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Form Sec 1707 - Uniform Application For Investment Adviser Registration - Securities And Exchange Commission Page 16

Your Name _______________________________ CRD Number _______________

FORM ADV

Part 1A

Date _____________________________________ SEC 801-Number ____________

Page 16 of 16

For purposes of this Item 12 only:

•

Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In

determining your or another person’s total assets, you may use the total assets shown on a current balance sheet

(but use total assets reported on a consolidated balance sheet with subsidiaries included, if that amount is

larger).

•

Control means the power to direct or cause the direction of the management or policies of a person,

whether through ownership of securities, by contract, or otherwise. Any person that directly or indirectly has

the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent or more of the profits, of

another person is presumed to control the other person.

Yes

A. Did you have total assets of $5 million or more on the last day of your most recent

⁪

fiscal year?

If “yes,” you do not need to answer Items 12.B. and 12.C.

B. Do you:

(1) control another investment adviser that had assets under management of

⁪

$25 million or more on the last day of its most recent fiscal year?

(2) control another person (other than a natural person) that had total assets of

⁪

$5 million or more on the last day of its most recent fiscal year?

C. Are you:

(1) controlled by or under common control with another investment adviser

that had assets under management of $25 million or more on the last day of

⁪

its most recent fiscal year?

(2) controlled by or under common control with another person (other than a

natural person) that had total assets of $5 million or more on the last day of its

⁪

most recent fiscal year?

Form Sec 1707 - Uniform Application For Investment Adviser Registration - Securities And Exchange Commission Page 16