Newly Adopted Fund Manager Reporting Obligations

On October 26, 2011, the Securities and Exchange Commission (the "SEC") adopted new Rule 204(b)-1 under the Investment Advisers Act of 1940, as amended (the "Advisers Act"), which requires certain federally registered investment advisers that serve as managers to hedge funds and private equity funds to make periodic filings on new Form PF with the SEC. The rule, along with companion Rule 4.27 under the Commodity Exchange Act, had been jointly proposed by the SEC and the Commodity Futures Trading Commission ("CFTC") to implement Sections 404 and 406 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, enacted July 21, 2010 ("Dodd-Frank"). The SEC and CFTC stated that the design of Form PF is intended to provide the Financial Stability Oversight Council (the "FSOC") with information important to the FSOC's understanding and monitoring of systemic risk in the private fund industry.