Determining Whether Required to File Form 13F

An institutional investment manager, which includes an investment adviser firm, (“Manager”) must use Form 13F for reports to the SEC required by Section 13(f) of the Securities Exchange Act of 1934 (“Exchange Act”).

Rule 13F-1 provides that every Manager which exercises investment discretion with respect to accounts holding Section 13(f) securities having an aggregate fair market value on the last trading day of any month of any calendar year of at least $100,000,000 shall file a report on Form 13F with the SEC within 45 days after the last day of such calendar year and within 45 days after the last day of each of the first three calendar quarters of the subsequent calendar year.