AUMdb

← Lloyds Bank Plc

Form ADV (full filing)

as of Apr 08, 2026 · 1.13 MB · sha256 3c04ec3c39b9…

Extracted text

Machine-extracted from the archived PDF. Layout artifacts are expected.

                                                                           FORM ADV
     UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS

Primary Business Name: LLOYDS BANK PLC                                                                                                           CRD Number: 161257
Other-Than-Annual Amendment - All Sections                                                                                                                Rev. 10/2021
4/8/2026 6:42:24 AM



WARNING: Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal
         prosecution. You must keep this form updated by filing periodic amendments. See Form ADV General Instruction 4.
Item 1 Identifying Information

Responses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the
information in Item 1 should be provided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.

A.   Your full legal name (if you are a sole proprietor, your last, first, and middle names):
     LLOYDS BANK PLC


B.   (1) Name under which you primarily conduct your advisory business, if different from Item 1.A.
     LLOYDS BANK PLC

     List on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.


     (2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box

     If you check this box, complete a Schedule R for each relying adviser.


C.   If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the
     name change is of
        your legal name or        your primary business name:


D.   (1) If you are registered with the SEC as an investment adviser, your SEC file number:
     (2) If you report to the SEC as an exempt reporting adviser, your SEC file number: 802-75227
     (3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers:
     CIK Number
     1167831



E.   (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 161257

     If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.


     (2) If you have additional CRD Numbers, your additional CRD numbers:
                                                                              No Information Filed



F.   Principal Office and Place of Business
     (1) Address (do not use a P.O. Box):
         Number and Street 1:                                          Number and Street 2:
         33 OLD BROAD STREET
         City:                           State:                        Country:                                    ZIP+4/Postal Code:
         LONDON                                                        United Kingdom                              EC2N 1HZ

         If this address is a private residence, check this box:

         List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If
         you are applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to
         which you are applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or
         if you are reporting to the SEC as an exempt reporting adviser, list the largest twenty-five offices in terms of numbers of employees as of the end of your
         most recently completed fiscal year.

     (2) Days of week that you normally conduct business at your principal office and place of business:
           Monday - Friday    Other:

         Normal business hours at this location:
         9.00 AM TO 17.00 PM
     (3) Telephone number at this location:
         +44 207 626 1500
     (4) Facsimile number at this location, if any:
     (5) What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of
         the end of your most recently completed fiscal year?
         0


G.   Mailing address, if different from your principal office and place of business address:

     Number and Street 1:                                                   Number and Street 2:
     City:                          State:                                  Country:                       ZIP+4/Postal Code:


     If this address is a private residence, check this box:


H.   If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:

     Number and Street 1:                                                    Number and Street 2:
     City:                          State:                                   Country:                      ZIP+4/Postal Code:

                                                                                                                                                                      Yes No
I.   Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and
     LinkedIn)?


     If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D.
     If a website address serves as a portal through which to access other information you have published on the web, you may list the portal without listing
     addresses for all of the other information. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly
     available social media platforms where you do not control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the
     addresses of employee accounts on publicly available social media platforms.


J.   Chief Compliance Officer
     (1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact
     information for your Chief Compliance Officer, if you have one. If not, you must complete Item 1.K. below.

     Name:                                                                   Other titles, if any:
     Telephone number:                                                       Facsimile number, if any:
     Number and Street 1:                                                    Number and Street 2:
     City:                          State:                                   Country:                      ZIP+4/Postal Code:


     Electronic mail (e-mail) address, if Chief Compliance Officer has one:


     (2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered
     under the Investment Company Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS
     Employer Identification Number (if any):
     Name:
     IRS Employer Identification Number:


K.   Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions
     about this Form ADV, you may provide that information here.

     Name:                                                                  Titles:
     Telephone number:                                                      Facsimile number, if any:
     Number and Street 1:                                                   Number and Street 2:
     City:                          State:                                  Country:                       ZIP+4/Postal Code:


     Electronic mail (e-mail) address, if contact person has one:

                                                                                                                                                                      Yes No
L.   Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law,
     somewhere other than your principal office and place of business?


     If "yes," complete Section 1.L. of Schedule D.
                                                                                                                                                                      Yes No
M.   Are you registered with a foreign financial regulatory authority?


     Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial
     regulatory authority. If "yes," complete Section 1.M. of Schedule D.
                                                                                                                                                                      Yes No
N.   Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?

                                                                                                                                                                      Yes No
O.   Did you have $1 billion or more in assets on the last day of your most recent fiscal year?
     If yes, what is the approximate amount of your assets:
          $1 billion to less than $10 billion

          $10 billion to less than $50 billion
          $50 billion or more




     For purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using
     the total assets shown on the balance sheet for your most recent fiscal year end.


P.   Provide your Legal Entity Identifier if you have one:
     H7FNTJ4851HG0EXQ1Z70

     A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity
     identifier.




SECTION 1.B. Other Business Names


                                                                       No Information Filed



SECTION 1.F. Other Offices


                                                                       No Information Filed



SECTION 1.I. Website Addresses

 List your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not
 limited to, Twitter, Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available
 social media platform.


 Address of Website/Account on Publicly Available Social Media Platform:      https://www.LinkedIn.com Lloyds Bank Corporate & Institutional




 Address of Website/Account on Publicly Available Social Media Platform:      https://www.LinkedIn.com Lloyds Bank Business & Commercial




 Address of Website/Account on Publicly Available Social Media Platform:      https://www.LinkedIn.com Lloyds Bank International




 Address of Website/Account on Publicly Available Social Media Platform:      https://www.Facebook.com Lloyds Bank




 Address of Website/Account on Publicly Available Social Media Platform:      https://www.Facebook.com Lloyds Bank Business




 Address of Website/Account on Publicly Available Social Media Platform:      https://www.Instagram.com Lloydsbank




 Address of Website/Account on Publicly Available Social Media Platform:      https://www.Instagram.com Lloydsbankbusiness




 Address of Website/Account on Publicly Available Social Media Platform:      https://www.Twitter.com Lloydsbank




 Address of Website/Account on Publicly Available Social Media Platform:      https://www.Twitter.com Lloydsbankbiz




 Address of Website/Account on Publicly Available Social Media Platform:      https://www.Tiktok.com Lloyds




 Address of Website/Account on Publicly Available Social Media Platform:      https://www.YouTube.com Lloydsbusiness
 Address of Website/Account on Publicly Available Social Media Platform:   https://www.YouTube.com Lloydsbankonline




 Address of Website/Account on Publicly Available Social Media Platform:   https://www.lloydsbankacademy.co.uk




 Address of Website/Account on Publicly Available Social Media Platform:   http://www.lloydsbank.com




 Address of Website/Account on Publicly Available Social Media Platform:   https://secure.lloydsbank.co.uk




SECTION 1.L. Location of Books and Records


                                                                     No Information Filed



SECTION 1.M. Registration with Foreign Financial Regulatory Authorities

 List the name and country, in English, of each foreign financial regulatory authority with which you are registered. You must complete a separate Schedule D
 Section 1.M. for each foreign financial regulatory authority with whom you are registered.


 Name of Country/Foreign Financial Regulatory Authority:
 Canada - Alberta Securities Commission


 Other:




 Name of Country/Foreign Financial Regulatory Authority:
 Canada - British Columbia Securities Commission


 Other:




 Name of Country/Foreign Financial Regulatory Authority:
 Canada - Ontario Securities Commission


 Other:




 Name of Country/Foreign Financial Regulatory Authority:
 Canada - Quebec, Financial Markets Authority


 Other:




 Name of Country/Foreign Financial Regulatory Authority:
 Denmark - Danish Financial Supervisory Authority


 Other:




 Name of Country/Foreign Financial Regulatory Authority:
 Luxembourg, Grand Duchy of - Commission to Surveillance of the Finance Sector


 Other:
 Name of Country/Foreign Financial Regulatory Authority:
 Other


 Other:
 BELGIUM - FINANCIAL SERVICES AND MARKETS AUTHORITY




 Name of Country/Foreign Financial Regulatory Authority:
 Other


 Other:
 BANK OF ITALY




 Name of Country/Foreign Financial Regulatory Authority:
 Other


 Other:
 NORWAY - THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY




 Name of Country/Foreign Financial Regulatory Authority:
 United Kingdom - Financial Conduct Authority


 Other:




 Name of Country/Foreign Financial Regulatory Authority:
 United Kingdom - Prudential Regulation Authority


 Other:




Item 2 SEC Registration/Reporting
SEC Reporting by Exempt Reporting Advisers
B.   Complete this Item 2.B. only if you are reporting to the SEC as an exempt reporting adviser. Check all that apply. You:
          (1) qualify for the exemption from registration as an adviser solely to one or more venture capital funds, as defined in rule 203(l)-1;
          (2)   qualify for the exemption from registration because you act solely as an adviser to private funds and have assets under management, as defined
                in rule 203(m)-1, in the United States of less than $150 million;
          (3)   act solely as an adviser to private funds but you are no longer eligible to check box 2.B.(2) because you have assets under management, as
                defined in rule 203(m)-1, in the United States of $150 million or more.


          If you check box (2) or (3), complete Section 2.B. of Schedule D.



SECTION 2.B. Private Fund Assets
If you check Item 2.B.(2) or (3), what is the amount of the private fund assets that you manage?                                                               $0


NOTE: "Private fund assets" has the same meaning here as it has under rule 203(m)-1. If you are an investment adviser with its principal office and place of
business outside the United States only include private fund assets that you manage at a place of business in the United States.




Item 3 Form of Organization
If you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.
A.   How are you organized?
           Corporation

           Sole Proprietorship

           Limited Liability Partnership (LLP)
           Partnership

           Limited Liability Company (LLC)

           Limited Partnership (LP)

           Other (specify):


     If you are changing your response to this Item, see Part 1A Instruction 4.


B.   In what month does your fiscal year end each year?
     DECEMBER


C.   Under the laws of what state or country are you organized?
     State Country
             United Kingdom


     If you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the
     name of the state or country where you reside.

     If you are changing your response to this Item, see Part 1A Instruction 4.




Item 6 Other Business Activities

In this Item, we request information about your firm's other business activities.

A.   You are actively engaged in business as a (check all that apply):
           (1)    broker-dealer (registered or unregistered)
           (2)    registered representative of a broker-dealer
           (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
           (4)    futures commission merchant
           (5)    real estate broker, dealer, or agent
           (6)    insurance broker or agent
           (7)    bank (including a separately identifiable department or division of a bank)
           (8)    trust company
           (9)    registered municipal advisor
           (10)   registered security-based swap dealer
           (11)   major security-based swap participant
           (12)   accountant or accounting firm
           (13)   lawyer or law firm
           (14)   other financial product salesperson (specify): PAYMENTS MERCHANT


     If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.
                                                                                                                                                             Yes No
B.   (1)   Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?

     (2)   If yes, is this other business your primary business?

           If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.
                                                                                                                                                             Yes No
     (3)   Do you sell products or provide services other than investment advice to your advisory clients?


           If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.




SECTION 6.A. Names of Your Other Businesses

 If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


 Other Business Name: BLACKHORSE SPECIALIST MORTGAGES


 Other line(s) of business in which you engage using this name (check all that apply):
     (1)    broker-dealer (registered or unregistered)
     (2)    registered representative of a broker-dealer
     (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
     (4)    futures commission merchant
     (5)    real estate broker, dealer, or agent
     (6)    insurance broker or agent
     (7)    bank (including a separately identifiable department or division of a bank)
    (8)    trust company
    (9)    registered municipal advisor
    (10)   registered security-based swap dealer
    (11)   major security-based swap participant
    (12)   accountant or accounting firm
    (13)   lawyer or law firm
    (14)   other financial product salesperson (specify):




If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


Other Business Name: LLOYDS


Other line(s) of business in which you engage using this name (check all that apply):
    (1)    broker-dealer (registered or unregistered)
    (2)    registered representative of a broker-dealer
    (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
    (4)    futures commission merchant
    (5)    real estate broker, dealer, or agent
    (6)    insurance broker or agent
    (7)    bank (including a separately identifiable department or division of a bank)
    (8)    trust company
    (9)    registered municipal advisor
    (10)   registered security-based swap dealer
    (11)   major security-based swap participant
    (12)   accountant or accounting firm
    (13)   lawyer or law firm
    (14)   other financial product salesperson (specify):




If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


Other Business Name: LLOYDS BANK


Other line(s) of business in which you engage using this name (check all that apply):
    (1)    broker-dealer (registered or unregistered)
    (2)    registered representative of a broker-dealer
    (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
    (4)    futures commission merchant
    (5)    real estate broker, dealer, or agent
    (6)    insurance broker or agent
    (7)    bank (including a separately identifiable department or division of a bank)
    (8)    trust company
    (9)    registered municipal advisor
    (10)   registered security-based swap dealer
    (11)   major security-based swap participant
    (12)   accountant or accounting firm
    (13)   lawyer or law firm
    (14)   other financial product salesperson (specify):




If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


Other Business Name: LLOYDS BANK CARDNET


Other line(s) of business in which you engage using this name (check all that apply):
    (1)    broker-dealer (registered or unregistered)
    (2)    registered representative of a broker-dealer
    (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
    (4)    futures commission merchant
    (5)    real estate broker, dealer, or agent
    (6)    insurance broker or agent
    (7)    bank (including a separately identifiable department or division of a bank)
    (8)    trust company
    (9)    registered municipal advisor
    (10)   registered security-based swap dealer
    (11)   major security-based swap participant
    (12)   accountant or accounting firm
    (13)   lawyer or law firm
    (14)   other financial product salesperson (specify): PAYMENTS MERCHANT




If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


Other Business Name: LLOYDS BANK PRIVATE BANKING


Other line(s) of business in which you engage using this name (check all that apply):
    (1)    broker-dealer (registered or unregistered)
    (2)    registered representative of a broker-dealer
    (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
    (4)    futures commission merchant
    (5)    real estate broker, dealer, or agent
    (6)    insurance broker or agent
    (7)    bank (including a separately identifiable department or division of a bank)
    (8)    trust company
    (9)    registered municipal advisor
    (10)   registered security-based swap dealer
    (11)   major security-based swap participant
    (12)   accountant or accounting firm
    (13)   lawyer or law firm
    (14)   other financial product salesperson (specify):




If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


Other Business Name: LLOYDS BANK SPECIALIST MORTGAGE SOLUTIONS


Other line(s) of business in which you engage using this name (check all that apply):
    (1)    broker-dealer (registered or unregistered)
    (2)    registered representative of a broker-dealer
    (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
    (4)    futures commission merchant
    (5)    real estate broker, dealer, or agent
    (6)    insurance broker or agent
    (7)    bank (including a separately identifiable department or division of a bank)
    (8)    trust company
    (9)    registered municipal advisor
    (10)   registered security-based swap dealer
    (11)   major security-based swap participant
    (12)   accountant or accounting firm
    (13)   lawyer or law firm
    (14)   other financial product salesperson (specify):




If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


Other Business Name: LLOYDS CARDNET


Other line(s) of business in which you engage using this name (check all that apply):
    (1)    broker-dealer (registered or unregistered)
    (2)    registered representative of a broker-dealer
    (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
    (4)    futures commission merchant
    (5)    real estate broker, dealer, or agent
    (6)    insurance broker or agent
    (7)    bank (including a separately identifiable department or division of a bank)
    (8)    trust company
    (9)    registered municipal advisor
    (10)   registered security-based swap dealer
    (11)   major security-based swap participant
    (12)   accountant or accounting firm
    (13)   lawyer or law firm
    (14) other financial product salesperson (specify): PAYMENT MERCHANT




If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


Other Business Name: LLOYDS PRIVATE BANKING


Other line(s) of business in which you engage using this name (check all that apply):
    (1)    broker-dealer (registered or unregistered)
    (2)    registered representative of a broker-dealer
    (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
    (4)    futures commission merchant
    (5)    real estate broker, dealer, or agent
    (6)    insurance broker or agent
    (7)    bank (including a separately identifiable department or division of a bank)
    (8)    trust company
    (9)    registered municipal advisor
    (10)   registered security-based swap dealer
    (11)   major security-based swap participant
    (12)   accountant or accounting firm
    (13)   lawyer or law firm
    (14)   other financial product salesperson (specify):




If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


Other Business Name: LLOYDS SPECIALIST MORTGAGE SOLUTIONS


Other line(s) of business in which you engage using this name (check all that apply):
    (1)    broker-dealer (registered or unregistered)
    (2)    registered representative of a broker-dealer
    (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
    (4)    futures commission merchant
    (5)    real estate broker, dealer, or agent
    (6)    insurance broker or agent
    (7)    bank (including a separately identifiable department or division of a bank)
    (8)    trust company
    (9)    registered municipal advisor
    (10)   registered security-based swap dealer
    (11)   major security-based swap participant
    (12)   accountant or accounting firm
    (13)   lawyer or law firm
    (14)   other financial product salesperson (specify):




If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


Other Business Name: MAYFAIR PRIVATE BANKING


Other line(s) of business in which you engage using this name (check all that apply):
    (1)    broker-dealer (registered or unregistered)
    (2)    registered representative of a broker-dealer
    (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
    (4)    futures commission merchant
    (5)    real estate broker, dealer, or agent
    (6)    insurance broker or agent
    (7)    bank (including a separately identifiable department or division of a bank)
    (8)    trust company
    (9)    registered municipal advisor
    (10)   registered security-based swap dealer
    (11)   major security-based swap participant
    (12)   accountant or accounting firm
    (13)   lawyer or law firm
    (14)   other financial product salesperson (specify):
 If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


 Other Business Name: MBNA


 Other line(s) of business in which you engage using this name (check all that apply):
     (1)    broker-dealer (registered or unregistered)
     (2)    registered representative of a broker-dealer
     (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
     (4)    futures commission merchant
     (5)    real estate broker, dealer, or agent
     (6)    insurance broker or agent
     (7)    bank (including a separately identifiable department or division of a bank)
     (8)    trust company
     (9)    registered municipal advisor
     (10)   registered security-based swap dealer
     (11)   major security-based swap participant
     (12)   accountant or accounting firm
     (13)   lawyer or law firm
     (14)   other financial product salesperson (specify):




 If you are actively engaged in other business using a different name, provide that name and the other line(s) of business.


 Other Business Name: SCOTTISH WIDOWS BANK


 Other line(s) of business in which you engage using this name (check all that apply):
     (1)    broker-dealer (registered or unregistered)
     (2)    registered representative of a broker-dealer
     (3)    commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
     (4)    futures commission merchant
     (5)    real estate broker, dealer, or agent
     (6)    insurance broker or agent
     (7)    bank (including a separately identifiable department or division of a bank)
     (8)    trust company
     (9)    registered municipal advisor
     (10)   registered security-based swap dealer
     (11)   major security-based swap participant
     (12)   accountant or accounting firm
     (13)   lawyer or law firm
     (14)   other financial product salesperson (specify):




SECTION 6.B.(2) Description of Primary Business
Describe your primary business (not your investment advisory business):


If you engage in that business under a different name, provide that name:




SECTION 6.B.(3) Description of Other Products and Services
Describe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above.
LLOYDS BANK PLC ALSO PROVIDES HEDGING, ADMINISTRATIVE, LIQUIDITY AND OTHER LENDING FACILITIES (WHICH MAY INCLUDE REPURCHASE
ARRANGEMENTS) TO CANCARA THE PRIVATE FUND DESCRIBED IN SECTION 7B(1)


If you engage in that business under a different name, provide that name:




Item 7 Financial Industry Affiliations

In this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may
occur between you and your clients.

A.   This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your
     advisory affiliates and any person that is under common control with you.
     You have a related person that is a (check all that apply):
         (1)   broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)
         (2)   other investment adviser (including financial planners)
           (3)     registered municipal advisor
           (4)     registered security-based swap dealer
           (5)     major security-based swap participant
           (6)     commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
           (7)     futures commission merchant
           (8)     banking or thrift institution
           (9)     trust company
           (10)    accountant or accounting firm
           (11)    lawyer or law firm
           (12)    insurance company or agency
           (13)    pension consultant
           (14)    real estate broker or dealer
           (15)    sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
           (16)    sponsor, general partner, managing member (or equivalent) of pooled investment vehicles

      Note that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a
      broker-dealer. The number of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your
      firm's employees who are registered representatives of a broker-dealer should be disclosed under Item 5.B.(2).

      Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete
      Section 7.A. in Schedule D for your relying advisers. You should complete a Schedule R for each relying adviser.

      For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of
      Schedule D.

      You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with
      advisory services you provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the
      related person, and the related person does not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the
      related person; and (5) you have no reason to believe that your relationship with the related person otherwise creates a conflict of interest with your clients.

      You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your
      clients (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be
      operationally independent under rule 206(4)-2 of the Advisers Act.



SECTION 7.A. Financial Industry Affiliations

Complete a separate Schedule D Section 7.A. for each related person listed in Item 7.A.


1.   Legal Name of Related Person:
     BANK OF SCOTLAND PLC


2.   Primary Business Name of Related Person:
     BANK OF SCOTLAND PLC


3.   Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
     -
     or
     Other


4.   Related Person's
     (a)   CRD Number (if any):


     (b)   CIK Number(s) (if any):
           CIK Number
             897309




5.   Related Person is: (check all that apply)
     (a)          broker-dealer, municipal securities dealer, or government securities broker or dealer
     (b)          other investment adviser (including financial planners)
     (c)          registered municipal advisor
     (d)          registered security-based swap dealer
     (e)          major security-based swap participant
     (f)          commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
     (g)          futures commission merchant
     (h)          banking or thrift institution
     (i)          trust company
     (j)          accountant or accounting firm
     (k)          lawyer or law firm
     (l)          insurance company or agency
     (m)        pension consultant
     (n)        real estate broker or dealer
     (o)        sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
     (p)        sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
                                                                                                                                                              Yes No
6.   Do you control or are you controlled by the related person?


7.   Are you and the related person under common control?


8.   (a)   Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
     (b)   If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
           presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
           to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
     (c)   If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
           Number and Street 1:                                                Number and Street 2:
           City:                         State:                                Country:                   ZIP+4/Postal Code:
           If this address is a private residence, check this box:
                                                                                                                                                              Yes No
9.   (a)   If the related person is an investment adviser, is it exempt from registration?

     (b)   If the answer is yes, under what exemption?


10. (a)    Is the related person registered with a foreign financial regulatory authority ?
     (b)   If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
           Name of Country/English Name of Foreign Financial Regulatory Authority
             Luxembourg, Grand Duchy of - Commission to Surveillance of the Finance Sector
             Other - BELGIUM - FINANCIAL SERVICES AND MARKETS AUTHORITY
             Other - NORWAY - THE FINANCIAL SERVICES AUTHORITY OF NORWAY
             United Kingdom - Financial Conduct Authority
             United Kingdom - Prudential Regulation Authority

11. Do you and the related person share any supervised persons?


12. Do you and the related person share the same physical location?




1.   Legal Name of Related Person:
     LLOYDS BANK CORPORATE MARKETS WERTPAPIERHANDELSBANK GMBH


2.   Primary Business Name of Related Person:
     LLOYDS BANK CORPORATE MARKETS WERTPAPIERHANDELSBANK GMBH


3.   Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
     -
     or
     Other


4.   Related Person's
     (a)   CRD Number (if any):


     (b)   CIK Number(s) (if any):
                                                                               No Information Filed



5.   Related Person is: (check all that apply)
     (a)        broker-dealer, municipal securities dealer, or government securities broker or dealer
     (b)        other investment adviser (including financial planners)
     (c)        registered municipal advisor
     (d)         registered security-based swap dealer
     (e)        major security-based swap participant
     (f)        commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
     (g)        futures commission merchant
     (h)        banking or thrift institution
     (i)        trust company
     (j)        accountant or accounting firm
     (k)        lawyer or law firm
     (l)        insurance company or agency
     (m)        pension consultant
     (n)        real estate broker or dealer
     (o)        sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
     (p)        sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
                                                                                                                                                              Yes No
6.   Do you control or are you controlled by the related person?


7.   Are you and the related person under common control?


8.   (a)   Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
     (b)   If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
           presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
           to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
     (c)   If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
           Number and Street 1:                                                Number and Street 2:
           City:                         State:                                Country:                   ZIP+4/Postal Code:
           If this address is a private residence, check this box:
                                                                                                                                                              Yes No
9.   (a)   If the related person is an investment adviser, is it exempt from registration?

     (b)   If the answer is yes, under what exemption?


10. (a)    Is the related person registered with a foreign financial regulatory authority ?
     (b)   If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
           Name of Country/English Name of Foreign Financial Regulatory Authority
             Germany - German Federal Financial Supervisory Agency
             Other - GERMANY - DEUTSCHE BUNDESBANK

11. Do you and the related person share any supervised persons?


12. Do you and the related person share the same physical location?




1.   Legal Name of Related Person:
     LLOYDS BANK CORPORATE MARKETS PLC


2.   Primary Business Name of Related Person:
     LLOYDS BANK CORPORATE MARKETS PLC


3.   Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
     -
     or
     Other


4.   Related Person's
     (a)   CRD Number (if any):


     (b)   CIK Number(s) (if any):
                                                                               No Information Filed



5.   Related Person is: (check all that apply)
     (a)        broker-dealer, municipal securities dealer, or government securities broker or dealer
     (b)        other investment adviser (including financial planners)
     (c)        registered municipal advisor
     (d)        registered security-based swap dealer
     (e)        major security-based swap participant
     (f)        commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
     (g)        futures commission merchant
     (h)        banking or thrift institution
     (i)        trust company
     (j)        accountant or accounting firm
     (k)        lawyer or law firm
     (l)        insurance company or agency
     (m)        pension consultant
     (n)        real estate broker or dealer
     (o)        sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
     (p)        sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
                                                                                                                                                              Yes No
6.   Do you control or are you controlled by the related person?


7.   Are you and the related person under common control?


8.   (a)   Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
     (b)   If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
           presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
           to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
     (c)   If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
           Number and Street 1:                                                Number and Street 2:
           City:                         State:                                Country:                   ZIP+4/Postal Code:
           If this address is a private residence, check this box:
                                                                                                                                                              Yes No
9.   (a)   If the related person is an investment adviser, is it exempt from registration?

     (b)   If the answer is yes, under what exemption?


10. (a)    Is the related person registered with a foreign financial regulatory authority ?
     (b)   If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
           Name of Country/English Name of Foreign Financial Regulatory Authority
             Australia - Australian Securities and Investments Commission
             Canada - Alberta Securities Commission
             Canada - British Columbia Securities Commission
             Canada - Ontario Securities Commission
             Denmark - Danish Financial Supervisory Authority
             Guernsey - Guernsey Financial Services Commission
             Jersey - Jersey Financial Services Commission
             Luxembourg, Grand Duchy of - Commission to Surveillance of the Finance Sector
             Other - BELGIUM - FINANCIAL SERVICES AND MARKETS AUTHORITY
             Other - CANADA - QUEBEC SECURITIES COMMISSION
             Other - ISLE OF MAN - FINANCIAL SERVICE AUTHORITY
             Other - ITALY - BANK OF ITALY
             Other - NEW ZEALAND - RESERVE BANK OF NEW ZEALAND / COUNCIL OF FINANCIAL REGULATORS
             United Kingdom - Financial Conduct Authority
             United Kingdom - Prudential Regulation Authority

11. Do you and the related person share any supervised persons?


12. Do you and the related person share the same physical location?




1.   Legal Name of Related Person:
     LLOYDS SECURITIES INC.


2.   Primary Business Name of Related Person:
     LLOYDS SECURITIES


3.   Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
     -
     or
     Other


4.   Related Person's
     (a)   CRD Number (if any):


     (b)   CIK Number(s) (if any):
           CIK Number
             1496217




5.   Related Person is: (check all that apply)
     (a)        broker-dealer, municipal securities dealer, or government securities broker or dealer
     (b)        other investment adviser (including financial planners)
     (c)        registered municipal advisor
      (d)        registered security-based swap dealer
      (e)       major security-based swap participant
      (f)       commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
      (g)       futures commission merchant
      (h)       banking or thrift institution
      (i)       trust company
      (j)       accountant or accounting firm
      (k)       lawyer or law firm
      (l)       insurance company or agency
      (m)        pension consultant
      (n)        real estate broker or dealer
      (o)       sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
      (p)       sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
                                                                                                                                                                  Yes No
6.    Do you control or are you controlled by the related person?


7.    Are you and the related person under common control?


8.    (a)   Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
      (b)   If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
            presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
            to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
      (c)   If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
            Number and Street 1:                                                 Number and Street 2:
            City:                         State:                                 Country:                       ZIP+4/Postal Code:
            If this address is a private residence, check this box:
                                                                                                                                                                  Yes No
9.    (a)   If the related person is an investment adviser, is it exempt from registration?

      (b)   If the answer is yes, under what exemption?


10. (a)     Is the related person registered with a foreign financial regulatory authority ?
      (b)   If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
            Name of Country/English Name of Foreign Financial Regulatory Authority
            Canada - Alberta Securities Commission
            Canada - British Columbia Securities Commission
            Canada - Manitoba Securities Commission
            Canada - Ontario Securities Commission
            Canada - Quebec, Financial Markets Authority
            Other - CANADA - FINANCIAL CONSUMER AGENCY FOR CANADA (FCAC)
            Other - CANADA - OFFICE OF THE SUPERINTENDENT OF FINANCIAL INSTITUTIONS (OSFI)

11. Do you and the related person share any supervised persons?


12. Do you and the related person share the same physical location?



Item 7 Private Fund Reporting

                                                                                                                                                                   Yes No

B. Are you an adviser to any private fund?


     If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next
     sentence and in Instruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt
     reporting adviser, and another SEC-registered adviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section
     7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser), do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must,
     instead, complete Section 7.B.(2) of Schedule D.

     In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical
     code, or similar designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or
     designation in place of the fund's name.




SECTION 7.B.(1) Private Fund Reporting


                                                                      Funds per Page: 15       Total Funds: 1
A. PRIVATE FUND


Information About the Private Fund


1.   (a) Name of the private fund:
         CANCARA ASSET SECURITISATION LIMITED - ABCP PROGRAMME
     (b) Private fund identification number:
         (include the "805-" prefix also)
         805-3259637444




2.   Under the laws of what state or country is the private fund organized:
         State:                                                         Country:
                                                                        Jersey


3.   (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
     Name of General Partner, Manager, Trustee, or Director
     NADIA TREHIOU
     SHANE HOLLYWOOD



     (b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
                                                                         No Information Filed



4.   The private fund (check all that apply; you must check at least one):
         (1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
         (2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940


5.   List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
     Name of Country/English Name of Foreign Financial Regulatory Authority
     Jersey - Jersey Financial Services Commission

                                                                                                                                                      Yes No
6.   (a) Is this a "master fund" in a master-feeder arrangement?

     (b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
                                                                         No Information Filed


                                                                                                                                                      Yes No
     (c) Is this a "feeder fund" in a master-feeder arrangement?

     (d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
         Name of private fund:


         Private fund identification number:
         (include the "805-" prefix also)




     NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1)
     for the master-feeder arrangement or reporting on the funds separately.


7.   If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of
     the feeder funds answer the following questions:



                                                                         No Information Filed




     NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their
     assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued
     multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
                                                                                                                                                      Yes No
8.   (a) Is this private fund a "fund of funds"?

     NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment
     vehicles, regardless of whether they are also private funds or registered investment companies.
     (b) If yes, does the private fund invest in funds managed by you or by a related person?



                                                                                                                                                    Yes No
9.   During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment
     Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?


10. What type of fund is the private fund?

          hedge fund    liquidity fund    private equity fund     real estate fund     securitized asset fund   venture capital fund   Other private fund:


     NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.


11. Current gross asset value of the private fund:
     $ 1,130,874,559


Ownership


12. Minimum investment commitment required of an investor in the private fund:
     $ 250,000
     NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the
     organizational documents of the fund).


13. Approximate number of the private fund's beneficial owners:
     1


14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
     0%


15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
     0%
                                                                                                                                                    Yes No
     (b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment
         Company Act of 1940, are sales of the fund limited to qualified clients?


16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
     100%


Your Advisory Services
                                                                                                                                                    Yes No
17. (a) Are you a subadviser to this private fund?

     (b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to
         question 17.(a) is "no," leave this question blank.
                                                                          No Information Filed

                                                                                                                                                    Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?

     (b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer
         to question 18.(a) is "no," leave this question blank.
                                                                          No Information Filed

                                                                                                                                                    Yes No
19. Are your clients solicited to invest in the private fund?

     NOTE: For purposes of this question, do not consider feeder funds of the private fund.


20. Approximately what percentage of your clients has invested in the private fund?
     0%


Private Offering
                                                                                                                                                    Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?


22. If yes, provide the private fund's Form D file number (if any):
                                                                        No Information Filed
B. SERVICE PROVIDERS


Auditors
                                                                                                                                                    Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?

        (2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?

        If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm,
        you must complete questions (b) through (f) separately for each auditing firm.

           Additional Auditor Information : 1 Record(s) Filed.

            If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing
            firm, you must complete questions (b) through (f) separately for each auditing firm.


            (b) Name of the auditing firm:
                  DELOITTE LLP


            (c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
                  City:                                State:                       Country:
                  LONDON                                                            United Kingdom
                                                                                                                                                  Yes No
            (d) Is the auditing firm an independent public accountant?


            (e) Is the auditing firm registered with the Public Company Accounting Oversight Board?


                  If yes, Public Company Accounting Oversight Board-Assigned Number:
                  1147


            (f)   If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in
                  accordance with its rules?



                                                                                                                                                    Yes No
    (g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's
        investors?

    (h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?

             Yes      No     Report Not Yet Received

        If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.


Prime Broker
                                                                                                                                                    Yes No
24. (a) Does the private fund use one or more prime brokers?

        If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private
        fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.



                                                                           No Information Filed




Custodian
                                                                                                                                                    Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?

        If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund
        uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.

           Additional Custodian Information : 1 Record(s) Filed.



            If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
            fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
           (b) Legal name of custodian:
               THE BANK OF NEW YORK MELLON


           (c) Primary business name of custodian:
               THE BANK OF NEW YORK MELLON


           (d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
                 City:                                State:                       Country:
                 LONDON                                                            United Kingdom
                                                                                                                                                  Yes No
           (e) Is the custodian a related person of your firm?


           (f)   If the custodian is a broker-dealer, provide its SEC registration number (if any):
                 -
                 CRD Number (if any):




           (g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
               identifier (if any)




Administrator
                                                                                                                                                       Yes No
26. (a) Does the private fund use an administrator other than your firm?

         If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you
         must complete questions (b) through (f) separately for each administrator.



                                                                          No Information Filed




27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not
    your related person?
    0%
    Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any
    relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including
    allocations) was the valuation determined by such person.


Marketers
                                                                                                                                                       Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?

         You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or
         similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund
         uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.

         Additional Marketer Information : 7 Record(s) Filed.



           You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor,
           or similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private
           fund uses. If the private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.


                                                                                                                                                Yes No
           (b) Is the marketer a related person of your firm?


           (c) Name of the marketer:
               BANK OF AMERICA MERRILL LYNCH INTERNATIONAL DAC


           (d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
                 -
                 and CRD Number (if any):




           (e) Location of the marketer's office used principally by the private fund (city, state and country):
      City:                               State:                      Country:
      LONDON                                                          United Kingdom
                                                                                                                                   Yes No
(f)   Does the marketer market the private fund through one or more websites?


(g) If the answer to question 28.(f) is "yes," list the website address(es):
      Website Address
      WWW.BLOOMBERG.COM
      WWW.TRADEWEB.COM




You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor,
or similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private
fund uses. If the private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.


                                                                                                                                   Yes No
(b) Is the marketer a related person of your firm?


(c) Name of the marketer:
    CITIGROUP GLOBAL MARKETS LIMITED


(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
      -
      and CRD Number (if any):




(e) Location of the marketer's office used principally by the private fund (city, state and country):
      City:                               State:                      Country:
      LONDON                                                          United Kingdom
                                                                                                                                   Yes No
(f)   Does the marketer market the private fund through one or more websites?


(g) If the answer to question 28.(f) is "yes," list the website address(es):
      Website Address
      WWW.BLOOMBERG.COM
      WWW.TRADEWEB.COM




You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor,
or similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private
fund uses. If the private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.


                                                                                                                                   Yes No
(b) Is the marketer a related person of your firm?


(c) Name of the marketer:
    J.P. MORGAN SECURITIES LLC


(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
      801 - 3702
      and CRD Number (if any):
      79


(e) Location of the marketer's office used principally by the private fund (city, state and country):
      City:                                   State:                               Country:
      NEW YORK                                New York                             United States
                                                                                                                                   Yes No
(f)   Does the marketer market the private fund through one or more websites?


(g) If the answer to question 28.(f) is "yes," list the website address(es):
      Website Address
      WWW.MORGANMARKETS.COM




You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor,
or similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private
fund uses. If the private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.


                                                                                                                                   Yes No
(b) Is the marketer a related person of your firm?


(c) Name of the marketer:
    LLOYDS BANK CORPORATE MARKETS PLC


(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
      -
      and CRD Number (if any):




(e) Location of the marketer's office used principally by the private fund (city, state and country):
      City:                               State:                      Country:
      LONDON                                                          United Kingdom
                                                                                                                                   Yes No
(f)   Does the marketer market the private fund through one or more websites?


(g) If the answer to question 28.(f) is "yes," list the website address(es):
                                                                No Information Filed




You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor,
or similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private
fund uses. If the private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.


                                                                                                                                   Yes No
(b) Is the marketer a related person of your firm?


(c) Name of the marketer:
    LLOYDS BANK CORPORATE MARKETS WERTPAPIERHANDELSBANK GMBH


(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
      -
      and CRD Number (if any):




(e) Location of the marketer's office used principally by the private fund (city, state and country):
      City:                                                State:                            Country:
      FRANKFURT                                                                              Germany
                                                                                                                                   Yes No
(f)   Does the marketer market the private fund through one or more websites?


(g) If the answer to question 28.(f) is "yes," list the website address(es):
                                                                No Information Filed




You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor,
or similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private
fund uses. If the private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.


                                                                                                                                   Yes No
             (b) Is the marketer a related person of your firm?


             (c) Name of the marketer:
                 LLOYDS SECURITIES


             (d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
                   8 - 68647
                   and CRD Number (if any):
                   154515


             (e) Location of the marketer's office used principally by the private fund (city, state and country):
                   City:                                    State:                                  Country:
                   NEW YORK                                 New York                                United States
                                                                                                                                                         Yes No
             (f)   Does the marketer market the private fund through one or more websites?


             (g) If the answer to question 28.(f) is "yes," list the website address(es):
                                                                               No Information Filed




             You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor,
             or similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private
             fund uses. If the private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.


                                                                                                                                                         Yes No
             (b) Is the marketer a related person of your firm?


             (c) Name of the marketer:
                 MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED


             (d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
                   801 - 14235
                   and CRD Number (if any):
                   7691


             (e) Location of the marketer's office used principally by the private fund (city, state and country):
                   City:                                    State:                                  Country:
                   NEW YORK                                 New York                                United States
                                                                                                                                                         Yes No
             (f)   Does the marketer market the private fund through one or more websites?


             (g) If the answer to question 28.(f) is "yes," list the website address(es):
                                                                               No Information Filed




                                                                   Funds per Page: 15     Total Funds: 1




SECTION 7.B.(2) Private Fund Reporting


                                                                         No Information Filed




Item 10 Control Persons

In this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10
should be provided for the filing adviser only.

If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners
and executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported
on either Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C.
                                                                                                                                                               Yes No
A.   Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?


     If yes, complete Section 10.A. of Schedule D.


B.   If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities
     Exchange Act of 1934, please complete Section 10.B. of Schedule D.




SECTION 10.A. Control Persons


                                                                         No Information Filed



SECTION 10.B. Control Person Public Reporting Companies


                                                                         No Information Filed




Item 11 Disclosure Information

In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to
determine whether to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an
investment adviser, and to identify potential problem areas to focus on during our on-site examinations. One event may result in "yes" answers to more than
one of the questions below. In accordance with General Instruction 5 to Form ADV, "you" and "your" include the filing adviser and all relying advisers under an
umbrella registration.

Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all
of your officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you.
If you are a "separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.

If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years
following the date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your
disclosure to ten years following the date of an event only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of
calculating this ten-year period, the date of an event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary
orders, judgments, or decrees lapsed.

You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.

                                                                                                                                                               Yes No
Do any of the events below involve you or any of your supervised persons?

For "yes" answers to the following questions, complete a Criminal Action DRP:
A.   In the past ten years, have you or any advisory affiliate:                                                                                                Yes No
     (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?

     (2) been charged with any felony?


     If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to
     charges that are currently pending.


B.   In the past ten years, have you or any advisory affiliate:
     (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving:
         investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury,
         forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?
     (2) been charged with a misdemeanor listed in Item 11.B.(1)?


     If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to
     charges that are currently pending.


For "yes" answers to the following questions, complete a Regulatory Action DRP:
C.   Has the SEC or the Commodity Futures Trading Commission (CFTC) ever:                                                                                      Yes No
     (1) found you or any advisory affiliate to have made a false statement or omission?

     (2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?

     (3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied,
         suspended, revoked, or restricted?
     (4) entered an order against you or any advisory affiliate in connection with investment-related activity?

     (5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
D.   Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:
     (1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?

     (2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?

     (3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business
         denied, suspended, revoked, or restricted?
     (4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?

     (5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory
         affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?


E.   Has any self-regulatory organization or commodities exchange ever:
     (1) found you or any advisory affiliate to have made a false statement or omission?

     (2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule
         violation" under a plan approved by the SEC)?
     (3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied,
         suspended, revoked, or restricted?
     (4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you
         or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?


F.   Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or
     suspended?


G.   Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C.,
     11.D., or 11.E.?


For "yes" answers to the following questions, complete a Civil Judicial Action DRP:
H.   (1) Has any domestic or foreign court:                                                                                                                 Yes No
         (a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?

         (b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?

         (c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a
             state or foreign financial regulatory authority?
     (2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?




Schedule A
Direct Owners and Executive Officers
1. Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive
   officers. Use Schedule C to amend this information.
2. Direct Owners and Executive Officers. List below the names of:
   (a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is
        required if you are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar
        status or functions;
   (b) if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a
        public reporting company (a company subject to Section 12 or 15(d) of the Exchange Act);
        Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a
        class of your voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild,
        parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing
        the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the
        security.
   (c) if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or
        have contributed, 5% or more of your capital;
   (d) in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has
        contributed, 5% or more of your capital, the trust and each trustee; and
   (e) if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5%
        or more of your capital, and (ii) if managed by elected managers, all elected managers.
3. Do you have any indirect owners to be reported on Schedule B?           Yes      No

4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or
   "I" if the owner or executive officer is an individual.
5. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or
   member; and for shareholders or members, the class of securities owned (if more than one is issued).
6. Ownership codes are:       NA - less than 5%            B - 10% but less than 25%       D - 50% but less than 75%
                              A - 5% but less than 10%     C - 25% but less than 50%       E - 75% or more
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does
       not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are
       control persons.
   (b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
  (c) Complete each column.
FULL LEGAL NAME (Individuals: Last DE/FE/I Title or Status                    Date Title or Status Ownership Control PR CRD No. If None: S.S. No. and
Name, First Name, Middle Name)                                                Acquired MM/YYYY Code          Person     Date of Birth, IRS Tax No. or
                                                                                                                        Employer ID No.
LLOYDS BANKING GROUP PLC                FE       PARENT COMPANY               12/2005                E           Y       N
SHELLEY, STEPHEN, ROBERT                I        GROUP EXECUTIVE              09/2017                NA          Y       N   7092078
                                                 COMMITTEE MEMBER
WALTON, ANDREW, CHARLES                 I        GROUP EXECUTIVE              12/2018                NA          Y       N   4767738
                                                 COMMITTEE MEMBER
CHALMERS, WILLIAM, LEON DAVID           I        CHIEF FINANCIAL OFFICER 08/2019                     NA          Y       N   7246014
                                                 AND EXECUTIVE DIRECTOR
LEGG, SARAH, CATHERINE                  I        NON EXECUTIVE DIRECTOR 12/2019                      NA          Y       N   7246019
MACKENZIE, AMANDA, FELICITY             I        NON EXECUTIVE DIRECTOR 10/2018                      NA          Y       N   7246028
WOODS, CATHERINE, MARIE                 I        NON EXECUTIVE DIRECTOR 03/2020                      NA          Y       N   7246030
HINSHELWOOD, NIGEL, GRANT               I        NON EXECUTIVE DIRECTOR 01/2019                      NA          Y       N   7246041
Bentley, Sarah                          I        NON EXECUTIVE DIRECTOR 01/2019                      NA          Y       N   7246045
GILLIGAN, BRENDAN, EDWARD               I        NON EXECUTIVE DIRECTOR 01/2019                      NA          Y       N   7246047
BUDENBERG, ROBIN, FRANCIS               I        NON EXECUTIVE DIRECTOR 01/2021                      NA          Y       N   7358053
Cheetham, Kate                          I        CHIEF LEGAL OFFICER AND 07/2019                     NA          Y       N   7358055
                                                 COMPANY SECRETARY
Nunn, Charles, Alan                     I        EXECUTIVE DIRECTOR AND 08/2021                      NA          Y       N   7531463
                                                 GROUP CHIEF EXECUTIVE
Mehta, Harmeen                          I        NON EXECUTIVE DIRECTOR 11/2021                      NA          Y       N   7531473
Winter, John                            I        GROUP EXECUTIVE              09/2022                NA          Y       N   7720724
                                                 COMMITTEE MEMEBER
Opperman, Jayne                         I        GROUP EXECUTIVE              01/2023                NA          Y       N   7720730
                                                 COMMITTEE MEMBER
Doherty, Sharon                         I        GROUP EXECUTIVE              06/2022                NA          Y       N   7720733
                                                 COMMITTEE MEMBER
Singh, Jasjyot                          I        GROUP EXECUTIVE              07/2022                NA          Y       N   7720738
                                                 COMMITTEE MEMBER
Turner, Cathy                           I        NON EXECUTIVE DIRECTOR 11/2022                      NA          Y       N   7720805
Van Kemenade, Ron                       I        GROUP EXECUTIVE              06/2023                NA          Y       N   7904490
                                                 COMMITTEE MEMBER
Barua, Chirantan                        I        GROUP EXECUTIVE              05/2023                NA          Y       N   7904491
                                                 COMMITTEE MEMBER
Bostock, Nathan, Mark                   I        NON-EXECUTIVE                08/2024                NA          Y       N   8057640
                                                 DIRECTOR
Vogelzang, Chris                        I        NON EXECUTIVE DIRECTOR 08/2025                      NA          Y       N   8216458
Murphy, Amanda                          I        GROUP EXECUTIVE              03/2026                NA          Y       N   8232588
                                                 COMMITTEE MEMBER



Schedule B
Indirect Owners
1. Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first
   complete Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information.
2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:
   (a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct
       the sale of, 25% or more of a class of a voting security of that corporation;

       For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent,
       grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence;
       or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
   (b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon
       dissolution, or have contributed, 25% or more of the partnership's capital;
   (c) in the case of an owner that is a trust, the trust and each trustee; and
   (d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have
       contributed, 25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of
   the Exchange Act) is reached, no further ownership information need be given.
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or
   "I" if the owner is an individual.
5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or
   members, the class of securities owned (if more than one is issued).
6. Ownership codes are:      C - 25% but less than 50%      E - 75% or more
                             D - 50% but less than 75%      F - Other (general partner, trustee, or elected manager)
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does
          not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are
          control persons.
   (b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
   (c) Complete each column.

No Information Filed




Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.
Item 7. In Section 7.A of Schedule D we have included only those related persons of Lloyds Bank plc. that (1) have business dealings with us in connection
with our investment advisory services; (2) conduct shared operations (excluding, for the sake of clarity, shared back office and legal and compliance services)
with us in connection with our investment advisory services; (3) refer clients or business to us, or to which we refer prospective clients or business, in either
case in connection with our investment advisory services; (4) share supervised persons or premises with our personnel engaged in our investment advisory
services; or (5) we believe create a conflict of interest with our clients in connection with our investment advisory services. Lloyds Bank plc has hundreds of
related persons that are not included in Section 7.A of Schedule D. A list of related persons that are not listed in Section 7.A is available upon request to
prospective clients. Item 11. Our responses to Item 11 do not include information about the disciplinary history of personnel of Lloyds Bank plc. who are not
involved in our investment advisory business and are not directors of Lloyds Bank plc. Inclusion of such personnel in our responses to Item 11 would have
resulted in additional affirmative responses to the questions in Item 11. In addition, except as set forth in our responses to Item 11, our responses to Item
11 do not include information regarding the disciplinary history of Lloyds Bank plc and its advisory affiliates in connection with matters not relating to our
investment advisory business. In the ordinary course of business, on an annual basis, Lloyds Bank plc and its advisory affiliates are subject to threatened
and actual legal and regulatory challenges, investigations and enforcement actions related to our other businesses. For example, Lloyds Bank plc and its
advisory affiliates are regularly the subject of customer lawsuits relating to the banking services of Lloyds Bank plc (such as in relation to Motor Finance
Commission and Payment Protection Insurance) that may involve allegations of violations of various bank regulatory requirements. Inclusion of such actions
related to the non-advisory businesses of Lloyds Bank plc and our advisory affiliates would have resulted in additional affirmative responses to the
questions in Item 11.




DRP Pages


CRIMINAL DISCLOSURE REPORTING PAGE (ADV)

                                                                           GENERAL INSTRUCTIONS
 This Disclosure Reporting Page (DRP ADV) is an           INITIAL          AMENDED response used to report details for affirmative responses to Items 11.A. or
                                                                    OR
 11.B. of Form ADV.

                                                                                       Criminal
 Check item(s) being responded to:
       11.A(1)                                  11.A(2)                                       11.B(1)                              11.B(2)



 Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
 with a completed Execution Page.

 Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
 cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
 result in more than one affirmative answer to the items listed above.

 PART I
  A.    The person(s) or entity(ies) for whom this DRP is being filed is (are):
            You (the advisory firm)

            You and one or more of your
                                           advisory affiliates
            One or more of your
                                  advisory affiliates


        If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
        If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.


         ADV DRP - ADVISORY AFFILIATE

          CRD
                                                          This advisory affiliate is      a Firm    an Individual
          Number:
          Registered:
                           Yes        No
          Name:         THE MORTGAGE BUSINESS PLC
                        (TMB)
                        (For individuals, Last, First,
                        Middle)
             This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
             This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
             registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
             adviser's or advisory affiliate's favor.
             This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
             circumstances:


 B.    If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
       the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.

             Yes       No


       NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.


PART II
 1.    If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
       the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship.
       PROCEEDINGS WERE INITIATED AGAINST TMB, ONE OF THE AFFILIATES OF LLOYDS BANK PLC. TMB IS A SUBSIDIARY OF BANK OF SCOTLAND PLC.


 2.    Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
       Docket/Case number).
       THE LONDON BOROUGH OF NEWHAM (NEWHAM)


 3.    Event Disclosure Detail (Use this for both organizational and individual charges.)

        A. Date First Charged (MM/DD/YYYY):

              05/01/2016       Exact      Explanation
              If not exact, provide explanation:
              MAY 2016 TMB AND ITS DIRECTOR BECAME AWARE OF PROCEEDINGS INITIATED AGAINST TMB AND THE DIRECTOR.
        B. Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
           (3) plea for each charge, and (4) product type if charge is investment-related).
           IN MAY 2016 THE LONDON BOROUGH OF NEWHAM INITIATED PROCEEDINGS AGAINST TMB AND ONE OF ITS DIRECTORS. EACH WERE CHARGED
           WITH TWO OFFENCES THAT RELATED TO THE FAILURE TO RESPOND TO STATUTORY NOTICES REQUESTING INFORMATION AND DOCUMENTS SENT
           TO TMB BY NEWHAM. THESE MATTERS HAVE ARISEN IN CONNECTION WITH A PROPERTY MORTGAGED TO TMB. THESE OFFENSES CARRY MAXIMUM
           FINES OF 5,000 POUNDS EACH.
        C. Did any of the Charge(s) within the Event involve a              ?
                                                                   felony          Yes      No

        D. Current status of the Event?         Pending      On Appeal             Final
        E.    Event Status Date (complete unless status is Pending) (MM/DD/YYYY):

              11/01/2016       Exact      Explanation
              If not exact, provide explanation:


 4.    Disposition Disclosure Detail:
       Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
       sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid.
       AT A SENTENCING HEARING ON 1 NOVEMBER 2016, TMB PLEADED GUILTY TO THESE TWO CHARGES AND WAS FINED A TOTAL OF £3,120. NEWHAM
       ENTERED NO EVIDENCE IN RELATION TO THE REMAINING CHARGES AGAINST THE DIRECTOR WHICH WERE, EFFECTIVELY, WITHDRAWN. THE
       PROCEEDINGS ARE NOW CONCLUDED.


 5.    Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
       the subject of the charge(s) occurred. (Your response must fit within the space provided.)
       IN MAY 2016 NEWHAM INITIATED PROCEEDINGS AGAINST TMB AND ONE OF ITS DIRECTORS WHO WERE CHARGED WITH TWO OFFENCES THAT RELATE
       TO THE FAILURE TO RESPOND TO STATUTORY NOTICES REQUESTING INFORMATION AND DOCUMENTS SENT TO TMB BY NEWHAM. THESE MATTERS HAVE
       ARISEN IN CONNECTION WITH A PROPERTY MORTGAGED TO TMB. AT A SENTENCING HEARING ON 1 NOVEMBER 2016, TMB PLEADED GUILTY TO THESE
       TWO CHARGES AND WAS FINED A TOTAL OF £3,120. NEWHAM ENTERED NO EVIDENCE IN RELATION TO THE REMAINING CHARGES AGAINST THE
       DIRECTOR WHICH WERE, EFFECTIVELY, WITHDRAWN. THE PROCEEDINGS ARE NOW CONCLUDED.




REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)

                                                                       GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an          INITIAL        AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
                                                                  OR
11.E., 11.F. or 11.G. of Form ADV.

                                                                                Regulatory Action
Check item(s) being responded to:
      11.C(1)                         11.C(2)                          11.C(3)                        11.C(4)                           11.C(5)
      11.D(1)                         11.D(2)                          11.D(3)                        11.D(4)                           11.D(5)
     11.E(1)                                11.E(2)                           11.E(3)                       11.E(4)
     11.F.                                  11.G.



Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.

PART I
A.    The person(s) or entity(ies) for whom this DRP is being filed is (are):
             You (the advisory firm)

             You and one or more of your
                                               advisory affiliates
             One or more of your
                                   advisory affiliates


      If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
      If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.


       ADV DRP - ADVISORY AFFILIATE

         CRD
                                                              This advisory affiliate is   a Firm   an Individual
         Number:
         Registered:
                            Yes        No
         Name:         LLOYDS BANK PLC
                       (For individuals, Last, First,
                       Middle)


             This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
             This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
             registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
             adviser's or advisory affiliate's favor.

       If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
       11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
       event listed in Item 11 that occurred more than ten years ago.

             This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
             circumstances:


B.    If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
      the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.

             Yes       No


      NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.


PART II
1.    Regulatory Action initiated by:
        SEC      Other Federal       State                 Foreign
                                                  SRO
      (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
      FINANCIAL CONDUCT AUTHORITY


2.    Principal Sanction:
      Civil and Administrative Penalt(ies) /Fine(s)
      Other Sanctions:


3.    Date Initiated (MM/DD/YYYY):

      06/11/2020       Exact      Explanation
      If not exact, provide explanation:


4.    Docket/Case Number:


5.    Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):


6.    Principal Product Type:
      Banking Products (Other than CD(s))
      Other Product Types:


7.    Describe the allegations related to this regulatory action (your response must fit within the space provided):
      ON 11 JUNE 2020, THE FCA PUBLISHED A FINAL NOTICE IMPOSING A PENALTY OF £64,046,800 ON LLOYDS BANK PLC, BANK OF SCOTLAND PLC, AND
      THE MORTGAGE BUSINESS PLC ('THE BANKS') FOR BREACHES OF PRINCIPLES 3 AND 6 OF THE AUTHORITY'S PRINCIPLES FOR BUSINESSES. THESE
      BREACHES WERE IN RELATION TO THE HANDLING OF MORTGAGE CUSTOMERS IN PAYMENT DIFFICULTIES OR ARREARS BETWEEN 7 APRIL 2011 AND 21
      DECEMBER 2015. AS A RESULT OF THESE BREACHES, THE FCA FOUND THAT THE BANKS PUT A LARGE NUMBER OF CUSTOMERS AT RISK OF BEING
      TREATED UNFAIRLY. THE BANKS AGREED TO RESOLVE ALL ISSUES OF FACT AND LIABILITY AND QUALIFIED FOR A 30% DISCOUNT UNDER THE
      AUTHORITY'S EXECUTIVE SETTLEMENT PROCEDURES. WERE IT NOT FOR THIS DISCOUNT, THE AUTHORITY WOULD HAVE IMPOSED A FINANCIAL PENALTY
      OF £91,495,400.



8.    Current Status?           Pending        On Appeal        Final


9.    If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:


If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.


10. How was matter resolved:
      Settled


11. Resolution Date (MM/DD/YYYY):

      06/11/2020        Exact      Explanation
      If not exact, provide explanation:


12. Resolution Detail:

       A.    Were any of the following Sanctions Ordered (check all appropriate items)?

                 Monetary/Fine Amount: $ 64,046,800.00
                 Revocation/Expulsion/Denial                                              Disgorgement/Restitution
                 Censure                                                                  Cease and Desist/Injunction
                 Bar                                                                      Suspension

       B.    Other Sanctions Ordered:
             NONE. MONETARY VALUE IN GBP RATHER THAN USD
             Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
             Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
             requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
             disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
             penalty was waived:
             THE BANKS AGREED TO RESOLVE ALL ISSUES OF FACT AND LIABILITY AND QUALIFIED FOR A 30% DISCOUNT UNDER THE AUTHORITY'S EXECUTIVE
             SETTLEMENT PROCEDURES. WERE IT NOT FOR THIS DISCOUNT, THE AUTHORITY WOULD HAVE IMPOSED A FINANCIAL PENALTY OF £91,495,400.


13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
    must fit within the space provided).
      THE BANKS AGREED TO RESOLVE ALL ISSUES OF FACT AND LIABILITY AND QUALIFIED FOR A 30% DISCOUNT UNDER THE AUTHORITY'S EXECUTIVE
      SETTLEMENT PROCEDURES.




                                                                    GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an       INITIAL        AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
                                                               OR
11.E., 11.F. or 11.G. of Form ADV.

                                                                        Regulatory Action
Check item(s) being responded to:
     11.C(1)                         11.C(2)                        11.C(3)                         11.C(4)                        11.C(5)
     11.D(1)                         11.D(2)                        11.D(3)                         11.D(4)                        11.D(5)
     11.E(1)                         11.E(2)                        11.E(3)                         11.E(4)
     11.F.                           11.G.



Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.   The person(s) or entity(ies) for whom this DRP is being filed is (are):
          You (the advisory firm)

          You and one or more of your
                                           advisory affiliates
          One or more of your
                                  advisory affiliates


     If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
     If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.


     ADV DRP - ADVISORY AFFILIATE

         CRD           161259
                                                          This advisory affiliate is   a Firm   an Individual
         Number:
         Registered:
                            Yes     No
         Name:         BANK OF SCOTLAND PLC
                       (For individuals, Last, First,
                       Middle)


          This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
          This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
          registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
          adviser's or advisory affiliate's favor.

     If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
     11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
     event listed in Item 11 that occurred more than ten years ago.

          This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
          circumstances:


B.   If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
     the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.

           Yes         No


     NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.


PART II
1.   Regulatory Action initiated by:
       SEC      Other Federal       State                 Foreign
                                                 SRO
     (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
     UK FINANCIAL CONDUCT AUTHORITY


2.   Principal Sanction:
     Civil and Administrative Penalt(ies) /Fine(s)
     Other Sanctions:


3.   Date Initiated (MM/DD/YYYY):

     06/21/2019       Exact      Explanation
     If not exact, provide explanation:


4.   Docket/Case Number:


5.   Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):


6.   Principal Product Type:
     Banking Products (Other than CD(s))
     Other Product Types:


7.   Describe the allegations related to this regulatory action (your response must fit within the space provided):
     BANK OF SCOTLAND FAILED TO ALERT THE THEN REGULATOR (THE FINANCIAL SERVICES AUTHORITY) OF SUSPICIONS OF FRAUD IN ITS READING
     BRANCH WITHIN THE IMPAIRED ASSETS ('IAR') TEAM, AFTER IDENTIFYING SUSPICIOUS CONDUCT IN EARLY 2007. THE SUSPICIOUS CONDUCT RELATED
     TO A DIRECTOR (LYNDEN SCOURFIELD) SANCTIONING LIMITS AND ADDITIONAL LENDING FACILITIES BEYOND THE SCOPE OF HIS AUTHORITY FOR AT
     LEAST 3 YEARS. BANK OF SCOTLAND NOTIFIED THE FCA IN 2009. THE FCA FOUND THAT THIS CAUSED DELAYS IN INVESTIGATIONS CONDUCTED BY THE
     FCA AND THAMES VALLEY POLICE AND THAT IT RISKED PREJUDICING THE INVESTIGATION BY THAMES VALLEY POLICE.
 8.   Current Status?           Pending       On Appeal         Final


 9.   If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:


 If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.


 10. How was matter resolved:
      Settled


 11. Resolution Date (MM/DD/YYYY):

      06/21/2019        Exact      Explanation
      If not exact, provide explanation:


 12. Resolution Detail:

       A.   Were any of the following Sanctions Ordered (check all appropriate items)?

                Monetary/Fine Amount: $ 45,500,000.00
                Revocation/Expulsion/Denial                                               Disgorgement/Restitution
                Censure                                                                   Cease and Desist/Injunction
                Bar                                                                       Suspension

       B.   Other Sanctions Ordered:
            NONE. MONETARY VALUE IN GBP RATHER THAN USD.
            Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
            Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
            requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
            disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
            penalty was waived:
            A FINE OF £45,500,000 WAS LEVIED. BANK OF SCOTLAND SETTLED THE MATTER DURING STAGE 1 WHICH MEANT IT QUALIFIED FOR A 30%
            DISCOUNT ON THE ORIGINAL PROPOSED FINE OF £65,000,000.


 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
     must fit within the space provided).
      A FINE OF £45,500,000 WAS LEVIED FOR BREACHING PRINCIPLE 11 AND SUBSEQUENTLY PAID. THE MATTER IS NOW SETTLED.




CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)

No Information Filed




Execution Pages
DOMESTIC INVESTMENT ADVISER EXECUTION PAGE
 You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to
 the SEC and all amendments.


 Appointment of Agent for Service of Process

 By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the
 state in which you maintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to
 receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand
 for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state
 action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding, or
 arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b)
 is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939,
 the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of the state
 in which you maintain your principal office and place of business or of any state in which you are submitting a notice filing.


 Signature

 I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under
 penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other
 information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having
custody or possession of these books and records to make them available to federal and state regulatory representatives.


Signature:                                                             Date: MM/DD/YYYY
Printed Name:                                                          Title:
Adviser CRD Number:
161257




NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to
the SEC and all amendments.


1. Appointment of Agent for Service of Process

By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or
other legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such
persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or
papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or
arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any
activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly,
upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of
1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of any state in which you are submitting a
notice filing.


2. Appointment and Consent: Effect on Partnerships

If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws
from or is admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this
irrevocable power of attorney and consent shall be in effect for any action brought against you or any of your former partners.


3. Non-Resident Investment Adviser Undertaking Regarding Books and Records

By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal office in
Washington D.C., at any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission,
correct, current, and complete copies of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940.
This undertaking shall be binding upon you, your heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of
attorney or any of your general partners and managing agents.


Signature

I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both
certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits
and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.


I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having
custody or possession of these books and records to make them available to federal and state regulatory representatives.


Signature:                                             Date: MM/DD/YYYY
EMMA NOBLE                                             04/07/2026
Printed Name:                                          Title:
EMMA NOBLE                                             CHIEF COMPLIANCE OFFICER
Adviser CRD Number:
161257