A. General Description of Advisory Firm SECOR Investment Advisors, LP (“SIA”) was established in 2010 and has offices in New York, New York. SECOR is a wholly-owned subsidiary of SECOR Asset Management, LP. Raymond Iwanowski and Duen Li (Tony) Kao collectively hold a majority stake in SECOR Asset Management, LP. Refer to Item 10 for a further description of SECOR Asset Management, LP and SECOR’s industry affiliations.

SECOR Investment Advisors (UK), LLP (“SIA UK” and, together with SIA, “SECOR”), which is indirectly owned by SAM, is a limited liability partnership formed in the United Kingdom that is authorized and regulated by the United Kingdom Financial Conduct Authority (FCA) and registered with the SEC as a relying adviser under umbrella registration with SIA. SIA UK provides non-discretionary investment management services similar to those provided by SIA. SAM owns SECOR Partners (UK), Ltd., the controlling parent entity of SIA (UK). SECOR Partners, LLC is the governing entity of SAM. Its managing members are Tony Kao and Raymond Iwanowski. B. Description of Advisory Services

SECOR offers discretionary and non-discretionary investment advisory services to U.S. and non-U.S. institutional clients, including employee pension and benefit plans and two pooled investment vehicles offered only to certain affiliated non-U.S. pension plans that are existing clients of SECOR. With the exception of one client and two “fund of funds”, SECOR generally does not have discretionary authority over its clients’ portfolios. As of December 31, 2019, SECOR has $14.6 billion in non-discretionary regulatory assets under management and $253 million in discretionary regulatory assets under management.

SECOR provides non-discretionary investment advisory services to two pooled investment vehicles offered only to certain affiliated non-U.S. pension plans that are existing clients of SECOR. Both non-discretionary pooled investment vehicles are “funds of funds”. SECOR also provides discretionary investment advisory services to two pooled investment vehicles that are “funds-of-one”. The discretionary pooled investment vehicles are also “fund of funds”. As former plan sponsors, SECOR’s staff considers its fiduciary mindset to be the hallmark of its business approach. SECOR works with clients as an “extension” of their staff, in what we refer to as an “insourcing” role. SECOR works with each client to determine appropriate risk and return objectives, customizes an investment strategy, tailors an implementation process, provides risk management tools, and monitors the program on an ongoing basis. We enhance the investment process through strategy implementation and monitoring on a “real- time” basis to ensure the investment program remains appropriate in light of stated objectives. SECOR generally works closely with clients on day-today management and investment of the clients’ accounts. In its capacity as a pension advisor, SECOR designs, implements and monitors investment strategies for clients. Among SECOR’s pension advisory services are the following: Asset-Liability Management (ALM)/Investment Policy and Research We believe the establishment of an appropriate strategic policy portfolio is the key determinant in a pension program’s success. With this recognition, SECOR believes a highly customizable approach in conducting ALM studies is essential to developing sound long-term investment policies:


• Collaborate with plan stakeholders, actuary and other professionals to develop investment plan objectives;
• Create capital market assumptions, including (as needed) new asset classes, overlays, other hedging programs, and non-linear strategies and liability proxies;
• Through SECOR’s propriety ALM model, incorporate complex liability rules, regulatory rules, benefit structures, and/or contribution rules, if required:

o Focus priority on the plan’s funded status; o Incorporate appropriate return-generating and risk-mitigating strategies; o Simulate range of median/downside outcomes; and/or o Select optimal portfolio in context of objective;


• Employ Monte Carlo portfolio optimization for each possible portfolio, which incorporates different economic scenarios and potential short-term risk and return-factor views;
• Work closely with the plan stakeholders to evaluate the series of potential investment strategies and select a portfolio that meets the initial plan objectives; and
• Develop the Investment Policy Statement; crystallizing the plan's investment objectives and agreed strategic investment policy. Tactical Asset Allocation and Investment Manager Selection

Tactical asset allocation and investment manager selection are key components to the implementation of the strategic investment policy. When implementing the strategic policy portfolio, the speed of the implementation is dictated by the current market environment. Shorter-term market fundamentals and technicals may differ relative to longer-term assumptions embedded within the ALM. SECOR believes opportunities remain for skilled investment managers and advisors who can identify, then exploit, these market dislocations for the benefit of our clients. Our views are evident across various levels including asset class, sub-asset class, investment manager, sector/industry, and/or risk characteristic/indicative levels. Investment manager selection is another key component to the implementation of the strategic policy portfolio. SECOR’s team possesses many years of portfolio management and investment manager research experience. The combination of these experiences sets SECOR apart from its competitors. SECOR’s investment manager selection due diligence process includes rigorous evaluation of both quantitative and qualitative attributes. We provide the following services within investment manager selection:
• Recommend portfolio weightings, investment vehicles and strategies;
• Select, hire, monitor, evaluate and terminate external investment managers;
• Advise on investment guidelines and benchmarks; and
• Assist with investment manager agreements (IMA) negotiations, fees, derivative documentation. Due to our robust working relationships with managers and understanding of their investment processes, we utilize managers to implement specific market views. This involves a close working relationship with investment managers to modify investment guidelines and benchmarks to reflect any tactical asset allocation views in an efficient and timely manner. Implementation and Portfolio Solutions At SECOR, academic research and theory are married with decades of practical experience to assist clients in developing asset allocation strategies that maximize asset efficiency. We strive to develop strategies that are innovative, cost-effective, feasible to implement, and practical to monitor and control. SECOR provides advice on the management and implementation of:
• Derivative overlay and liability hedging programs. o Currencies o Interest rate o Inflation o Tail risk hedging o Beta replication / quantitative indexing
• Manage rebalancing policy guidelines and asset mix re-balancing
• Manage plan cash, funding and liquidity requirements
• Oversee investment manager and strategy implementation and transitions o Develop proxy voting procedures. o Monitor securities lending program, if applicable. Risk Management, Monitoring, and Controls

Risk management is at the heart of SECOR’s investment philosophy. SECOR believes risk management is a continuous process. SECOR uses its proprietary integrated ALM implementation risk analyzer to evaluate through live market scenarios or stress-test under any historical scenario to sensitivity to macroeconomic factors and capital market valuations impacts on client portfolios. The client receives updates featuring information relating to:


• Plan-level investment and derivative risk exposure;
• Monitoring of plan’s alignment with strategic objectives;
• Management of counterparty exposures;
• Compliance with investment guidelines and regulatory requirements;
• Manager performance and compliance with the mandate; and/or
• Assessment of investment manager operations. Client Communications and Customized Reporting

SECOR understands trustees and investment committees’ fiduciary requirements. SECOR customizes educational seminars and materials designed to help educate trustees and investment committees on the various market and economic developments, investments, strategies, and financial trends. These customized educational materials include:
• Personal client service (on-site working partnership);
• Conduct regular and frequent client meetings;
• Customized and detailed performance and risk reporting;
• Trustee and Investment Committee reporting;
• Compliance reporting; and/or
• Customized client education programs. Note that, while SECOR provides extensive consultative services to its clients, it generally does not exercise discretion over, actively trade, or maintain custody over, its clients’ plan assets. C. Availability of Customized Solutions for Clients SECOR’s advisory services emphasize the customization of solutions for each client. D. Wrap Fee Programs As of the date of this Brochure, SECOR is not advising clients to participate in any wrap fee programs and is not itself serving as a manager in any wrap fee program.
E. Assets Under Management
As of December 31, 2019, SECOR has $14,641,061,822 in non-discretionary regulatory assets under management and $252,604,164 in discretionary regulatory assets under management. please register to get more info

A. Advisory Fees and Compensation
SECOR is compensated for providing advisory services to its clients as set forth in each client’s respective Investment Advisory Agreement (IAA). SECOR’s fee income comes exclusively in the form of advisory service fees. SECOR receives performance-based fees for one client. Advisory service fees typically are a percentage of the pension plan assets for which services are rendered.
Example: Advisory Service Fee Schedule for
SECOR
Client Assets (USD) Annual Fee Rate
First 2 Billion X basis points Next 2 Billion Y basis points Next 2 Billion Z basis points etc. … The percentages are negotiated on a case-by-case basis and are determined based upon a number of factors including but not limited to, the amount and type of work involved, the size of the portfolios or pension plans serviced by SECOR, and the amount of SECOR’s resources dedicated to providing the services.
B. Payment of Fees
Advisory service fees are billed quarterly in arrears at one quarter of the annual rate, or monthly in arrears at one twelfth of the annual rate based on a percentage of the client’s portfolio(s) or plan assets receiving services at the end of the previous quarter or month. The value of the portfolios and/or plan assets includes money market funds and cash balances.
C. Additional Fees and Expenses
The advisory service fees described above are for advisory services only and do not include any applicable transaction fees, taxes or commissions payable to third parties and are separate and distinct from fees and expenses charged by mutual funds, ETFs, separate account managers, which may be recommended to clients.
D. Prepayment of Fees
SECOR invoices fees in arrears on a quarterly or monthly basis. SECOR’s service may be terminated by either party upon written or oral notification in accordance with the applicable contractual notice of termination. Upon termination, the fees charged for advisory services will be pro-rated and a refund for any unearned fees will be issued. The client is responsible for paying for services rendered until the termination of the agreement. E. Additional Compensation and Conflicts of Interest We do not accept, and none of our Supervised Persons accepts, any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. please register to get more info

Performance-based fees are fees based on an increase in value of the assets of a client. An adviser charging performance fees to only some accounts faces a variety of conflicts because the adviser can potentially receive greater fees from its accounts having a performance-based compensation structure than from those accounts it charges a fee not directly derived from performance (e.g., an asset-based fee). As a result, the adviser may have an incentive to direct the best investment ideas to, or to allocate or sequence trades in favor of, the account that pays a performance fee. SECOR typically does not charge any performance-based fees to clients and, therefore, is not generally subject to the potential conflicts of interest that such arrangements create. With respect to one account that is a qualified client, we have entered into an incentive fee arrangement in compliance with Section 205(a)(1) of the Investment Advisors Act of 1940 and the exemptions available thereunder (including Rule 205-3). please register to get more info

SECOR provides discretionary and non-discretionary investment advisory services to U.S. and non-U.S. institutional investors, including employee pension and benefit plans. SECOR’s clients as of December 31, 2019 were pension plans and four pooled investment vehicles that are “funds of funds” please register to get more info

A. Methods of Analysis and Investment Strategies
Set forth below is a summary of key methods of analysis and investment strategies used for SECOR’s primary services, listed in Item 4(B) above. SECOR’s investment strategy recommendations can vary greatly from one client to another, depending on each respective client’s investment objectives and regulatory constraints. Generally, SECOR undertakes the following procedural steps when crafting and implementing a client’s investment strategy.
1. Evaluate the pension plan’s (the “Plan”) funded status.
SECOR, first, performs extensive consultative due diligence to learn more about its prospective client. SECOR’s team will perform its own proprietary evaluation of the Plan’s funded status. Factors feeding into this process are listed below. Better understand the Plan’s liability
• Actuarial Study - An outside actuarial firm will provide SECOR with an analysis of such Plan variables as: o Where the Plan is in its life cycle - for example, whether a new company has few retirees and a growing pool of participants. Older companies might have a large population of retirees and a diminishing number of active employee participants; o Average age of Plan participants (retirees vs. active employees); o Expected mortality rates; o Average maturity of expected Plan payments; and/or o Inflation Indexing (if applicable) - Some plans require an inflation hedge, while others are not as concerned about inflation.
• Regulatory framework / contribution requirements - expected changes in regulation(s) can affect a Plan’s funded status. Better understand the goals and constraints of the Plan sponsor
• Ability to make contributions
• Downside risk thresholds
• Outcome of previous Asset-Liability Management studies
• Key issues and concerns to the Plan trustees Work with trustees to define the investment universe and key decisions
• Asset classes to be considered
• Implementation constraints (size, legal, regulatory, etc.)
• Relevant capital market assumptions
• Potential need for derivative overlays and risk mitigation strategies (see #2 below)
• How to reduce the volatility of the Plan’s funded status - Depending upon the economic environment and implementation constraints, one plan may want to focus more on hedging its liabilities, while another plan may solely focus on improving the return on its assets (the Plan’s portfolio investments).
2. Identify ways to mitigate uncompensated portfolio risk.
Once SECOR gains a better understanding of the Plan’s funded status, the team will run an optimization to gauge the Plan’s funded status sensitivity with respect to a broad range of economic scenarios.
Translate risk and return into metrics that are intuitive and easy to understand

• Simulation - Run multi-year performance scenarios under various economic conditions, to identify unnecessary portfolio risk.
• Present Portfolio Hedging Ideas - Re-run performance scenarios with risk mitigation trade ideas included in the analysis. Focus on expected upside and downside cases across a variety of metrics.
3. Recommend and implement a strategic portfolio.
Upon presenting the Plan sponsors with its analysis, SECOR, then, works with the Plan sponsors to select portfolios appropriate to their goals and constraints.
Implementing a strategic portfolio

• Asset Class Allocation - Develop a plan to shift to an asset class mix that seeks to provide an attractive risk-adjusted portfolio performance. If approved by the Plan’s trustees, SECOR will help the Plan to adjust its investments in stocks, bonds, currencies, commodities, emerging markets, real estate, hedge funds, and other applicable investment choices.
• Select Optimal Roster of External Portfolio Managers - SECOR analyzes managers within a given investment space (e.g., European equity portfolio managers) and provides recommendations to the Plan as to which managers might provide the best risk-adjusted portfolio performance. If approved by the client, SECOR will help the Plan adjust its current line-up of external portfolio managers.
• On-going Monitoring and Oversight - SECOR helps the Plan monitor its investments and re- initiates the portfolio optimization process based upon client feedback.

B. Material, Significant or Unusual Risks Related to Investment Strategies
General Risks. SECOR’s investment advice entails a significant degree of risk. There is no guarantee that clients’ investment objectives will be achieved. There is no guarantee that investment opportunities discussed between SECOR and clients will be available to clients or capable of implementation on a cost-effective or timely basis. Each client must be able and have enough knowledge and experience in financial and business matters to be capable of evaluating the merits and risks of investing in SECOR’s investment strategies. Limited Information Regarding Portfolio Managers. Although SECOR receives information, including valuations, from prospective portfolio managers regarding such portfolio manager’s historical performance (if any), exposures, and investment strategy, in most cases SECOR will have little or no means of independently verifying the information supplied to it by such portfolio managers and will rely in large part on the limited information provided to it by such portfolio managers. Estimates and Valuations from Portfolio Managers. Interests in a portfolio fund generally are valued in accordance with the methods provided by the instruments governing such portfolio fund. These valuations may be provided by a portfolio manager to the portfolio fund based on the interim unaudited financial records of such portfolio fund, and, therefore, are subject to adjustment (upward or downward) upon the auditing of such financial records. The net asset values received by SECOR from such portfolio managers typically will be estimates only, subject to revision through the end of each underlying portfolio fund’s annual audit. Risk of Loss. There is no assurance that SECOR’s investment advice will be able to generate returns or that the returns will be commensurate with the risks inherent with the investment strategy. The marketability and value of any such strategic investment advice will depend upon many factors beyond the control of the SECOR. The past investment performance of SECOR’s investment strategies cannot be taken to guarantee future results. Management Risk. When any investment adviser provides bespoke investment advice to clients based on its investment skills and analytical abilities, there is a chance that such investment advice will not be successful or will not meet expectations and that subjective decisions made by such investment adviser may cause a client to incur losses or to miss profit opportunities. Asset Allocation Risk. Asset allocation risk is the risk that an investment adviser may allocate or recommend the allocation of a client’s assets to an asset class or mandate that underperforms other asset classes or mandates during a given period of time. Moreover, some asset classes may be less liquid or provide less protection against various risks than other asset classes. Investment and Market Risk. All investment recommendations are subject to investment risk, including the possibility of losing the entire principal amount. A recommendation to invest in a particular manager or strategy also may involve market risk and information risk. When investment advice is based on information received from clients, investment managers and/or other third parties, there is a chance that such information may be materially inaccurate. In this regard, investment advisers may rely significantly on the accuracy and completeness of the information provided by clients and third parties without independent verification of such information. Furthermore, an investment adviser may not be able to detect fraud by another investment manager. Likewise, an investment adviser may not ensure that an investment manager is complying with stated guidelines that have otherwise been disclosed.
C. Risks Associated with Particular Types of Securities
Not applicable.
D. Risks Particular to Pandemics, including COVID-9
Investments may be affected by public health events including, without limitation, outbreaks of an infectious disease, pandemic or any other serious public health concern, including COVID- 19. Certain events may adversely affect the ability of a party (including SECOR or a counterparty) to perform its obligations. An infectious disease outbreak could have a broader negative impact on the world economy or international business activity. Prolonged changes due to these events may have a significant negative impact on the value and performance of investments, SIM’s ability to source, manage, value and divest investments, and a client’s ability to achieve its investment objectives. As of March 2020, the outbreak of COVID-19 has adversely impacted global public health and commercial activity and contributed to significant volatility in certain markets, including equity, debt and commodities markets. The global impact of the outbreak is rapidly evolving. Public health precautionary measures taken by governments, businesses and individuals, as well as the general uncertainty surrounding the dangers and impact of COVID-19, are creating significant disruption in supply chains and economic activity. The potential impacts of COVID-19, including global, regional or other economic recession, as well as the scale of such impacts, are uncertain and difficult to assess.
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There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. please register to get more info

A. Broker-Dealer Registration Status
Not applicable.
B. Futures Commission Merchant Commodity Pool Operator, or Commodity Trading
Adviser Registration Status.
Not applicable.
C. Material Relationships or Arrangements with Industry Participants
SECOR is one of two U.S. investment advisory firms that are wholly owned by SECOR Asset Management, LP (“SAM”) and registered with the SEC. The other firm is SECOR Investment Management, LP (“SIM”). SIM provides discretionary investment management services to institutions and pooled investment vehicles. MassMutual’s Babson Capital Management, LLC (“Babson”) purchased a minority, passive non- controlling interest in SAM in September 2011. Babson acquired less than 10% of SAM. In September 2016, Babson completed the integration of four Massachusetts Mutual Life Insurance Company (MassMutual) institutional affiliates (previously announced on March 9, 2016). Babson and its subsidiaries, Cornerstone Real Estate Advisers LLC, Wood Creek Capital Management, LLC, and Baring Asset Management Limited are now operating as a unified company under the “Barings” name. SECOR does not believe that Barings’ ownership interest creates any material conflict of interest with clients.

SAM and its affiliates are collectively referred to herein as the “SECOR Management Group”. Entities within the Group share certain personnel and other resources. The interrelationships among the above entities present potential conflicts of interest, including but not limited to, the following: Resource Allocation: SECOR Management Group personnel may have conflicts in allocating their time and services among their clients. Such personnel will devote as much time to each client as is appropriate for the SECOR Management Group to perform its duties in accordance with its client agreements;
• Trade Allocation: SECOR Management Group may face conflicts in allocating limited investment opportunities among clients with similar investment objectives or hedging requirements. While SECOR Management Group will attempt to allocate such limited investment opportunities on a fair and equitable basis, there is no guarantee that every client will participate in such opportunities as fully as every other client;
• Potential Impact of Trades: The purchase or sale of a security or investment position with limited liquidity in one client’s account may temporarily inflate or depress the market price of the security or investment position, thereby having an adverse impact upon the value of any account holding that position and/or the ability of such account to liquidate its position;
• Potential Impact of Liquidations: The liquidation of a security or investment position with limited liquidity in one client’s account may temporarily depress the market price of that security or investment instrument, thereby having an adverse impact upon the value of any account holding that position and/or the ability of such account to liquidate its position; and
• Potential Impact of Aggregation: The positions of clients of the SECOR Management Group may be aggregated for purposes of position limits, reporting requirements, and other regulatory requirements and prohibitions. As a result, some clients may not be able to hold as large a position in a particular security as they would be able to hold if their position were not aggregated with those of other clients.
D. Material Conflicts of Interest Relating to Other Investment Advisers
When appropriate for a particular client, SIA and SIA UK may recommend that a client utilize services provided by their affiliate SIM. Prior to recommending SIM to a particular client, SIA and SIA UK always inform the client of their relationship with SIM and give the client the opportunity to ask questions and receive answers in this regard. SIA and SIA UK do not represent recommendations of SIM to their clients as being “independent”. please register to get more info

Transactions and Personal Trading

A. Code of Ethics
SECOR recognizes and believes (i) that high ethical standards are essential for its success and to maintain the confidence of its clients; (ii) that its long-term business interests are best served by adherence to the principle that the interests of clients come first; and (iii) that it has a fiduciary duty to its clients to act for their benefit. All SECOR personnel must put the interests of its clients before their own personal interests and must act honestly and fairly in all respects in dealings with clients. All SECOR personnel must also comply with all federal securities laws. SECOR has adopted a Code of Ethics governing personal trading by its personnel. Among other requirements, all personnel must seek pre-approval from the Chief Compliance Officer (“CCO”) for certain personal trades, must report their personal securities transactions and holdings to the CCO, and must report to the CCO when they believe that a violation of the Code of Ethics has occurred. Clients or prospective clients may obtain a copy of the Code of Ethics by contacting SECOR’s Chief Compliance Officer via phone at 212-980-7350. Inquiries can also be sent via email to [email protected]. Gifts and Entertainment SECOR has considered the risk that employees might be improperly influenced by excessive gifts or entertainment. SECOR has also considered the risk that employees might try to use gifts or entertainment to exert improper influence on another individual or entity. SECOR has established a policy to mitigate such risks by establishing limits and reporting obligations relating to gifts and entertainment. Political and Charitable Contributions Political contributions by SECOR or SECOR’s supervised persons to politically connected individuals or entities with the intention of influencing such individuals or entities for business purposes are strictly prohibited. SECOR strictly prohibits its supervised persons, as well as any affiliated entity, from making political contributions to any state or local government entity, official, candidate, political party, or political action committee. B. Securities In Which SECOR or a Related Person Has a Material Financial Interest Not applicable. C. Investing in Securities That SECOR or a Related Person Recommends to Clients We require that our personnel obtain preapproval prior to engaging in any transaction in a “reportable security” within the meaning of SEC Rule 204A-1 (with certain limited exceptions). D. Conflicts of Interest Created by Contemporaneous Trading Our personal trading policy allows employees to purchase or sell similar securities to those purchased and sold for our investment products, subject to our approval process. In general, we expect that our pre-approval process will reduce the risk of contemporaneous trading. please register to get more info

A. Factors Considered in Selecting or Recommending Broker-Dealers
a. Research and Other Soft Dollar Benefits
SECOR does not exercise discretion over or trade individual company securities in client assets and therefore does not participate in any soft dollar agreements with broker-dealers.
b. Brokerage for Client Referrals
Not applicable.
c. Directed Brokerage
Not applicable.
B. Order Aggregation and Trade Allocation
SECOR does not exercise discretion over or trade individual company securities in client assets and therefore does not aggregate or allocate orders.
C. Trading Errors
Not applicable. please register to get more info

A. Frequency and Nature of Review of Client Accounts or Financial Plans SECOR’s review process is generally systematic. Formal reviews of client portfolios are conducted monthly and, informally, on a weekly basis. The formal review is constrained to a monthly cycle, because SECOR requires the official numbers from the client's custodian before it can properly assess asset allocation and performance. A more informal review of client accounts is done on a weekly basis, using the most recent month-end positioning. Using unofficial and stale position data is not ideal, but it still allows SECOR to extrapolate benchmark returns and create a pro forma weekly portfolio review. B. Factors Prompting Review of Client Accounts Other than a Periodic Review Item 13.B. is not applicable; we do not provide these services to clients. C. Content and Frequency of Account Reports to Clients SECOR provides customized reports to clients which are generally completed on a quarterly basis. These risk reports include asset allocation, performance and performance attribution summaries. Additionally, these reports illustrate the underlying risk factors and exposures of the client’s pension plan. If clients desire a more frequent update on these risk reports, SECOR can produce risk reports on a monthly basis. please register to get more info

A. Economic Benefits for Providing Services to Clients Not applicable. B. Compensation to Non-Supervised Persons for Client Referrals Not applicable. please register to get more info

In its capacity as a pension advisor, SECOR does not generally have custody of any client funds or securities. SECOR generally sends out invoices to its clients, who then generally pay advisory service fees via wire transfer. SECOR does not have any fee debit authority. SECOR does have custody with respect to two pooled investment vehicles (both “fund of funds”). These funds are audited in accordance with U.S. generally accepted accounting principles (“GAAP”) by an independent public accounting firm that is registered with, and subject to regular inspections by, the Public Company Accounting Oversight Board (“PCAOB”). The audited financial statements are distributed to investors within 120 days of year-end. Fund assets are held at a “qualified custodian.” SECOR does not have custody with respect to one of the four pooled investment vehicles (also a “fund of funds”). This fund is regulated under the laws of the Grand Duchy of Luxembourg, by the Commission de Surveillance du Secteur Financier (“CSSF”), the Luxembourg supervisory commission of the financial sector in Europe. please register to get more info

Generally, SECOR does not maintain discretionary authority to manage portfolios on behalf of its clients. The scope of SECOR’s investment practices and relationships with clients are granted through the clients’ respective investment management agreements. SECOR has accepted authority to manage one client’s assets on a discretionary basis. Before accepting this authority, SECOR executed an investment management agreement with the client. SECOR works closely with the client to develop custom investment guidelines for each assignment. The investment guidelines dictate the restrictions and limitations placed on SECOR’s investment authority. With respect to this one client, SECOR generally has the ability to leverage and otherwise encumber the assets in the client’s accounts and to transfer assets among the client’s accounts. please register to get more info

Generally speaking, as a pension advisor, SECOR does not recommend any individual company securities, so there is a relatively remote chance that it would need to engage in client consultation regarding a proxy vote. However, SECOR may advise its clients to invest in an external manager whose hedge fund is listed on an exchange (e.g., a CUSIP listed in Ireland or Luxembourg). It is possible in this scenario for the hedge fund to call a proxy vote by its investors, at which point SECOR would need to consult with its client (the investor in the hedge fund). Investment personnel will consider whether SECOR is subject to any material conflict of interest in connection with each proxy vote. SECOR personnel must notify the CCO if they are aware of any potential material conflict of interest associated with a proxy vote. If the CCO and/or SECOR detect a material conflict of interest in connection with a proxy solicitation, the CCO may seek input from a proxy voting service and/or outside counsel. The CCO will record the third-party recommendation(s) and will then vote the proxy, based upon its determination as to what is in the best interests of the client. please register to get more info

A. Balance Sheet This item is inapplicable as we do not require or solicit prepayment of fees six months or more in advance. B. Financial Conditions Likely to Impair Ability to Meet Contractual Commitments to Clients Not applicable. C. Bankruptcy Filings Not applicable. please register to get more info