Deficiencies in Examinations Noted By the SEC

The SEC Staff has noted language in documents used by the Registrant appears to be inconsistent with Rule 21 F-17. The Registrant’s separation agreement between the Firm and the employee (“separation agreement”) states, in relevant part:

Confidentiality Section … you may use Confidential Information solely: (i) to the extent that such use is approved in advance by the managing partner of the firm; … or (v) to the extent necessary or required by law, legal process, court order, or lawful subpoena, provided that, to the extent practicable, (A) you will provide the Firm with prompt notice so that the Firm may seek a protective order or other appropriate remedy and/or waive your compliance with the provisions of this paragraph, and (B) in the event that such protective order or other remedy is  not obtained, or the Firm waives your compliance with the provisions of this paragraph, you will furnish only that portion of the Confidential Information which is legally required.

The above language in this separation agreement may impede the Registrant’s former personnel from communicating with the Commission Staff and, accordingly, may be inconsistent with Rule 21 F-l 7(a).