines the firm’s initiative based on specific form requirements, assigning responsibilities to a working group. Once established, a formal project plan is written to organize data mapping and aggregation.

Access to RKBAS library of Form PF definitions, interpretations and institutional knowledge. During the discovery stage, delivery of a fully customized Form PF road map outlining the adviser’s reporting requirements. To supplement the review and the implementation of a repeatable process, a tailored compliance and risk management tool to store the client’s specific methodologies and interpretations used to respond to questions in the Form. Includes guidance on a full inventory of regulatory filings in addition to Form PF for which the adviser has a filing requirement.

SEC3 will assist its clients with the interpretation of Form PF requirements and will assist mid-sized fund managers with filing Form PF. SEC3 offers a cost-effective solution to smaller and mid-sized advisers.

Sindex’s staff has taken its project management methodology, successfully used for complex data-driven initiatives such as portfolio management systems, security master, order management systems, data warehouse and reporting implementation, and customized it for adaption to Form PF needs.

Analysis of required data inputs and sources for each section/question

N/A Leveraging our subject matter expertise, we provide full data discovery and analysis for each question on the form. This includes: identifying the sources, normalizing and aggregating the data (including performing additional calculations if required) and full mapping into the appropriate sections/questions.

Deloitte will work with your legal counsel to perform an analysis of data inputs that are available from existing client systems and those that will need to be enriched from outside or other sources.

Manage data sourcing, mapping and verification from multiple sources, standardization of data dictionary, design of the workflow, definition and review of calculations

Gravitas BCS gap analysis focuses on making connections between disparate data and a final, reportable product. Mapping each section through staging tables for calculations and importing allows for a reliable, automatable filing process.

RKBAS utilizes a compliance and risk management tool which stores the client’s methodologies for answering each question in Form PF (provided as an approval audit trail and links to underlying data sets). Other regulatory filings can be built on to this platform to enable alignment of all third-party reporting and disclosures. RKBAS provides a detailed analysis of required data inputs. RKBAS will conduct a customized data mapping and gap analysis to assist firms in completing all Form PF data requirements. Our process facilitates the aggregation, enrichment and tagging of data necessary for population of responses.

N/A Sindex has reviewed, organized and documented the more than seventeen hundred data elements that are included in preparing the Form PF filing.

28 November 2012

Consulting Firms



Deliverables, continued

Form PF specific “mini tools” to accelerate and support progress N/A “Mini tools” include: a customizable user dashboard, comprehensive review and approval workflow management, full audit trail and reporting, customizable security settings, ability to attach and store supporting documentation, a comprehensive calculation engine for form requirements, and an enterprise scale ETL component for data mapping.

We will utilize our Gap Assessment Template, Solution Assessment Framework, Planning and Data Analytics Tools, and Operating Model templates to accelerate progress with Form PF.

Customizable Form PF data dictionary for line-by-line Form PF data identification for each data point including data sources and calculation, central location for data element characteristics and tracking progress on each data element. Fund Scoping template that follows a multi step Fund categorization process to help prioritize the filings along with sections to be filed and other details. Data Element Matrix: Organizes data mapping and calculations Shadow Filer: Leverages sources and uses of data listed in Data Element Matrix to test system data extracts for Form PF reporting Baseline Form PF plan Baseline Form PF reporting flow

Formal workflow and initiative, an electronic Form PF filing application (third party), assistance with form calculations.

RKBAS utilizes a compliance and risk management tool which stores the client’s methodologies for answering each question in Form PF(provided as an approval audit trail and links to underlying data sets). Other regulatory filings can be built on to this platform to enable alignment of all third-party reporting and disclosures.

N/A Sindex can either leverage systems the client has in place for calculating derived numbers (performance, VaR, etc.), or can utilize its own tools where the client may not have the capability in-house.

Filing/submission to SEC via PFRA N/A We support full XML integration for automated upload/filing capabilities to the SEC.

Deloitte will not file Form PF on behalf of a client, but will work closely with our clients to develop process- and technology-oriented solutions that will create repeatable and predictable outputs for Form PF.

EY does not directly file the form with the SEC but works with vendors and clients to ensure smooth vendor integration, form accuracy and assumptions documentation before filing.

Gravitas currently works with industry leading technology providers who have produced electronic filing applications. Gravitas BCS will see the client through the electronic process once it is completely defined by the SEC.

RKBAS available to assist in file submission.

Yes There are multiple software offerings in the marketplace designed to take finalized data input and format the filing to SEC specifications; we can assist in the selection and implementation of an appropriate tool from the marketplace.

Services Project Management N/A End-to-end project management from hardware and software setup, data discovery analysis and preparation, data integration and automation, process consulting, filing support services and compliance support services. There is a complete solution knowledge transfer so client can be self-sufficient post project.

We can manage the overall Form PF project effort, from requirements through implementation (for non-attest client relationships)

We provide program/project management assistance through the entire lifecycle of your Form PF reporting project. We can quickly assist you in mobilizing a multi-dimensional team from finance, operations, compliance and technology Apply proven approach to current and future state assessments, including processes and data flows, resourcing plan, data architecture, and implementation roadmap

On- and off-site project management team.

Maintain timeline and overall organization of the project, including coordination with internal and external resources.

Not Reported Sindex’s staff has an average of 15 years of financial industry experience, including project management of complex data-driven initiatives, such as portfolio management systems implementations, data warehouse and reporting implementations, etc.

Subject matter experts (legal, CPA, CFA, etc.) ACA provides unparalleled regulatory compliance consulting to its clients, including investment advisers and private fund managers. ACA specializes in offering customized client-specific solutions designed to assist firms as they build and maintain best practice compliance programs. ACA bases these solutions on its unique insights into current regulatory focus areas, including Form PF filing requirements. ACA provides a variety of regulatory compliance consulting services to assist clients in preparing Form PF. For example, ACA can assist firms in identifying issues relevant to determining if and when the firm needs to file Form PF, and what section(s) of Form PF must be completed. ACA can address practical questions about the form, based on ACA’s industry knowledge, and can provide a reasonableness check on a firm’s list of assumptions and its draft Form PF filing. Additionally, ACA’s clients are provided access to a confidential online forum to anonymously discuss issues related to Form PF.

Subject matter expertise for all aspects of the engagement including certified software professionals, former hedge fund COOs and CFOs, CPAs, CFAs, MBAs and former CCOs and legal counsel. Compliance program development and on-going compliance support; SEC and state registration; annual compliance program reviews and compliance training; ML compliance monitoring; compliance manual development; trade surveillance and monitoring portfolio and investment guideline monitoring regulatory filings including Form ADV and Form PF; marketing material review; broker dealer compliance support; assistance with regulatory examinations and mock examinations; business continuity plan development and testing.

Deloitte’s regulatory consulting resources and experience are global and span the alternative investments industry, including private equity funds, hedge funds and industry service providers. We bring regulatory reporting methodologies and leading practice insight to the challenges of new regulatory reporting requirements, such as Form PF.

Subject matter experts including asset management and regulatory reporting advisors, CPAs, CFAs, former SEC examiners, compliance and risk specialists, data and solution architects and analysts with significant years of experience

Gravitas Managing Director Mark Seaman is responsible for providing high end business consulting services with respect to software platform integration and best .business practices for front, middle and back office operational workflow

RKBAS engagement team is led by a former SEC enforcement attorney with experience as a COO/CCO and principal of alternative management companies. The team also includes CPAs, CFAs, MBAs, JDs as well as professionals with alternative management company CFO, COO and CCO and audit experience. The RKBAS team has assisted a number of 8/29 filers with Form PF, in particular with mapping the organizational infrastructure and data sources and providing interpretative and regulatory guidance on specific questions on the Form

SEC3 has subject matter experts including MBAs, CPAs, CFAs, JDs, former SEC examiners and compliance and risk specialists with significant years of experience. SEC3 assists its clients with meeting all their regulatory needs including completing Form PF. Specific Form PF services include determining if and when they need to file Form PF, which entities and funds need to report and how to aggregate assets, what sections of Form PF to fill out and how to answer specific Form PF questions. Other services SEC3 offers include SEC-registration services and assistance with setting up and administering customized compliance programs based on each client’s risk assessment as well as conducting annual and quarterly reviews and mock audits.

With our long-term hedge fund consulting practice, we have expertise on all the data components that comprise Form PF, whether it is shareholder data, performance, portfolio accounting, security master, risk, derivatives or leverage data fields.


Consulting Firms


Deliverables, continued

Form PF specific “mini tools” to accelerate and support progress N/A “Mini tools” include: a customizable user dashboard, comprehensive review and approval workflow management, full audit trail and reporting, customizable security settings, ability to attach and store supporting documentation, a comprehensive calculation engine for form requirements, and an enterprise scale ETL component for data mapping.

We will utilize our Gap Assessment Template, Solution Assessment Framework, Planning and Data Analytics Tools, and Operating Model templates to accelerate progress with Form PF.

Customizable Form PF data dictionary for line-by-line Form PF data identification for each data point including data sources and calculation, central location for data element characteristics and tracking progress on each data element. Fund Scoping template that follows a multi step Fund categorization process to help prioritize the filings along with sections to be filed and other details. Data Element Matrix: Organizes data mapping and calculations Shadow Filer: Leverages sources and uses of data listed in Data Element Matrix to test system data extracts for Form PF reporting Baseline Form PF plan Baseline Form PF reporting flow

Formal workflow and initiative, an electronic Form PF filing application (third party), assistance with form calculations.

RKBAS utilizes a compliance and risk management tool which stores the client’s methodologies for answering each question in Form PF(provided as an approval audit trail and links to underlying data sets). Other regulatory filings can be built on to this platform to enable alignment of all third-party reporting and disclosures.

N/A Sindex can either leverage systems the client has in place for calculating derived numbers (performance, VaR, etc.), or can utilize its own tools where the client may not have the capability in-house.

Filing/submission to SEC via PFRA N/A We support full XML integration for automated upload/filing capabilities to the SEC.

Deloitte will not file Form PF on behalf of a client, but will work closely with our clients to develop process- and technology-oriented solutions that will create repeatable and predictable outputs for Form PF.

EY does not directly file the form with the SEC but works with vendors and clients to ensure smooth vendor integration, form accuracy and assumptions documentation before filing.

Gravitas currently works with industry leading technology providers who have produced electronic filing applications. Gravitas BCS will see the client through the electronic process once it is completely defined by the SEC.

RKBAS available to assist in file submission.

Yes There are multiple software offerings in the marketplace designed to take finalized data input and format the filing to SEC specifications; we can assist in the selection and implementation of an appropriate tool from the marketplace.

Services Project Management N/A End-to-end project management from hardware and software setup, data discovery analysis and preparation, data integration and automation, process consulting, filing support services and compliance support services. There is a complete solution knowledge transfer so client can be self-sufficient post project.

We can manage the overall Form PF project effort, from requirements through implementation (for non-attest client relationships)

We provide program/project management assistance through the entire lifecycle of your Form PF reporting project. We can quickly assist you in mobilizing a multi-dimensional team from finance, operations, compliance and technology Apply proven approach to current and future state assessments, including processes and data flows, resourcing plan, data architecture, and implementation roadmap

On- and off-site project management team.

Maintain timeline and overall organization of the project, including coordination with internal and external resources.

Not Reported Sindex’s staff has an average of 15 years of financial industry experience, including project management of complex data-driven initiatives, such as portfolio management systems implementations, data warehouse and reporting implementations, etc.

Subject matter experts (legal, CPA, CFA, etc.) ACA provides unparalleled regulatory compliance consulting to its clients, including investment advisers and private fund managers. ACA specializes in offering customized client-specific solutions designed to assist firms as they build and maintain best practice compliance programs. ACA bases these solutions on its unique insights into current regulatory focus areas, including Form PF filing requirements. ACA provides a variety of regulatory compliance consulting services to assist clients in preparing Form PF. For example, ACA can assist firms in identifying issues relevant to determining if and when the firm needs to file Form PF, and what section(s) of Form PF must be completed. ACA can address practical questions about the form, based on ACA’s industry knowledge, and can provide a reasonableness check on a firm’s list of assumptions and its draft Form PF filing. Additionally, ACA’s clients are provided access to a confidential online forum to anonymously discuss issues related to Form PF.

Subject matter expertise for all aspects of the engagement including certified software professionals, former hedge fund COOs and CFOs, CPAs, CFAs, MBAs and former CCOs and legal counsel. Compliance program development and on-going compliance support; SEC and state registration; annual compliance program reviews and compliance training; ML compliance monitoring; compliance manual development; trade surveillance and monitoring portfolio and investment guideline monitoring regulatory filings including Form ADV and Form PF; marketing material review; broker dealer compliance support; assistance with regulatory examinations and mock examinations; business continuity plan development and testing.

Deloitte’s regulatory consulting resources and experience are global and span the alternative investments industry, including private equity funds, hedge funds and industry service providers. We bring regulatory reporting methodologies and leading practice insight to the challenges of new regulatory reporting requirements, such as Form PF.

Subject matter experts including asset management and regulatory reporting advisors, CPAs, CFAs, former SEC examiners, compliance and risk specialists, data and solution architects and analysts with significant years of experience

Gravitas Managing Director Mark Seaman is responsible for providing high end business consulting services with respect to software platform integration and best .business practices for front, middle and back office operational workflow

RKBAS engagement team is led by a former SEC enforcement attorney with experience as a COO/CCO and principal of alternative management companies. The team also includes CPAs, CFAs, MBAs, JDs as well as professionals with alternative management company CFO, COO and CCO and audit experience. The RKBAS team has assisted a number of 8/29 filers with Form PF, in particular with mapping the organizational infrastructure and data sources and providing interpretative and regulatory guidance on specific questions on the Form

SEC3 has subject matter experts including MBAs, CPAs, CFAs, JDs, former SEC examiners and compliance and risk specialists with significant years of experience. SEC3 assists its clients with meeting all their regulatory needs including completing Form PF. Specific Form PF services include determining if and when they need to file Form PF, which entities and funds need to report and how to aggregate assets, what sections of Form PF to fill out and how to answer specific Form PF questions. Other services SEC3 offers include SEC-registration services and assistance with setting up and administering customized compliance programs based on each client’s risk assessment as well as conducting annual and quarterly reviews and mock audits.

With our long-term hedge fund consulting practice, we have expertise on all the data components that comprise Form PF, whether it is shareholder data, performance, portfolio accounting, security master, risk, derivatives or leverage data fields.

30 November 2012

Consulting Firms



Services, continued

Staff Augmentation Dedicated consultant for each ACA client supported by ACA’s regulatory filings team.

Comprehensive project resources as well as staff augmentation during and post-project are available. You have complete access to our consulting business including our outsourced COO/CFO business team of experienced operational and financial experts as well as compliance consultants, legal professionals and a technology support team.

Deloitte can provide resources of varying skill sets to address the individual needs of each of our clients, whether regulatory, technology, industry, or other required resources.

Provide subject matter experts, project management professionals, risk and compliance professionals, data and solution integration architects and analysts

Timothy Hamel is responsible for business consulting regarding Form PF.

Engagement teams are overseen by Gary S. Kaminsky, Principal of the firm’s regulatory enterprise risk management advisory practice. Our team is made up of seasoned financial professionals with specific experience in the front, middle and back offices of alternative management companies, including finance, operations and legal/compliance.

Varies based on services provided. Our staff’s expertise in automation and reconciliation can help reduce the need for staff augmentation. Our experience in documentation and training can help you leverage the temporary workforce more efficiently if needed.

Cost structure ACA is not offering a standalone Form PF filing solution. ACA’s consulting related to Form PF is either included as part of the current consulting agreement with clients or offered on an hourly basis.

Rates and references available upon request.

We charge on a time and materials basis as estimated for each client engagement.

Time and materials basis charged. Rates and references available on request.

Project undertaken on T&M, fixed cost and capped basis as determined by engagement. Typical fee range is between $100-$350/Hour based on level of consultant.

We charge on a time and materials basis (initial retainer may be required). Note that RKBAS has developed a phased approach that directly correlates to time and deliverables.

Varies based on services provided. We offer a competitive houly-based fee for Form PF services.

Sindex bills at an hourly rate and will work with clients to control cost with careful resource planning.


Firm Name ACA is referring its clients to a select number of third-party service providers who offer Form PF filing solutions. ACA clients are eligible to receive a discount from certain of these third-party service providers

CheckPoint Consulting, LLC N/A Vendor agnostic but we collaborate with several vendors that provide Form PF solutions/components

Gravitas - Consulting Services Division RKBAS works with administrators, prime brokers and technology providers of the client. We are vendor agnostic and view our services as value additive to the client’s overall PF effort.

SEC3 works with various technology firms and can assit with evaluating and recommending software and technology providers.

N/A

Function/Nature of service N/A Form PF reporting Architecture planning Software installation Support team setup Management/investor reporting Executive dashboards Product implementation and customization Requirements and design planning Deployment support Data Integration specialists

Deloitte is vendor agnostic, however our Form PF practice meets regularly with software vendors and fund administrators to understand the pros and cons of potential solutions for clients and to understand how the solution landscape is evolving. We bring this knowledge base of Form PF solutions to client engagements to accelerate solution design and implementation

End to end Form PF solution providers, data aggregation and data warehouse specialists, and risk calculations providers

Consulting services to assist managers in analyzing Form PF requirements, mapping information from data sources, selecting/implementing technology solution and establishing operating procedures to complete the form on an ongoing basis.

N/A N/A N/A

Bundled offering or requires separate contract N/A Included in our standard offering. N/A Bundled offerings and separate contract offerings

Separate contract dependent on scope. N/A N/A N/A


Consulting Firms


Services, continued

Staff Augmentation Dedicated consultant for each ACA client supported by ACA’s regulatory filings team.

Comprehensive project resources as well as staff augmentation during and post-project are available. You have complete access to our consulting business including our outsourced COO/CFO business team of experienced operational and financial experts as well as compliance consultants, legal professionals and a technology support team.

Deloitte can provide resources of varying skill sets to address the individual needs of each of our clients, whether regulatory, technology, industry, or other required resources.

Provide subject matter experts, project management professionals, risk and compliance professionals, data and solution integration architects and analysts

Timothy Hamel is responsible for business consulting regarding Form PF.

Engagement teams are overseen by Gary S. Kaminsky, Principal of the firm’s regulatory enterprise risk management advisory practice. Our team is made up of seasoned financial professionals with specific experience in the front, middle and back offices of alternative management companies, including finance, operations and legal/compliance.

Varies based on services provided. Our staff’s expertise in automation and reconciliation can help reduce the need for staff augmentation. Our experience in documentation and training can help you leverage the temporary workforce more efficiently if needed.

Cost structure ACA is not offering a standalone Form PF filing solution. ACA’s consulting related to Form PF is either included as part of the current consulting agreement with clients or offered on an hourly basis.

Rates and references available upon request.

We charge on a time and materials basis as estimated for each client engagement.

Time and materials basis charged. Rates and references available on request.

Project undertaken on T&M, fixed cost and capped basis as determined by engagement. Typical fee range is between $100-$350/Hour based on level of consultant.

We charge on a time and materials basis (initial retainer may be required). Note that RKBAS has developed a phased approach that directly correlates to time and deliverables.

Varies based on services provided. We offer a competitive houly-based fee for Form PF services.

Sindex bills at an hourly rate and will work with clients to control cost with careful resource planning.


Firm Name ACA is referring its clients to a select number of third-party service providers who offer Form PF filing solutions. ACA clients are eligible to receive a discount from certain of these third-party service providers

CheckPoint Consulting, LLC N/A Vendor agnostic but we collaborate with several vendors that provide Form PF solutions/components

Gravitas - Consulting Services Division RKBAS works with administrators, prime brokers and technology providers of the client. We are vendor agnostic and view our services as value additive to the client’s overall PF effort.

SEC3 works with various technology firms and can assit with evaluating and recommending software and technology providers.

N/A

Function/Nature of service N/A Form PF reporting Architecture planning Software installation Support team setup Management/investor reporting Executive dashboards Product implementation and customization Requirements and design planning Deployment support Data Integration specialists

Deloitte is vendor agnostic, however our Form PF practice meets regularly with software vendors and fund administrators to understand the pros and cons of potential solutions for clients and to understand how the solution landscape is evolving. We bring this knowledge base of Form PF solutions to client engagements to accelerate solution design and implementation

End to end Form PF solution providers, data aggregation and data warehouse specialists, and risk calculations providers

Consulting services to assist managers in analyzing Form PF requirements, mapping information from data sources, selecting/implementing technology solution and establishing operating procedures to complete the form on an ongoing basis.

N/A N/A N/A

Bundled offering or requires separate contract N/A Included in our standard offering. N/A Bundled offerings and separate contract offerings

Separate contract dependent on scope. N/A N/A N/A

“Bank of America Merrill Lynch” is the marketing name for the global banking and global markets businesses of Bank of America Corporation. Lending, derivatives, and other commercial banking activities are performed globally by banking affiliates of Bank of America Corporation, including Bank of America, N.A., member FDIC. Securities, strategic advisory, and other investment banking activities are performed globally by investment banking affiliates of Bank of America Corporation (“Investment Banking Affiliates”), including, in the United States, Merrill Lynch, Pierce, Fenner & Smith Incorporated and Merrill Lynch Professional Clearing Corp., both of which are registered broker-dealers and members of FINRA and SIPC, and, in other jurisdictions, Merrill Lynch International and other locally registered entities. Investment products offered by Investment Banking Affiliates: Are Not FDIC Insured • May Lose Value • Are Not Bank Guaranteed.

These materials have been prepared by one or more subsidiaries of Bank of America Corporation for the client or potential client to whom such materials are directly addressed and delivered (the “Company”) in connection with an actual or potential mandate or engagement and may not be used or relied upon for any purpose other than as specifically contemplated by a written agreement with us. These materials are based on information provided by or on behalf of the Company and/or other potential transaction participants, from public sources or otherwise reviewed by us. We assume no responsibility for independent investigation or verification of such information (including, without limitation, data from third party suppliers) and have relied on such information being complete and accurate in all material respects. To the extent such information includes estimates and forecasts of future financial performance prepared by or reviewed with the managements of the Company and/or other potential transaction participants or obtained from public sources, we have assumed that such estimates and forecasts have been reasonably prepared on bases reflecting the best currently available estimates and judgments of such managements (or, with respect to estimates and forecasts obtained from public sources, represent reasonable estimates). No representation or warranty, express or implied, is made as to the accuracy or completeness of such information and nothing contained herein is, or shall be relied upon as, a representation, whether as to the past, the present or the future. These materials were designed for use by specific persons familiar with the business and affairs of the Company and are being furnished and should be considered only in connection with other information, oral or written, being provided by us in connection herewith. These materials are not intended to provide the sole basis for evaluating, and should not be considered a recommendation with respect to, any transaction or other matter. These materials do not constitute an offer or solicitation to sell or purchase any securities and are not a commitment by Bank of America Corporation or any of its affiliates to provide or arrange any financing for any transaction or to purchase any security in connection therewith. These materials are for discussion purposes only and are subject to our review and assessment from a legal, compliance, accounting policy and risk perspective, as appropriate, following our discussion with the Company. We assume no obligation to update or otherwise revise these materials. These materials have not been prepared with a view toward public disclosure under applicable securities laws or otherwise, are intended for the benefit and use of the Company, and may not be reproduced, disseminated, quoted or referred to, in whole or in part, without our prior written consent. These materials may not reflect information known to other professionals in other business areas of Bank of America Corporation and its affiliates.

Bank of America Corporation and its affiliates (collectively, the “BAC Group”) comprise a full service securities firm and commercial bank engaged in securities, commodities and derivatives trading, foreign exchange and other brokerage activities, and principal investing as well as providing investment, corporate and private banking, asset and investment management, financing and strategic advisory services and other commercial services and products to a wide range of corporations, governments and individuals, domestically and offshore, from which conflicting interests or duties, or a perception thereof, may arise. In the ordinary course of these activities, parts of the BAC Group at any time may invest on a principal basis or manage funds that invest, make or hold long or short positions, finance positions or trade or otherwise effect transactions, for their own accounts or the accounts of customers, in debt, equity or other securities or financial instruments (including derivatives, bank loans or other obligations) of the Company, potential counterparties or any other company that may be involved in a transaction. Products and services that may be referenced in the accompanying materials may be provided through one or more affiliates of Bank of America Corporation. We have adopted policies and guidelines designed to preserve the independence of our research analysts. These policies prohibit employees from offering research coverage, a favorable research rating or a specific price target or offering to change a research rating or price target as consideration for or an inducement to obtain business or other compensation. We are required to obtain, verify and record certain information that identifies the Company, which information includes the name and address of the Company and other information that will allow us to identify the Company in accordance, as applicable, with the USA Patriot Act (Title III of Pub. L. 107-56 (signed into law October 26, 2001) and such other laws, rules and regulations as applicable within and outside the United States.

We do not provide legal, compliance, tax or accounting advice. Accordingly, any statements contained herein as to tax matters were neither written nor intended by us to be used and cannot be used by any taxpayer for the purpose of avoiding tax penalties that may be imposed on such taxpayer. If any person uses or refers to any such tax statement in promoting, marketing or recommending a partnership or other entity, investment plan or arrangement to any taxpayer, then the statement expressed herein is being delivered to support the promotion or marketing of the transaction or matter addressed and the recipient should seek advice based on its particular circumstances from an independent tax advisor. Notwithstanding anything that may appear herein or in other materials to the contrary, the Company shall be permitted to disclose the tax treatment and tax structure of a transaction (including any materials, opinions or analyses relating to such tax treatment or tax structure, but without disclosure of identifying information or, except to the extent relating to such tax structure or tax treatment, any nonpublic commercial or financial information) on and after the earliest to occur of the date of (i) public announcement of discussions relating to such transaction, (ii) public announcement of such transaction or (iii) execution of a definitive agreement (with or without conditions) to enter into such transaction; provided, however, that if such transaction is not consummated for any reason, the provisions of this sentence shall cease to apply. ©2012 Bank of America Corporation

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Contact Us

For information relating to the content within this guide, or any other areas for which you require

assistance, please contact the Hedge Fund Consulting Team at Bank of America Merrill Lynch.

Our contact details are below—we look forward to hearing from you.

Cary Goldstein Chris Throop

+1.646.855.4029 +1.646.855.0612

[email protected] [email protected]

Bank of America Merrill Lynch Hedge Fund Consulting

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