Form ADV (full filing)
as of Mar 30, 2026
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FORM ADV
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS
Primary Business Name: BARINGS AUSTRALIA PTY LTD CRD Number: 169697
Annual Amendment - All Sections Rev. 10/2021
3/30/2026 11:37:14 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):
BARINGS AUSTRALIA PTY LTD
B. (1) Name under which you primarily conduct your advisory business, if different from Item 1.A.
BARINGS AUSTRALIA PTY LTD
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: 802-80559
(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers:
No Information Filed
E. (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 169697
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:
LEVEL 19, SUITE 19.02 60 CASTLEREAGH STREET
City: State: Country: ZIP+4/Postal Code:
SYDNEY Australia 02000
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 5:00 PM
(3) Telephone number at this location:
612 9000 2117
(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:
549300MKZ00NWL5DZR13
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/SHOWCASE/BARINGS-GLOBAL-PRIVATE-FINANCE
Address of Website/Account on Publicly Available Social Media Platform: https://www.youtube.com/@barings
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://X.COM/BARINGS
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.BARINGS.COM
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BARINGS
Address of Website/Account on Publicly Available Social Media Platform: https://podcast.barings.com/public/75/Streaming-Income---A-Podcast-from-Barings-6f727a82
Address of Website/Account on Publicly Available Social Media Platform: https://open.spotify.com/show/7wv1GJCQHcggXDdMHbhRlY
Address of Website/Account on Publicly Available Social Media Platform: https://podcasts.apple.com/us/podcast/streaming-income-a-podcast-from-barings/id1449496233
Address of Website/Account on Publicly Available Social Media Platform: https://gcapinvest.com/
Address of Website/Account on Publicly Available Social Media Platform: https://www.youtube.com/@gryphoncapitalinvestment7587
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/SHOWCASE/BARINGS-REAL-ESTATE
Address of Website/Account on Publicly Available Social Media Platform: https://www.youtube.com/@baringsrealestateaustralia
SECTION 1.L. Location of Books and Records
Complete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a
separate Schedule D, Section 1.L. for each location.
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
340 MADISON AVENUE 18TH FLOOR
City: State: Country: ZIP+4/Postal Code:
NEW YORK New York United States 10173
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
917-542-8300 212-682-9439
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING THOSE RELATING TO THE FIRM'S INVESTMENT
ADVISORY BUSINESS CONDUCTED BY ITS FIXED INCOME, PUBLIC EQUITY, ALTERNATIVE INVESTMENTS, PRIVATE FINANCE AND REAL ESTATE GROUPS AND THOSE RELATING
TO SYNDICATED BANK LOAN ACCOUNTS MANAGED BY THE FIRM).
Name of entity where books and records are kept:
BROADRIDGE INVESTOR COMMUNICATIONS SOLUTIONS, INC.
Number and Street 1: Number and Street 2:
PO BOX 416423
City: State: Country: ZIP+4/Postal Code:
BOSTON Massachusetts United States 02241
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
631-254-7400
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
BROADRIDGE INVESTOR COMMUNICATIONS SOLUTIONS, INC. STORE FIRM'S PROXY CARDS, RESEARCH RECOMMENDATIONS AND PROXY VOTING RECORDS REQUIRED BY
SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940.
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
20 OLD BAILEY
City: State: Country: ZIP+4/Postal Code:
LONDON United Kingdom EC4M7BF
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
4402076286000
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 AND RELEVANT UK FINANCIAL CONDUCT AUTHORITY (FCA) RECORD
KEEPING REQUIREMENTS ARE ARCHIVED AT IRON MOUNTAIN.
Name of entity where books and records are kept:
BARINGS AUSTRALIA PTY LTD
Number and Street 1: Number and Street 2:
60 CASTLEREAGH STREET LEVEL 19
City: State: Country: ZIP+4/Postal Code:
SYDNEY Australia 02000
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
61 2 9000 2117
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940.
Name of entity where books and records are kept:
REDBOX
Number and Street 1: Number and Street 2:
450 LEXINGTON AVE
City: State: Country: ZIP+4/Postal Code:
NEW YORK New York United States 10017
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
866-474-1429
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
THIS LOCATION IS USED AS A DEPOSITORY TO STORE THE FIRM'S RECORDED CALLS FOR TRADERS.
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
2331 ROSECRANS AVENUE SUITE 4225
City: State: Country: ZIP+4/Postal Code:
EL SEGUNDO California United States 90245
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
(310) 234-2525 (310) 234-2552
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING THOSE RELATING TO THE FIRM'S REAL ESTATE GROUP
AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC)).
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
300 SOUTH TRYON STREET SUITE 2500
City: State: Country: ZIP+4/Postal Code:
CHARLOTTE North Carolina United States 28202
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
704-805-7200 704-805-7302
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 AND RELEVANT AUSTRALIAN SECURITIES AND INVESTMENTS
COMMISSION RECORDKEEPING REQUIREMENTS IN RELATION TO ACTIVITIES CARRIED OUT BY THE FIRM, INCLUDING THOSE RELATING TO THE FIRM'S INVESTMENT
ADVISORY BUSINESS.
Name of entity where books and records are kept:
REDBOX
Number and Street 1: Number and Street 2:
UNIT E3 BROOKLANDS CLOSE
City: State: Country: ZIP+4/Postal Code:
SUNBURY-ON-THAMES, United Kingdom
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
4401159377100
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
THIS LOCATION IS USED AS A DEPOSITORY TO STORE THE FIRM'S RECORDED CALLS FOR TRADERS.
Name of entity where books and records are kept:
NAVEX GLOBAL (CYXTERA)
Number and Street 1: Number and Street 2:
14901 FAA BLVD
City: State: Country: ZIP+4/Postal Code:
FORT WORTH Texas United States 76155
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
8662970224
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
BACKUP DATA CENTER
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
1295 STATE STREET
City: State: Country: ZIP+4/Postal Code:
SPRINGFIELD Massachusetts United States 01111
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
(413) 744-1000
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
ISS (SWITCH LTD.) 1
Number and Street 1: Number and Street 2:
5225 W CAPOVILLA AVENUE
City: State: Country: ZIP+4/Postal Code:
LAS VEGAS Nevada United States 89118
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
6466806350
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
BACKUP DATA CENTER
Name of entity where books and records are kept:
ISS (SWITCH LTD.) 2
Number and Street 1: Number and Street 2:
7315 S DECATUR BLVD
City: State: Country: ZIP+4/Postal Code:
LAS VEGAS Nevada United States 89118
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
6466806350
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
ISS HOSTS ITS WEB APPLICATION AND SERVICES USING A PAIR OF DATACENTERS IN THE UNITED STATES (US) WHICH PROVIDE PRIMARY AND RECOVERY SERVICES, BOTH
SITES ARE IN LAS VEGAS, NEVADA
Name of entity where books and records are kept:
PROOFPOINT INC.
Number and Street 1: Number and Street 2:
892 ROSS DR
City: State: Country: ZIP+4/Postal Code:
SUNNYVALE California United States 94089
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
4085174710
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
THIS LOCATION IS USED FOR A DEPOSITORY FOR EMAIL ARCHIVING
Name of entity where books and records are kept:
INFOSHRED LLC
Number and Street 1: Number and Street 2:
3 CRAFTSMAN ROAD
City: State: Country: ZIP+4/Postal Code:
EAST WINDSOR Connecticut United States 06088
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
888-800-1552
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
THIS LOCATION IS USED TO STORE PAPER RECORDS. THIS LOCATION IS ALSO USED AS AN OFF-SITE REPOSITORY FOR ELECTRONIC BACK-UPS OF DATA FOR DISASTER
RECOVERY PURPOSES.
Name of entity where books and records are kept:
BARINGS
Number and Street 1: Number and Street 2:
3RD FLOOR, BUILDING 3 NO 1 BALLSBRIDGE 126 PEMBROKE ROAD
City: State: Country: ZIP+4/Postal Code:
DUBLIN 4 Ireland D04-EP27
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
35314869700
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 AND RELEVANT UK FINANCIAL CONDUCT AUTHORITY (FCA) RECORD
KEEPING REQUIREMENTS ARE ARCHIVED AT IRON MOUNTAIN.
Name of entity where books and records are kept:
PROOFPOINT, INC.
Number and Street 1: Number and Street 2:
100 BROOK DRIVE GREEN PARK, BERSHIRE
City: State: Country: ZIP+4/Postal Code:
READING United Kingdom RG2 6UJ
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
4401184025900
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
THIS LOCATION IS USED AS A DEPOSITORY FOR EMAIL ARCHIVING AND ELECTRONIC MESSAGING
Name of entity where books and records are kept:
NAVEX GLOBAL
Number and Street 1: Number and Street 2:
5500 MEADOWS ROAD SUITE 500
City: State: Country: ZIP+4/Postal Code:
LAKE OSWEGO Oregon United States 28277
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
866-297-0224
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CORPORATE OFFICE/BACKUP DATA CENTER FOR ETHICSPOINT
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
26 S MIDDLESEX AVE
City: State: Country: ZIP+4/Postal Code:
MONROE New Jersey United States 08831
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
1420 EXCHANGE STREET
City: State: Country: ZIP+4/Postal Code:
CHARLOTTE North Carolina United States 28208
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
2920-E HUTCHINSON MCDONALD RD.
City: State: Country: ZIP+4/Postal Code:
CHARLOTTE North Carolina United States 28269
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
600 BURNING TREE ROAD
City: State: Country: ZIP+4/Postal Code:
FULLERTON California United States 92833-1450
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
5086 4TH ST
City: State: Country: ZIP+4/Postal Code:
IRWINDALE California United States 91706
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
2009 COUNTRY CLUB DRIVE
City: State: Country: ZIP+4/Postal Code:
CARROLLTON Texas United States 75006
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
35/F GLOUCESTER TOWER, 15 QUEEN'S ROAD
City: State: Country: ZIP+4/Postal Code:
HONG KONG China
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
852-2841-1411
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 AND RELEVANT UK FINANCIAL CONDUCT AUTHORITY (FCA) RECORD
KEEPING REQUIREMENTS ARE ARCHIVED AT IRON MOUNTAIN.
Name of entity where books and records are kept:
RESTORE PLC
Number and Street 1: Number and Street 2:
UNIT 5 REDHILL DISTRIBUTION CENTRE
City: State: Country: ZIP+4/Postal Code:
REDHILL United Kingdom RH1 5DY
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
4401708 527 60
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RESTORE PLC IS A THIRD PARTY UNAFFILIATED RECORD KEEPER USED TO RETAIN CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT
ADVISERS ACT OF 1940 THAT ARE NO LONGER REQUIRED TO BE KEPT ON-SITE. SUCH BOOKS AND RECORDS ARE ARCHIVED AT RESTORE PLC.
Name of entity where books and records are kept:
ISS
Number and Street 1: Number and Street 2:
702 KING FARM BOULEVARD SUITE 300
City: State: Country: ZIP+4/Postal Code:
ROCKVILLE Maryland United States 20850
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Telephone Number: Facsimile number, if any:
646-680-6350
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EXTERNAL VENDOR USED TO PROCESS FIRM'S PROXY VOTING
Name of entity where books and records are kept:
BROADRIDGE FINANCIAL SOLUTIONS
Number and Street 1: Number and Street 2:
193 MARSH WALL
City: State: Country: ZIP+4/Postal Code:
LONDON United Kingdom E14 9SG
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Telephone Number: Facsimile number, if any:
207551383
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 AND RELEVANT UK FINANCIAL CONDUCT AUTHORITY (FCA) RECORD
KEEPING REQUIREMENTS ARE ARCHIVED AT IRON MOUNTAIN.
Name of entity where books and records are kept:
FRANKFURT A. M.
Number and Street 1: Number and Street 2:
UNTERLINDAU 29 FLOOR 2
City: State: Country: ZIP+4/Postal Code:
FRANKFURT Germany 60323
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Telephone Number: Facsimile number, if any:
490696681220
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT.
Name of entity where books and records are kept:
PARIS
Number and Street 1: Number and Street 2:
10 RUE DES PYRAMIDES
City: State: Country: ZIP+4/Postal Code:
PARIS France 75001
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Telephone Number: Facsimile number, if any:
330153936000
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT
Name of entity where books and records are kept:
BOSTON
Number and Street 1: Number and Street 2:
10 FAN PIER BLVD 9TH FLOOR
City: State: Country: ZIP+4/Postal Code:
BOSTON Massachusetts United States 02210
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Telephone Number: Facsimile number, if any:
(617) 761-3800
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT AT THE OFFICE OF BARINGS LLC.
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
1100 KENNEDY ROAD
City: State: Country: ZIP+4/Postal Code:
WINDSOR Connecticut United States 06095
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Telephone Number: Facsimile number, if any:
860-298-3415
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 AND RELEVANT AUSTRALIAN SECURITIES AND INVESTMENTS
COMMISSION RECORDKEEPING REQUIREMENTS IN RELATION TO ACTIVITIES CARRIED OUT BY THE FIRM, INLCUDING THOSE RELATED TO THE FIRM'S INVESTMENT ADVISORY
BUSINESS.
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
811 STATE ROUTE #33
City: State: Country: ZIP+4/Postal Code:
FREEHOLD New Jersey United States 07728-8431
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
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other.
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
20 EASTERN PARK RD
City: State: Country: ZIP+4/Postal Code:
EAST HARTFORD Connecticut United States 06108
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
2604 W 13TH STREET
City: State: Country: ZIP+4/Postal Code:
CHICAGO Illinois United States 60608
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
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other.
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
2211 W PERSHING RD
City: State: Country: ZIP+4/Postal Code:
CHICAGO Illinois United States 60608
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Telephone Number: Facsimile number, if any:
1-800-934-3453
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other.
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
BLACKROCK
Number and Street 1: Number and Street 2:
P.O. BOX 978884
City: State: Country: ZIP+4/Postal Code:
DALLAS Texas United States 75397-8884
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Telephone Number: Facsimile number, if any:
1-212-810-5800
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other.
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940.
Name of entity where books and records are kept:
IRON MOUNTAIN (CONTACT OFFICE SUPPORTING REGIONAL LOCATIONS)
Number and Street 1: Number and Street 2:
12958 MIDWAY PLACE
City: State: Country: ZIP+4/Postal Code:
CERRITOS California United States 90703
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Telephone Number: Facsimile number, if any:
800-934-3453
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC)).
Name of entity where books and records are kept:
IRON MOUNTAIN (CONTACT OFFICE SUPPORTING REGIONAL LOCATIONS)
Number and Street 1: Number and Street 2:
331 S. SWIFT ROAD
City: State: Country: ZIP+4/Postal Code:
ADDISON Illinois United States 60101-1448
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Telephone Number: Facsimile number, if any:
800-934-3453
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC)).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
1915 S GRAND AVE
City: State: Country: ZIP+4/Postal Code:
SANTA ANA California United States 92705
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
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other.
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
ALLGRESS
Number and Street 1: Number and Street 2:
111 LINDBERGH AVE SUITE F
City: State: Country: ZIP+4/Postal Code:
LIVERMORE California United States 94551
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Telephone Number: Facsimile number, if any:
925-579-0002
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DESCRIPTION - CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940.
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
2641 SEMINOLE AVE
City: State: Country: ZIP+4/Postal Code:
SOUTH GATE California United States 90280
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
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other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
STARCOMPLIANCE
Number and Street 1: Number and Street 2:
9200 CORPORATE BLVD SUITE 440
City: State: Country: ZIP+4/Postal Code:
ROCKVILLE Maryland United States 20850
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Telephone Number: Facsimile number, if any:
301-340-3900
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USES THIS LOCATION TO ELECTRONICALLY STORE ALL THE FIRM'S CODE OF ETHICS RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
FIS DATA SYSTEM INC. / PTA
Number and Street 1: Number and Street 2:
601 RIVERSIDE AVE
City: State: Country: ZIP+4/Postal Code:
JACKSONVILLE Florida United States 32204
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
781-238-0900
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FIS/PTA USES THIS LOCATION TO ELECTRONICALLY STORE ALL THE FIRM'S CODE OF ETHICS RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF
1940
Name of entity where books and records are kept:
STOCKHOLM
Number and Street 1: Number and Street 2:
BIBLIOTEKSGATAN 3, FLOOR 4 SUITE 0244M
City: State: Country: ZIP+4/Postal Code:
STOCKHOLM Sweden 111 46
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Telephone Number: Facsimile number, if any:
460851819150
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT.
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
175 BEARFOOT ROAD
City: State: Country: ZIP+4/Postal Code:
NORTHBOROUGH Massachusetts United States 01532
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
978-671-6400
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 AND RELEVANT AUSTRALIAN SECURITIES AND INVESTMENTS
COMMISSION RECORDKEEPING REQUIREMENTS IN RELATION TO ACTIVITIES CARRIED OUT BY THE FIRM, INLCUDING THOSE RELATED TO THE FIRM'S INVESTMENT ADVISORY
BUSINESS.
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
111 SOUTH WACKER DRIVE SUITE 3100
City: State: Country: ZIP+4/Postal Code:
CHICAGO Illinois United States 60606
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
312-465-1500
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING THOSE RELATING TO THE FIRM'S INVESTMENT
ADVISORY BUSINESS CONDUCTED BY ITS MIDDLE MARKET LENDING GROUP).
Name of entity where books and records are kept:
BARINGS FOXBOROUGH
Number and Street 1: Number and Street 2:
2 HAMPSHIRE STREET SUITE 101
City: State: Country: ZIP+4/Postal Code:
FOXBOROUGH Massachusetts United States 02025
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
(617) 235-1570
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other.
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT AT THE OFFICE OF BARINGS LLC.
Name of entity where books and records are kept:
BARINGS MELBOURNE
Number and Street 1: Number and Street 2:
80 COLLINS STREET SUITE 4, LEVEL 42, NORTH TOWER
City: State: Country: ZIP+4/Postal Code:
MELBOURNE Australia 3000
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
61 2 9000 2117
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT AT THE OFFICE OF BARINGS LLC.
Name of entity where books and records are kept:
BARINGS SHANGHAI
Number and Street 1: Number and Street 2:
8 CENTURY AVE UNIT 1511-12, LEVEL 15. TOWER 2
City: State: Country: ZIP+4/Postal Code:
SHANGHAI China PUDONG DIST
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Telephone Number: Facsimile number, if any:
86 21 3107 189
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT AT THE OFFICE OF BARINGS LLC.
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
2680 SEQUOIA DR
City: State: Country: ZIP+4/Postal Code:
SOUTH GATE California United States 90280
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
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other.
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
6711 VALLEY VIEW STREET
City: State: Country: ZIP+4/Postal Code:
LA PALMA California United States 90623
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
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other.
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
8700 MERCURY LANE
City: State: Country: ZIP+4/Postal Code:
PICO RIVERA California United States 90660
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
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other.
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
BARINGS TAIPEI
Number and Street 1: Number and Street 2:
A, NO. 7, SECTION 5, XINYI ROAD 101 BUILDING, 55TH FLOOR
City: State: Country: ZIP+4/Postal Code:
TAIPEI Taiwan, Republic of China 11012
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Telephone Number: Facsimile number, if any:
886 2 6638 818
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT AT THE OFFICE OF BARINGS LLC.
Name of entity where books and records are kept:
BARINGS DUBAI
Number and Street 1: Number and Street 2:
DUBAI INTERNATIONAL FINANCIAL CENTRE, GATE DISTRIC GATE BUILDING, FLOOR 15, EAST WING, OFFICE # GD-GB
City: State: Country: ZIP+4/Postal Code:
DUBAI United Arab Emirates
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
971 56 665 072
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT AT THE OFFICE OF BARINGS LLC.
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
96 HIGH STREET
City: State: Country: ZIP+4/Postal Code:
NORTH BILLERICA Massachusetts United States 01862
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
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other.
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
1515 WASHINGTON STREET
City: State: Country: ZIP+4/Postal Code:
BRAINTREE Massachusetts United States 02184
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
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other.
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 (INCLUDING RECORDS RELATING TO THE FIRM'S REAL ESTATE
GROUP AND ITS FORMER SUBSIDIARY, BARINGS REAL ESTATE ADVISERS LLC (F/K/A CORNERSTONE REAL ESTATE ADVISERS LLC).
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
RUE DU MARCHÉ 28
City: State: Country: ZIP+4/Postal Code:
GENEVA Switzerland 1204
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
410225911100
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other.
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT AT THE OFFICE OF BARINGS.
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
PASEO DE LA CASTELLANA 95 9TH FLOOR - C
City: State: Country: ZIP+4/Postal Code:
MADRID Spain 28046
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
34 91 737 0407
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT AT THE OFFICE OF BARINGS.
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
VIA FATEBENEFRATELLI 10
City: State: Country: ZIP+4/Postal Code:
MILAN Italy 20121
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
39 0249 760 21
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CERTAIN BOOKS AND RECORDS RELATING TO APPLICANT'S INVESTMENT ADVISORY BUSINESS AND REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
ARE KEPT AT THE OFFICE OF BARINGS.
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
FRAUENSTRAßE 30
City: State: Country: ZIP+4/Postal Code:
MUNICH Germany 80469
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
490892105620
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
7TH FLOOR, 29 EULJI-RO,
City: State: Country: ZIP+4/Postal Code:
SEOUL Korea, South 04523
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
82237880500
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CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
77 BLOOR STREET WEST SUITE 657
City: State: Country: ZIP+4/Postal Code:
TORONTO Canada M5S 1M2
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
416 645 7045
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
BARINGS SWITZERLAND SÀRL BAHNHOFPLATZ 1
City: State: Country: ZIP+4/Postal Code:
ZURICH Switzerland 8001
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
410432156770
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
BARINGS LLC
Number and Street 1: Number and Street 2:
AL MARYAH ISLAND, ABU DHABI GLOBAL MARKET SQUARE AL SILA TOWER, 24TH FLOOR, P.O. BOX 128666
City: State: Country: ZIP+4/Postal Code:
ABU DHABI United Arab Emirates
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
97126948600
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
ARTEMIS, A BARINGS COMPANY
Number and Street 1: Number and Street 2:
2000 AVENUE OF THE STARS SUITE 630N
City: State: Country: ZIP+4/Postal Code:
LOS ANGELES California United States 90067
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
323 843 8353
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
ARTEMIS, A BARINGS COMPANY
Number and Street 1: Number and Street 2:
888 SEVENTH AVENUE 30TH FLOOR
City: State: Country: ZIP+4/Postal Code:
NEW YORK New York United States 10019
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
202 370 7450
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
ARTEMIS, A BARINGS COMPANY
Number and Street 1: Number and Street 2:
5404 WISCONSIN AVENUE SUITE 1150 10TH FLOOR
City: State: Country: ZIP+4/Postal Code:
CHEVY CHASE Maryland United States 20815
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
202 370 7450
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
ARTEMIS, A BARINGS COMPANY
Number and Street 1: Number and Street 2:
THE HARDIN BUILDING, 1380 WEST PACES FERRY RD 3RD FLOOR SUITE 3100
City: State: Country: ZIP+4/Postal Code:
ATLANTA Georgia United States 30327
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
202 370 7450
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
13379 JURUPA AVE
City: State: Country: ZIP+4/Postal Code:
FONTANA California United States 92337-7800
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
8009343453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
16028 MARQUARDT AVE OPM #001825
City: State: Country: ZIP+4/Postal Code:
CERRITOS California United States 90703-2347
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
8009343453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
6935 FLANDERS DR
City: State: Country: ZIP+4/Postal Code:
SAN DIEGO California United States 92121-2975
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
8009343453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
8661 KERNS ST
City: State: Country: ZIP+4/Postal Code:
SAN DIEGO California United States 92154-6286
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
8009343453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
1070 KENNEDY RD
City: State: Country: ZIP+4/Postal Code:
WINDSOR Connecticut United States 06095-1303
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
8009343453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
200 COMMERCIAL ST
City: State: Country: ZIP+4/Postal Code:
WATERTOWN Connecticut United States 06795-3309
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
8009343453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
13700 NW 2ND ST
City: State: Country: ZIP+4/Postal Code:
SUNRISE Florida United States 33325-6201
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
8009343453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
2625 W ROOSEVELT RD
City: State: Country: ZIP+4/Postal Code:
CHICAGO Illinois United States 60608-1015
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
2425 S HALSTED ST
City: State: Country: ZIP+4/Postal Code:
CHICAGO Illinois United States 60608-5091
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
4175 CHANDLER DR CHICAGO DISTRICT
City: State: Country: ZIP+4/Postal Code:
HANOVER PARK Illinois United States 60133-6769
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
1301 S ROCKWELL ST
City: State: Country: ZIP+4/Postal Code:
CHICAGO Illinois United States 60608-1659
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
7605 DORSEY RUN RD
City: State: Country: ZIP+4/Postal Code:
JESS Maryland United States 20794-9364
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
5104 CHIN PAGE RD
City: State: Country: ZIP+4/Postal Code:
DURHAM North Carolina United States 27703-8064
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
2012 TW ALEXANDER DR
City: State: Country: ZIP+4/Postal Code:
DURHAM North Carolina United States 27703
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
6100-P HARRIS TECHNOLOGY BLVD
City: State: Country: ZIP+4/Postal Code:
CHARLOTTE North Carolina United States 28269
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
6100 HARRIS TECH BLVD SUITE A
City: State: Country: ZIP+4/Postal Code:
CHARLOTTE North Carolina United States 28269
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
218 W YARD RD
City: State: Country: ZIP+4/Postal Code:
FEURA BUSH New York United States 12067-9704
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
37 HURDS CORNERS RD
City: State: Country: ZIP+4/Postal Code:
PAWLING New York United States 12564-2400
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
ROUTE 9W SOUTH 10-15
City: State: Country: ZIP+4/Postal Code:
PORT EWEN New York United States 12466
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
ROUTE 9W SOUTH 16
City: State: Country: ZIP+4/Postal Code:
PORT EWEN New York United States 12466
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
15333 HEMPSTEAD RD
City: State: Country: ZIP+4/Postal Code:
HOUSTON Texas United States 77040-3011
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
2630 CENTER STREET
City: State: Country: ZIP+4/Postal Code:
HOUSTON Texas United States 77007-6010
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
1110 S 3800 W STE 300
City: State: Country: ZIP+4/Postal Code:
SALT LAKE CITY Utah United States 84104-5509
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
1665 S 5350 W
City: State: Country: ZIP+4/Postal Code:
SALT LAKE CITY Utah United States 84104-4721
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-800-934-3453
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940
Name of entity where books and records are kept:
BLOOMBERG
Number and Street 1: Number and Street 2:
731 LEXINGTON AVENUE
City: State: Country: ZIP+4/Postal Code:
NEW YORK New York United States 10017
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
212-318-2000
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN BOOKS AND RECORDS REQUIRED BY SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 AND RELEVANT UK FINANCIAL CONDUCT AUTHORITY (FCA)RECORD
KEEPING REQUIREMENTS ARE ARCHIVED AT BLOOMBERG.
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:
Australia - Australian Securities and Investments Commission
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
Australia
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):
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
No Information Filed
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.
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:
ARTEMIS REAL ESTATE PARTNERS FUND II GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS FUND II GP, LLC
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.
No Information Filed
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:
MASSMUTUAL ASCEND LIFE INSURANCE COMPANY
2. Primary Business Name of Related Person:
MASSMUTUAL ASCEND LIFE INSURANCE COMPANY
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.
No Information Filed
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:
BARINGS (U.K.) LIMITED
2. Primary Business Name of Related Person:
BARINGS (U.K.) LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
802 - 75339
or
Other
4. Related Person's
(a) CRD Number (if any):
158277
(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?
EXEMPT REPORTING ADVISER - SECTION 203(M) OF THE INVESTMENT ADVISERS ACT
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
United Kingdom - Financial Conduct 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:
BARING ASSET MANAGEMENT (ASIA) LIMITED
2. Primary Business Name of Related Person:
BARING ASSET MANAGEMENT (ASIA) LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 56176
or
Other
4. Related Person's
(a) CRD Number (if any):
108513
(b) CIK Number(s) (if any):
CIK Number
1624302
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?
FOREIGN PRIVATE ADVISER EXEMPTION - SECTION 203(B)(3) OF THE INVESTMENT ADVISERS ACT
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
Hong Kong - Securities and Futures Commission
South Korea - Financial Supervisory Commission / Financial Supervisory Service
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:
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
2. Primary Business Name of Related Person:
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
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
225602
1306394
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
Other - HONG KONG - INSURANCE 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:
BARING FUND MANAGERS LIMITED
2. Primary Business Name of Related Person:
BARING FUND MANAGERS LIMITED
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
United Kingdom - Financial Conduct 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:
BARING INTERNATIONAL FUND MANAGERS (IRELAND) LIMITED
2. Primary Business Name of Related Person:
BARING INTERNATIONAL FUND MANAGERS (IRELAND) LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
802 - 114742
or
Other
4. Related Person's
(a) CRD Number (if any):
300157
(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?
EXEMPT REPORTING ADVISER - SECTION 203(M) OF THE INVESTMENT ADVISERS ACT
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 - Quebec, Financial Markets Authority
Ireland - Central Bank of Ireland
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:
BARINGS SINGAPORE PTE. LTD.
2. Primary Business Name of Related Person:
BARINGS SINGAPORE PTE. LTD.
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
Singapore - Monetary Authority of Singapore
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:
BARING ASSET MANAGEMENT KOREA LIMITED
2. Primary Business Name of Related Person:
BARING ASSET MANAGEMENT KOREA LIMITED
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?
FOREIGN PRIVATE ADVISER EXEMPTION - SECTION 203(B)(3) OF THE INVESTMENT ADVISERS ACT
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
South Korea - Financial Supervisory Commission / Financial Supervisory Service
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:
ARTEMIS REAL ESTATE PARTNERS FUND III GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS FUND III GP, LLC
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.
No Information Filed
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:
CRPTF - ARTEMIS TRANSITION ASSETS GP HOLDINGS, LLC
2. Primary Business Name of Related Person:
CRPTF - ARTEMIS TRANSITION ASSETS GP HOLDINGS, LLC
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.
No Information Filed
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:
ARTEMIS REAL ESTATE PARTNERS INCOME AND GROWTH FUND GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS INCOME AND GROWTH FUND GP, LLC
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.
No Information Filed
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:
ARTEMIS REAL ESTATE PARTNERS INCOME & GROWTH FUND II SEPARATE ACCOUNT GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS INCOME & GROWTH FUND II SEPARATE ACCOUNT GP, LLC
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.
No Information Filed
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:
ARTEMIS REAL ESTATE PARTNERS DEBT FUND GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS DEBT FUND GP, LLC
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.
No Information Filed
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:
ARTEMIS REAL ESTATE PARTNERS CREDIT OPPORTUNITIES FUND GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS CREDIT OPPORTUNITIES FUND GP, LLC
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.
No Information Filed
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:
CRE LEGAL ADVISORS, LLC
2. Primary Business Name of Related Person:
CRE LEGAL ADVISORS, LLC
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.
No Information Filed
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:
ARTEMIS REAL ESTATE PARTNERS HEALTHCARE FUND II GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS HEALTHCARE FUND II GP, LLC
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.
No Information Filed
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:
ARTEMIS REAL ESTATE PARTNERS FUND IV GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS FUND IV GP, LLC
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.
No Information Filed
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:
ARTEMIS REAL ESTATE PARTNERS HEALTHCARE FUND I GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS HEALTHCARE FUND I GP, LLC
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.
No Information Filed
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:
ARTEMIS REAL ESTATE PARTNERS INCOME AND GROWTH FUND II GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS INCOME AND GROWTH FUND II GP, LLC
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.
No Information Filed
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:
BARINGS AUSTRALIA PROPERTY PTY LTD
2. Primary Business Name of Related Person:
BARINGS AUSTRALIA PROPERTY PTY LTD
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.
No Information Filed
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:
BARING INTERNATIONAL INVESTMENT LTD
2. Primary Business Name of Related Person:
BARING INTERNATIONAL INVESTMENT LTD
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 15160
or
Other
4. Related Person's
(a) CRD Number (if any):
105724
(b) CIK Number(s) (if any):
CIK Number
1568131
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 - Manitoba Securities Commission
Canada - Quebec, Financial Markets Authority
United Kingdom - Financial Conduct 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:
BARINGS INVESTMENT MANAGEMENT (SHANGHAI) LIMITED
2. Primary Business Name of Related Person:
BARINGS INVESTMENT MANAGEMENT (SHANGHAI) LIMITED
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
China, People's Republic of - China Securities Regulatory Commission
Other - CHINA - ASSET MANAGEMENT ASSOCIATION OF CHINA
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:
BARINGS JAPAN LIMITED
2. Primary Business Name of Related Person:
BARINGS JAPAN LIMITED
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?
FOREIGN PRIVATE ADVISER EXEMPTION - SECTION 203(B)(3) OF THE INVESTMENT ADVISERS ACT
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
Japan - Financial Services Agency
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:
BARINGS SWITZERLAND SÀRL
2. Primary Business Name of Related Person:
BARINGS SWITZERLAND SÀRL
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.
No Information Filed
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:
JEFFERIES FINANCE LLC
2. Primary Business Name of Related Person:
JEFFERIES FINANCE LLC
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 74480
or
Other
4. Related Person's
(a) CRD Number (if any):
162264
(b) CIK Number(s) (if any):
CIK Number
1898590
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.
No Information Filed
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:
BARINGS SECURITIES LLC
2. Primary Business Name of Related Person:
BARINGS SECURITIES LLC
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
8 - 47589
or
Other
4. Related Person's
(a) CRD Number (if any):
36929
(b) CIK Number(s) (if any):
CIK Number
930012
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 - Nova Scotia Securities Commission
Canada - Ontario Securities Commission
Canada - Prince Edward Island, Securities Office
Canada - Quebec, Financial Markets Authority
Canada - Saskatchewan Financial Services Commission
Other - CANADA - NEW BRUNSWICK FINANCIAL AND CONSUMER SERVICES COMMISSION
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:
GREAT FALLS ADVISORS, LLC
2. Primary Business Name of Related Person:
GREAT FALLS ADVISORS, LLC
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.
No Information Filed
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:
ARTEMIS REAL ESTATE PARTNERS HEALTHCARE FUND II SIDECAR-C GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS HEALTHCARE FUND II SIDECAR-C GP, LLC
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.
No Information Filed
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:
BARING SICE (TAIWAN) LIMITED
2. Primary Business Name of Related Person:
BARING SICE (TAIWAN) LIMITED
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?
FOREIGN PRIVATE ADVISER EXEMPTION - SECTION 203(B)(3) OF THE INVESTMENT ADVISERS ACT
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
Other - TAIWAN - SECURITIES INVESTMENT TRUST AND CONSULTING ASSOCIATION
Taiwan - Financial Supervisory Commission
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:
COUNTERPOINTE INVESTMENT MANAGEMENT LLC
2. Primary Business Name of Related Person:
COUNTERPOINTE INVESTMENT MANAGEMENT LLC
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 132763
or
Other
4. Related Person's
(a) CRD Number (if any):
333864
(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.
No Information Filed
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:
ARTEMIS REAL ESTATE PARTNERS HEALTHCARE FUND III GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS HEALTHCARE FUND III GP, LLC
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.
No Information Filed
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:
ARTEMIS REAL ESTATE PARTNERS HEALTHCARE FUND III SIDECAR-C GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS REAL ESTATE PARTNERS HEALTHCARE FUND III SIDECAR-C GP, LLC
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.
No Information Filed
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:
ARTEMIS CLP PORTFOLIO CO-INVEST GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS CLP PORTFOLIO CO-INVEST GP, LLC
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.
No Information Filed
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:
ARTEMIS HEALTHCARE FUND III SENIORS HOUSING SIDECAR-R GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS HEALTHCARE FUND III SENIORS HOUSING SIDECAR-R GP, LLC
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.
No Information Filed
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:
ARTEMIS SENIORS SMA-R, GP, LLC
2. Primary Business Name of Related Person:
ARTEMIS SENIORS SMA-R, GP, LLC
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.
No Information Filed
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:
BARINGS OVERSEAS INVESTMENT FUND MANAGEMENT (SHANGHAI) LIMITED
2. Primary Business Name of Related Person:
BARINGS OVERSEAS INVESTMENT FUND MANAGEMENT (SHANGHAI) LIMITED
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
China, People's Republic of - China Securities Regulatory Commission
Other - CHINA - ASSET MANAGEMENT ASSOCIATION OF CHINA
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:
BARINGS REAL ESTATE ADVISERS INC.
2. Primary Business Name of Related Person:
BARINGS REAL ESTATE ADVISERS INC.
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.
No Information Filed
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:
BARINGS AUSTRALIA ASSET MANAGEMENT PTY LTD
2. Primary Business Name of Related Person:
BARINGS AUSTRALIA ASSET MANAGEMENT PTY LTD
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.
No Information Filed
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:
MASSMUTUAL PRIVATE WEALTH & TRUST, FSB
2. Primary Business Name of Related Person:
MASSMUTUAL PRIVATE WEALTH & TRUST, FSB
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
1103653
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.
No Information Filed
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:
C.M. LIFE INSURANCE COMPANY
2. Primary Business Name of Related Person:
C.M. LIFE INSURANCE COMPANY
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.
No Information Filed
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:
BARINGS LLC
2. Primary Business Name of Related Person:
BARINGS LLC
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 241
or
Other
4. Related Person's
(a) CRD Number (if any):
106006
(b) CIK Number(s) (if any):
CIK Number
9015
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 - Manitoba Securities Commission
Canada - Nova Scotia Securities Commission
Canada - Ontario Securities Commission
Canada - Quebec, Financial Markets Authority
Ireland - Central Bank of Ireland
Netherlands - The Netherlands Authority for the Financial Markets
Other - CANADA - NEW BRUNSWICK FINANCIAL AND CONSUMER SERVICES COMMISSION
Other - IRELAND - IRISH FINANCIAL SERVICES REGULATORY AUTHORITY
South Korea - Financial Supervisory Commission / Financial Supervisory Service
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:
MML BAY STATE LIFE INSURANCE COMPANY
2. Primary Business Name of Related Person:
MML BAY STATE LIFE INSURANCE COMPANY
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
924777
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.
No Information Filed
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:
BARING ASSET MANAGEMENT LIMITED
2. Primary Business Name of Related Person:
BARINGS
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
802 - 114253
or
Other
4. Related Person's
(a) CRD Number (if any):
299118
(b) CIK Number(s) (if any):
CIK Number
1606779
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?
EXEMPT REPORTING ADVISER - SECTION 203(M) OF THE INVESTMENT ADVISERS ACT
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
China, People's Republic of - China Securities Regulatory Commission
Dubai - Dubai Financial Services Authority
Other - ABU DHABI - FINANCIAL SERVICES REGULATORY AUTHORITY (FSRA)
United Kingdom - Financial Conduct 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:
GRYPHON CAPITAL INVESTMENTS PTY LTD
2. Primary Business Name of Related Person:
GRYPHON CAPITAL INVESTMENTS PTY LTD
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
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
No Information Filed
SECTION 7.B.(2) Private Fund Reporting
1. Name of the private fund:
BARINGS CAPITAL GLOBAL CREDIT FUND (LUX) SCSP, SICAV-SIF
2. Private fund identification number:
(include the "805-" prefix also)
805-3891127030
3. Name and SEC File number of adviser that provides information about this private fund in Section 7.B.(1) of Schedule D of its Form ADV filing
Name:
BARING INTERNATIONAL FUND MANAGERS (IRELAND) LIMITED
SEC File Number:
802 - 114742
Yes No
4. Are your clients solicited to invest in this private fund?
In answering this question, disregard feeder funds' investment in a master fund. For purposes of this question, 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.
1. Name of the private fund:
BARINGS GLOBAL INVESTMENT FUND
2. Private fund identification number:
(include the "805-" prefix also)
805-1303641090
3. Name and SEC File number of adviser that provides information about this private fund in Section 7.B.(1) of Schedule D of its Form ADV filing
Name:
BARING INTERNATIONAL FUND MANAGERS (IRELAND) LIMITED
SEC File Number:
802 - 114742
Yes No
4. Are your clients solicited to invest in this private fund?
In answering this question, disregard feeder funds' investment in a master fund. For purposes of this question, 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.
1. Name of the private fund:
BARINGS GLOBAL PRIVATE LOAN FUND 4 SCSP
2. Private fund identification number:
(include the "805-" prefix also)
805-5288868123
3. Name and SEC File number of adviser that provides information about this private fund in Section 7.B.(1) of Schedule D of its Form ADV filing
Name:
BARING INTERNATIONAL FUND MANAGERS (IRELAND) LIMITED
SEC File Number:
802 - 114742
Yes No
4. Are your clients solicited to invest in this private fund?
In answering this question, disregard feeder funds' investment in a master fund. For purposes of this question, 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.
1. Name of the private fund:
BARINGS GLOBAL PRIVATE LOAN FUND 4(S) SCSP
2. Private fund identification number:
(include the "805-" prefix also)
805-6549237149
3. Name and SEC File number of adviser that provides information about this private fund in Section 7.B.(1) of Schedule D of its Form ADV filing
Name:
BARING INTERNATIONAL FUND MANAGERS (IRELAND) LIMITED
SEC File Number:
802 - 114742
Yes No
4. Are your clients solicited to invest in this private fund?
In answering this question, disregard feeder funds' investment in a master fund. For purposes of this question, 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.
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 Name, DE/FE/I Title or Date Title or Status Ownership Control PR CRD No. If None: S.S. No. and Date of Birth,
First Name, Middle Name) Status Acquired MM/YYYY Code Person IRS Tax No. or Employer ID No.
BARINGS AUSTRALIA HOLDING COMPANY PTY FE SOLE OWNER 10/2009 E Y N
LTD
HOUGH, AMANDA, JANE I SECRETARY 10/2015 NA Y N 6629977
HOOLEY, JUSTIN, RYAN I DIRECTOR 09/2022 NA Y N 7716607
GAFFNEY, MICHAEL, EVIN I DIRECTOR 01/2024 NA Y N 2939235
SARANTIS, PENNY, MAREE I SECRETARY 12/2024 NA Y N 8066448
Wright, Alastair, John Dilworth I DIRECTOR 01/2026 NA N N 8245724
BURGESS, OLIVIA, HARRISON I COMPLIANCE 08/2025 NA N N 8245725
OFFICER
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.
FULL LEGAL NAME (Individuals: DE/FE/I Entity in Which Interest Status Date Status Ownership Control PR CRD No. If None: S.S. No.
Last Name, First Name, Middle is Owned Acquired Code Person and Date of Birth, IRS Tax
Name) MM/YYYY No. or Employer ID No.
BARINGS LLC DE BARING ASSET SOLE OWNER 10/2009 E Y N 106006
MANAGEMENT (ASIA)
HOLDINGS LIMITED
MM ASSET MANAGEMENT HOLDING DE BARINGS LLC SOLE MEMBER 02/2012 E Y N
LLC
MASSMUTUAL HOLDING LLC DE MM ASSET MANAGEMENT SOLE MEMBER 01/2012 E Y N
HOLDING LLC
MASSACHUSETTS MUTUAL LIFE DE MASSMUTUAL HOLDING SOLE MEMBER 07/2004 E Y N
INSURANCE COMPANY LLC
BARING ASSET MANAGEMENT FE BARINGS AUSTRALIA SOLE MEMBER 12/2017 E Y N
(ASIA) HOLDINGS LIMITED HOLDING COMPANY PTY
LTD
BARINGS AUSTRALIA HOLDING FE BARING ASSET SOLE MEMBER OF BARINGS 06/2014 E Y N
COMPANY PTY LTD MANAGEMENT (ASIA) AUSTRALIA HOLDING
HOLDINGS LIMITED COMPANY PTY LTD
Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.
Part 1 A, Schedule A/C Direct Owners and Executive Officers - Jon Millin does not have a middle name to report. SECTION 2B - BARINGS AUSTRALIA PTY LTD PRINCIPAL
OFFICE AND PLACE OF BUSINESS ARE OUTSIDE OF THE UNITED STATES AND IT DOES NOT MANAGE ANY PRIVATE FUND ASSETS AT A PLACE OF BUSINESS IN THE UNITED
STATES.
DRP Pages
CRIMINAL DISCLOSURE REPORTING PAGE (ADV)
No Information Filed
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., 11.E., 11.F. or
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: MASSACHUSETTS MUTUAL LIFE
INSURANCE COMPANY
(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)
STATE OF CONNECTICUT INSURANCE DEPARTMENT
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
10/03/2017 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
MC 18-87
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Insurance
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF CONNECTICUT INSURANCE DEPARTMENT CONDUCTED A MARKET CONDUCT EXAMINATION FOR THE PERIOD JANUARY 1, 2014 THROUGH DECEMBER 31,
2016 OF MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY ("MASSMUTUAL"). MASSMUTUAL IS THE PARENT OF MML INVESTMENT ADVISERS, LLC. AT THE
CONCLUSION OF THE EXAMINATION, THE STATE OF CONNECTICUT INSURANCE DEPARTMENT ALLEGED THAT MASSMUTUAL VIOLATED SUBSECTIONS 38A-15 AND 38A-
702M OF THE CONNECTICUT GENERAL STATUTES.
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:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
04/26/2019 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: $ 61,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
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:
MASSMUTUAL AGREED TO PROVIDE THE STATE OF CONNECTICUT INSURANCE DEPARTMENT WITH A SUMMARY OF ACTIONS TAKEN TO COMPLY WITH THE
RECOMMENDATIONS IN THE MARKET CONDUCT REPORT WITHIN 90 DAYS AND MASSMUTUAL AGREED TO PAY A FINE IN THE AMOUNT OF $61,000
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).
DURING THE PERIOD UNDER EXAMINATION (JANUARY 1, 2014-DECEMBER 31, 2016), THE STATE OF CONNECTICUT INSURANCE DEPARTMENT ALLEGED THAT
MASSMUTUAL, IN CERTAIN INSTANCES, FAILED TO FOLLOW ESTABLISHED PRACTICES AND PROCEDURES TO ENSURE COMPLIANCE WITH STATUTORY REQUIREMENTS
RESULTING IN: 35 PRODUCERS ACTING AS AGENTS WITHOUT BEING APPOINTED; 1 INSTANCE WHERE IT FAILED TO RETURN PREMIUM IN A TIMELY MANNER; 5
INSTANCES WHERE IT FAILED TO PROVIDE DOCUMENTATION FOR REGULATORY REVIEW; AND 1 INSTANCE WHERE IT FAILED TO RESPOND TIMELY TO A WRITTEN
REQUEST FOR INFORMATION.
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., 11.E., 11.F. or
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: MASSACHUSETTS MUTUAL LIFE
INSURACE COMPANY
(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)
MARYLAND INSURANCE ADMINISTRATION
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
04/12/2022 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
MIA-2023-04-018
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Insurance
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN 2003 THE INSURED PURCHASED A FLEXIBLE PREMIUM ADJUSTABLE LIFE INSURANCE POLICY WITH A FACE AMOUNT $500,000. IT WAS ALLEGED THAT MASSMUTUAL
RAISED THE PREMIUMS AND CHANGED AND CANCELLED THE POLICY WITHOUT NOTIFYING THE INSURED. THE INSURED FURTHER ALLEDGED THAT THE AGENT DID NOT
EXPLAIN THAT THE PREMIUM WOULD BE ADJUSTED ANNUALLY AND THAT THE AGENT MISREPRESENTED THE PRODUCT.
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:
Order
11. Resolution Date (MM/DD/YYYY):
04/26/2023 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: $ 1,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
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 MARYLAND INSURANCE COMMISSION ENTERED AN ORDER AGAINST MASSMUTUAL, AND WITHIN 30 DATS OF THE DATE OF ORDER, MASSMUTUAL WILL PAY AN
ADMINISTRATIVE PENALTY OF $1,000.
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).
THE STATE OF MARYLAND DETERMINED THAT MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY ("MASSMUTUAL") VIOLATED THE CODE OF MARYLAND REGULATIONS
("COMAR") 31.09.15.11 AND THEREFORE SUBSECTION 4-113 OF THE INSURANCE ARTICLE BY FAILING TO SEND ANNUAL REPORTS TO AN INSURED IN 2020 AND 2021.
THE ADMINISTRATION DID NOT FIND A VIOLATION BY MASSMUTUAL IN ITS OTHER ACTIONS COMPLAINED BY COMPLAINANT. THE MARYLAND INSURANCE COMMISSION
ENTERED AN ORDER AGAINST MASSMUTUAL, AND WITHIN 30 DAYS OF THE DATE OF THE ORDER, MASSMUTUAL WILL PAY AN ADMINISTRATIVE PENALTY OF $1,000.
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., 11.E., 11.F. or
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: MASSACHUSETTS MUTUAL LIFE
INSURACE COMPANY
(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)
STATE OF WASHINGTON OFFICE OF THE INSURANCE COMMISSIONER
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
05/26/2022 Exact Explanation
If not exact, provide explanation:
DATE OF 2021 ANNUAL CERTIFICATION PROVIDED TO THE OFFICE OF THE INSURANCE COMMISSIONER ON 5/26/2022, WITH AN EXPLANATION.
4. Docket/Case Number:
23-0147
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Insurance
Other Product Types:
LONG TERM CARE
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY MUST CERTIFY ANNUALLY TO THE OFFICE OF THE INSURANCE COMMISSIONER ("OIC") THE INSURANCE
PRODUCERS THAT ARE SELLING, SOLICITING OR NEGOTIATING THE COMPANY'S LONG TERM CARE ("LTC") INSURANCE PRODUCTS HAVE COMPLETED LTC
REQUIREMENTS. THE CERTIFICATION IS REQUIRED TO BE SUBMITTED ANNUALLY TO THE OIC OR BEFORE MARCH 31ST. MASSACHUSETTS MUTUALS LIFE INSURANCE
COMPANY WAS GRANTED AN EXTENSION TO FILE ITS 2021 ANNUAL CERTIFICATION REPORT BY MAY 31, 2022. THE STATE OF WASHINGTON OIC ALLEGED THAT
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY FAILED TO VERIFY THAT TWO INSURANCE PRODUCERS HAD RECEIVED THE REQUIRED LTC TRAINING BEFORE
THEY WERE PERMITTED TO SELL, SOLICIT, OR OTHERWISE NEGOTIATE THE SALE OF THE COMPANY'S LTC INSURANCE PRODUCTS. BY FAILING TO VERIFY THE
TRAINING, IT WAS ALLEGED THAT THE COMPANY VIOLATED RCW 48.83.130(4), JUSTIFYING THE IMPOSITION OF A FINE UNDER RCW 48.83.160.
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:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
09/08/2023 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: $ 10,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
THE COMPANY (MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY) ACKNOWLEDGED ITS DUTY TO COMPLY FULLY WITH THE APPLICABLE LAWS OF THE STATE
OF WASHINGTON AND CONSENTED TO THE ENTRY OF THE ORDER, WAIVED ANY AND ALL HEARING OR OTHER PROCEDURAL RIGHTS, AND FURTHER
ADMINISTRATIVE OR JUDICIAL CHALLENGES TO THE ORDER. BY AGREEMENT OF THE COMPANY AND THE INSURANCE COMMISSIONER, A FINE OF $10,000 IS
REQUIRED TO BE PAID WITHIN 30 DAYS. THE COMPANY UNDERSTOOD AND AGREED THAT ANY FURTHER FAILURE TO COMPLY WITH THE STATUTES AND/OR
REGULATIONS THAT ARE THE SUBJECT OF THE ORDER WOULD CONSTITUTE GROUNDS FOR FURTHER PENALTIES WHICH MAY BE IMPOSED IN DIRECT RESPONSE
TO FURTHER VIOLATIONS.
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:
BY FAILING TO VERIFY THAT TWO INSURANCE PRODUCERS HAD RECEIVED THE REQUIRED LTC TRAINING BEFORE PERMITTING TO SELL, SOLICIT, OR OTHERWISE
NEGOTIATE THE SALE OF THE COMPANY'S LTC INSURANCE PRODUCTS, THE COMPANY VIOLATED RCW 48.23.130(4), JUSTIFYING THE IMPOSITION OF A FINE OF
$10,000 AGAINST MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY UNDER RCW 48.83.160. THE COMPANY HAS PAID THE FINE.
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).
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY MUST CERTIFY ANNUALLY TO THE OFFICE OF THE INSURANCE COMMISSIONER ("OIC") THE INSURANCE
PRODUCERS THAT ARE SELLING, SOLICITING OR NEGOTIATING THE COMPANY'S LONG TERM CARE ("LTC") INSURANCE PRODUCTS HAVE COMPLETED LTC
REQUIREMENTS. THE CERTIFICATION IS REQUIRED TO BE SUBMITTED ANNUALLY TO THE OIC OR BEFORE MARCH 31ST. MASSACHUSETTS MUTUALS LIFE INSURANCE
COMPANY WAS GRANTED AN EXTENSION TO FILE ITS 2021 ANNUAL CERTIFICATION REPORT BY MAY 31, 2022. MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY
SUBMITTED THE CERTIFICATION ON MAY 26, 2022, WHICH REVEALED THAT IT SELF-DISCLOSED THAT TWO PRODUCERS SOLD THREE LTC POLICIES TO WASHINGTON
CONSUMERS ON BEHALF OF THE COMPANY AND THE PRODUCERS WERE NOT IN COMPLIANCE WITH THE LTC EDUCATION REQUIREMENTS AT THE TIME OF THE SALES.
RCW 48.83.130(4) REQUIRES ISSUERS TO OBTAIN VERIFICATION THAT A PRODUCER RECEIVES TRAINING BEFORE ETHE PRODUCERS IS PERMITTED TO SELL, SOLICIT
OR NEGOTIATE THE ISSUER'S LTC INSURANCE PRODUCTS. WAC 284-17-262(1) PROVIDES THAT EACH ISSUER THAT HAS LTC POLICES APPROVED FOR SALE IN WA
MUST CERTIFY ANNUAL THAT ALL OF ITS PRODUCERS HAVE (A) COMPLETED THE 8 HR. ONE TIME LTC EDUCATION TRAINING COURSE REQUIRED BY RCW 48.83.130(1)
(A)(I) PRIOR TO SELLING, SOLICITING, OR NEGOTIATING THE COMPANY'S LTC COVERAGE IN WA; AND (B) IF DUE, COMPLETED THE REQUIRED 4 HOUR LTC CE
REQUIREMENT IMPOSED BY RCS 48.83.130(2)(B). BY FAILING TO VERIFY THAT TWO PRODUCERS HAD RECEIVED THE REQUIRED LONG-TERM CARE TRAINING PRIOR TO
SELLING, SOLICITING OR NEGOTIATING THE SALE OF THE COMPANY'S INSURANCE PRODUCTS, IT WAS ALLEGED THAT THE COMPANY HAS VIOLATED RCW 48.83.130(4)
JUSTIFYING A FINE UNDER RCW 48.83.160. THE INSURANCE COMMISSIONER CONSENTED TO SETTLE THE MATTER IN CONSIDERATION OF THE COMPANY'S PAYMENT OF
A FINE AND UPON SUCH TERMS AND CONDITIONS, INCLUDING (1) THE COMPANY ACKNOWLEDGES THE DUTY TO COMPLY FULLY WITH THE APPLICABLE LAWS OF THE
STATE OF WASHINGTON; AND (2) THE COMPANY CONSENTED TO THE ENTRY OF THE ORDER. BY AGREEMENT, THE INSURANCE COMMISSIONER IMPOSED A FINE IN THE
AMOUNT OF $10,000 TO BE PAID WITHIN 30 DAYS.
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., 11.E., 11.F. or
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: MASSACHUSETTS MUTUAL LIFE
INSURANCE COMPANY
(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)
STATE OF DELAWARE INSURANCE COMMISSIONER
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
03/31/2024 Exact Explanation
If not exact, provide explanation:
FINAL EXAMINATION REPORT
4. Docket/Case Number:
DOCKET NO. 5635
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Insurance
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IT WAS ALLEGED THAT MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY'S PRACTICES AND PROCEDURES DID NOT COMPLY WITH STATUTORY AND REGULATORY
PROVISIONS: 18 DEL ADMIN. C.§12034.0 LIFE INSURANCE SOLICITATION DEFINITIONS; 18 DEL. ADMIN C. §12045.2 DUTIES OF AGENTS AND BROKERS; 18 DEL. C.
§1204.7.1 DUTIES OF INSURERS THAT USE AGENTS OR BROKERS; 18 DEL. ADMIN. C. §12047.4 STANDARDS FOR BASIC ILLUSTRATIONS.
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:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
05/08/2025 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: $ 133,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
RESPONDENT SHALL IMMEDIATELY IMPLEMENT CORRECTIVE ACTIONS FOR ANY AND ALL EXCEPTIONS AND RECOMMENDATIONS INCLUDED IN THE FINAL
EXAMINATION REPORT AND SHALL REPORT THE COMPLETION OF THE CORRECTIVE ACTIONS TO THE DEPARTMENT WITHIN 30 DAYS OF THE DATE OF THE
CONSENT ORDER.
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:
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY PAID AN ADMINISTRATIVE PENALTY OF $133,500.00 ON MAY 6, 2025. NO PORTION OF THE
ADMINISTRATIVE PENALTY WAS WAIVED.
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 DEPARTMENT, THROUGH ITS EXAMINERS, CONDUCTED A TARGET MARKET CONDUCT EXAMINATION OF MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY'S
AFFAIRS AND PRACTICES AS OF MARCH 31, 2024. THE DEPARTMENT PROVIDED MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY WITH A VERIFIED WRITTEN
REPORT OF THE EXAMINATION AND MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY REVIEWED AND PROVIDED THE DEPARTMENT WITH COMMENTS ON THE
EXAMINATION REPORT. THE DEPARTMENT THROUGH ITS EXAMINERS PREPARED A FINAL REPORT OF THE EXAMINATION DATED AS OF MARCH 31, 2024 (THE FINAL
EXAMINATION REPORT). THE FINAL EXAMINATION REPORT CONCLUDED THAT MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY'S PRACTICES AND PROCEDURES
DID NOT COMPLY WITH STATUTORY AND REGULATORY PROVISIONS. MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY ACCEPTED THE FINAL EXAMINATION REPORT
AND WAIVED ANY RIGHT TO A HEARING AND AGREED THAT THE DEPARTMENT MAY FILE THE FINAL EXAMINATION REPORT WITHOUT ANY FURTHER MODIFICATIONS.
MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY PAID AN ADMINISTRATIVE PENALTY FOR THE VIOLATIONS IN THE AMOUNT OF $133,500.00 ON MAY 6, 2025. THE
DEPARTMENT WILL POST A COPY OF THE FINAL EXAMINATION REPORT AND THE STIPULATION AND CONSENT ON THE DEPARTMENT'S PUBLIC WEBSITE. WITHIN 1 YEAR
OF THE DATE OF THE FINAL EXAMINATION REPORT, THE DEPARTMENT MAY RE-EXAMINE THE EXCEPTIONS AND RECOMMENDATIONS IN THE FINAL EXAMINATION
REPORT AND DETERMINE WHETHER THE CORRECTIVE ACTIONS WERE APPROPRIATE, PROPERLY IMPLEMENTED AND EFFECTIVE.
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:
169697
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
MELISSA LAGRANT 03/27/2026
Printed Name: Title:
MELISSA LAGRANT CHIEF COMPLIANCE OFFICER AND MANAGING DIRECTOR
Adviser CRD Number:
169697