IACCP 2 General Advisors Act QUESTIONS WITH COMPLETE SOLUTIONS

Commodity Trading advisors Family Offices Intrastate advisor ANSWER-An advisor whose clients are within the same state as the adviser’s principal business office AND that does not provide advice or issue reports about securities listed on any national exchange What is the registration AUM threshold for private fund advisors? ANSWER-$150 million Private Fund Advisor ANSWER-1) All clients that are US persons are Qualifying Private funds and 2) all assets it manages at any place of business in the US are solely attributable to private funds and have a total value of less that $150 million Qualifying Private Fund ANSWER-includes an issuer that would be an “investment company” but for the exclusions from Sections 3c1 or 3c7 Foreign Private Advisor ANSWER-1) has no place of business in the US 2) has fewer than 15 clients & investors in the US 3) has aggregate AUM attributable to clients & funds in the US of less than $25 million and 4) does not hold itself out generally to the public What is the exception to a “place of business”? ANSWER-If the only functions performed are back office and administrative and if the location is not advertised. Venture Capital Fund ANSWER-Required to have ALL: 1) pursues a venture capital strategy; 2) makes qualifying investments; 3) limits leverage; 4) offers no broad redemption rights; 5) has not registered under the Investment Company Act or registered as a BDC; 6) is a “private fund” What is the maximum a VC fund may hold in non-qualifying assets? ANSWER-20%