Disclosures - Belle Haven Investments

Important Disclosures and Regulatory Information

Belle Haven Investments, L.P. is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser and is a member of the Financial Industry Regulatory Authority (“FINRA”), and the Municipal Securities Rulemaking Board (“MSRB”). Additional information regarding Belle Haven, including the Firm's Form ADV filings and Form CRS Relationship Summary, is available through the SEC's Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov.

CLIENT RELATIONSHIP SUMMARY (FORM CRS)

Brokerage and investment advisory services and fees differ, and it is important for retail investors to understand these differences. Free and simple tools are available to research firms and financial professionals at www.investor.gov/CRS which also provides educational materials regarding broker-dealers, investment advisers and investing.

Additional information regarding Belle Haven, including the Firm’s Form ADV filings and Form CRS Relationship Summary, is available through the SEC's Investment Adviser Public Disclosure website can be at https://adviserinfo.sec.gov/firm/summary/29278.

Belle Haven Investments, L.P. Form CRS Relationship Summary - March 2026

Belle Haven Investments, L.P. Disclosure Brochure - May 2026

FORM ADV PART 2A

This brochure provides information about the qualifications, business practices, services, fees, and conflicts of interest of Belle Haven Investments, L.P. (“Belle Haven”). If you have any questions regarding the contents of this brochure or would like additional information, please contact us at (914) 816-4633 or by email at compliance@bellehaven.com.

The information contained in this brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Belle Haven is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Registration as an investment adviser does not imply a certain level of skill, training, expertise, or endorsement by the SEC or any governmental authority.

Additional information regarding Belle Haven, including the Firm's Form ADV filings and Form CRS Relationship Summary is available through the SEC's Investment Adviser Public Disclosure website at https://adviserinfo.sec.gov/firm/summary/29278.

Belle Haven Investments, L.P. - Form ADV Part 2A - March 2026

PRIVACY NOTICE

Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) is committed to protecting the confidentiality, integrity, and security of the nonpublic personal information entrusted to us by current, former, and prospective clients. This Privacy Notice describes the categories of information Belle Haven may collect, how such information may be used or shared, and the safeguards maintained to protect such information in accordance with applicable federal laws and regulations.

Belle Haven does not sell nonpublic personal information to nonaffiliated third-parties. The Firm may disclose nonpublic personal information as permitted or required by law, including as necessary to service client relationships, process transactions, administer accounts, comply with legal and regulatory obligations, respond to lawful requests, or otherwise support the operation and administration of the Firm’s advisory and brokerage services.

Belle Haven maintains administrative, technical, and physical safeguards designed to protect nonpublic personal information against unauthorized access, use, alteration, or disclosure. Access to such information is limited to personnel, affiliates, service providers, and other parties who require such access to perform legitimate business, operational, regulatory, or servicing functions on behalf of the Firm.

If you have any questions regarding this Privacy Notice or would like additional information regarding Belle Haven’s privacy practices, please contact the Firm at (914) 816-4633 or compliance@bellehaven.com.

Belle Haven Investments, L.P. - Privacy Notice March 2026

ERISA 408(b)(2) DISCLOSURE STATEMENT

Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) provides disclosures intended to assist covered plan fiduciaries in satisfying their responsibilities under Section 408(b)(2) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”).

These disclosures are designed to provide certain information regarding the services provided by Belle Haven, the Firm’s compensation, and potential conflicts of interest, as required under applicable ERISA regulations. This information should be reviewed in conjunction with Belle Haven’s Form ADV Part 2A Brochure, applicable investment management agreements, and any other governing account documentation or supplemental disclosures provided by the Firm.

The information contained in this disclosure is intended solely for use by ERISA plan fiduciaries, plan administrators, or other authorized representatives responsible for evaluating the reasonableness of compensation and services provided to an employee benefit plan or other covered arrangement under ERISA.

Belle Haven Investments L.P. ERISA 408(B)(2) Disclosure Statement March 2026

BUSINESS CONTINUITY PLAN

Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) maintains a Business Continuity Plan (“BCP”) reasonably designed to support the continuation of critical business operations in the event of a significant business disruption (“SBD”), including disruptions resulting from natural disasters, public health events, technology outages, cybersecurity incidents, power or telecommunications failures, or other emergency situations.

The Firm’s Business Continuity Plan is intended to support the protection of client information, the continuation of essential operations, and communication with clients, employees, custodians, counterparties, regulators, and other service providers during periods of disruption.

Belle Haven’s principal office is located at 800 Westchester Avenue, Suite N607, Rye Brook, New York 10573. The Firm’s primary telephone number is (914) 816-4633. In the event Belle Haven cannot be reached through its primary contact number, clients may contact the Firm at (914) 816-4622.

Clients may also contact Belle Haven’s clearing firm, BNY Pershing, LLC (“Pershing”), at (201) 413-3333 or by visiting www.pershing.com for certain account-related inquiries. In addition, clients may contact their account custodian directly regarding access to account information, funds, or securities.

Belle Haven Investments, L.P. - Business Continuity Plan Disclosure Statement

Belle Haven Investments, L.P. - Business Continuity Plan - Pandemic Mitigation and Airborne Infectious Disease Exposure Prevention Plan Statement

ORDER ROUTING

Disclosure Pursuant to SEC Rule 606 - Order Routing

Pursuant to Rule 606 under the Securities and Exchange Act of 1934, Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) is required to make available certain information regarding its order routing practices for client equity and option orders.

Belle Haven routes client equity and option orders to its clearing firm, BNY Pershing, LLC (“Pershing”), for execution. Information regarding Pershing’s order routing practices and Rule 606 disclosures is available at https://www.orderroutingdisclosure.com.

INVESTOR EDUCATION AND REGULATORY RESOURCES

SECURITIES INVESTOR PROTECTION CORPORATION (“SIPC”) INFORMATION
Information regarding the Securities Investor Protection Corporation ("SIPC"), including the SIPC brochure and additional educational materials, may be obtained by contacting SIPC via its website at www.sipc.org or by telephone at (202) 371-8300.

FINANCIAL INDUSTRY REGULATORY AUTHORITY (“FINRA”) INVESTOR EDUCATION AND PROTECTION
Information regarding FINRA BrokerCheck, investor education resources, and FINRA's Public Disclosure Program may be obtained from FINRA at www.finra.org. Investors may also contact the FINRA BrokerCheck hotline at (800) 289-9999 or by accessing https://brokercheck.finra.org/.

MUNICIPAL SECURITIES RULEMAKING BOARD (“MSRB”) RULE G-10 INVESTOR AND MUNICIPAL ADVISORY CLIENT EDUCATION AND PROTECTION
Information regarding municipal securities investor protections, municipal market disclosures, and procedures for filing complaints with an appropriate regulatory authority is available through the Municipal Securities Rulemaking Board ("MSRB") website, including access to the MSRB Investor Brochure required under MSRB Rule G-10 at www.msrb.org.

ANTI-MONEY LAUNDERING: CUSTOMER IDENTIFICATION PROGRAM

Important Information About Procedures for Opening a New Account

To help the government combat the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record information that identifies each person or entity opening an account.

As part of Belle Haven Investments, L.P.’s (“Belle Haven” or the “Firm”) Customer Identification Program (“CIP”), the Firm may request certain identifying information and documentation from individuals and entities seeking to establish an account or maintain a client relationship. Such information may include, but is not limited to, name, address, date of birth, taxpayer identification number, organizational formation documents, government-issued identification, or other information necessary to verify identity.

Belle Haven reserves the right to restrict, suspend, or decline to establish or maintain an account or client relationship if requested information or documentation is not provided, cannot be verified, or otherwise raises regulatory, legal, compliance, or risk-related concerns.

Belle Haven complies with applicable anti-money laundering (“AML”) laws and regulations, including sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).

FIRM AND WEBSITE DISCLOSURES

The views and opinions expressed herein are those of Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) as of the date indicated and are subject to change without notice. The information provided is for informational and educational purposes only and should not be construed as investment advice, a recommendation, offer, or solicitation to buy or sell any security, or to adopt any investment strategy. Information presented is not intended to serve as a primary basis for investment decisions.

Information contained herein has been obtained from sources believed to be reliable; however, Belle Haven does not represent or warrant the accuracy, completeness, or timeliness of such information. References to third-party websites, articles, publications, or other content are provided for informational purposes only and do not constitute an endorsement, sponsorship, or approval by Belle Haven of any third-party, its products, services, or opinions.

Certain material may contain forward-looking statements, projections, estimates, or other predictive information that reflects assumptions and expectations regarding future events or market conditions. Actual results and outcomes may differ materially from those expressed or implied. Any forward-looking statements are inherently subject to uncertainty and should not be relied upon as guarantees of future events, performance, or results.

Material may also include hypothetical, targeted, projected, or illustrative performance information for informational purposes only. Such information does not represent the performance of any actual client account or the actual trading of client assets and has inherent limitations. Hypothetical performance results are prepared with the benefit of hindsight and are based on assumptions that may not reflect actual market conditions, economic factors, trading activity, or client-specific constraints. Certain hypothetical or projected information may rely on assumptions regarding market conditions, reinvestment rates, issuer behavior, or portfolio characteristics that may not reflect actual future events. Actual client results may differ materially from any hypothetical or illustrative examples presented.

Investing involves risk, including the possible loss of principal. Fixed income investments are subject to various risks, including, but not limited to, interest rate risk, credit risk, issuer risk, market risk, liquidity risk, inflation risk, reinvestment risk, and call risk. Municipal securities may be less liquid than other fixed income investments and may be subject to additional risks, including changes in tax laws, issuer financial condition, or market conditions. Income from municipal securities may be subject to state or local taxes, capital gains taxes, and, in certain circumstances, the alternative minimum tax (“AMT”). Tax-aware or tax-sensitive investment strategies may not be appropriate for all investors or account types.

Any investment objectives, portfolio characteristics, risk management techniques, or investment processes described herein represent goals or general approaches only and there can be no assurance that such objectives or strategies will be achieved or successful under all market conditions. Past performance is not indicative of future results.

Nothing contained herein should be construed as tax, accounting, or legal advice. Investors should consult their own professional advisers regarding their individual financial situation, tax circumstances, and investment objectives before making any investment decision.

This material is not directed to, or intended for distribution to or use by, any person or entity in any jurisdiction where such distribution, publication, availability, or use would be contrary to applicable law or regulation. No portion of this material may be reproduced, redistributed, transmitted, or otherwise disclosed, in whole or in part, without the prior written consent of Belle Haven.

Belle Haven Investments, L.P. is registered with the U.S. Securities and Exchange and Commission (“SEC”) as an investment adviser and is a member of the Financial Industry Regulatory Authority (”FINRA”) and Municipal Securities Rulemaking Board (“MSRB”). Additional information about Belle Haven, including the Firm’s Form ADV Part 2A Brochure and Form CRS, is available at www.adviserinfo.sec.gov.

Belle Haven claims compliance with the Global Investment Performance Standards (“GIPS®”). GIPS® is a registered trademark of the CFA Institute. The CFA Institute does not endorse or promote Belle Haven, nor does it warrant or guarantee the accuracy or quality of any information provided by the Firm. Additional information regarding Belle Haven’s GIPS-compliant composite presentations and related disclosures is available upon request by contacting service@bellehaven.com.

SOCIAL MEDIA DISCLOSURES

Content published, posted, shared, or otherwise disseminated by Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) through any social media platform, including but not limited to, LinkedIn, X, Spotify, YouTube, podcasts, or other digital communication channels (collectively, “Belle Haven Social Media Platforms”), is provided for informational and educational purposes only. Such content should not be construed as investment advice, a recommendation, offer, or solicitation to buy or sell any security or to adopt any investment strategy.

The views and opinions expressed are those of Belle Haven as of the date indicated and are subject to change without notice. Information contained in social media content has been obtained from sources believed to be reliable; however, Belle Haven does not represent or warrant the accuracy, completeness, or timeliness of such information.

Interactions with Belle Haven Social Media Platforms, including follows, likes, shares, reposts, comments, or other forms of engagement, should not be construed as endorsements of Belle Haven, its personnel, or its advisory services, nor should they be interpreted as testimonials regarding client experience or investment performance.

Any securities, sectors, market commentary, investment themes, or portfolio examples referenced are provided for illustrative or informational purposes only and do not represent all securities purchased, sold, or recommended for client accounts. There should be no assumption that any securities identified or discussed were or will be profitable. Belle Haven may or may not currently hold, or intend to hold, the securities referenced.

Certain content may contain forward-looking statements, projections, estimates, or other predictive information based on assumptions regarding future market or economic conditions. Actual results and outcomes may differ materially from those expressed or implied. Any forward-looking information is inherently subject to uncertainty and should not be relied upon as a guarantee of future performance or results.

Content published through Belle Haven Social Media Platforms may also include hypothetical, targeted, projected, or illustrative performance information for informational purposes only. Such information does not represent the performance of actual client accounts or actual trading and has inherent limitations. Hypothetical or illustrative results are prepared with the benefit of hindsight and may not reflect the impact of material economic, market, or client-specific factors. Actual client results may differ materially from any hypothetical or illustrative examples presented.

Investing involves risk, including the possible loss of principal. Fixed income investments are subject to various risks, including market risk, interest rate risk, credit risk, issuer risk, inflation risk, liquidity risk, reinvestment risk, and call risk. Municipal securities may be less liquid than other fixed income investments and may be subject to additional risks, including changes in tax laws, issuer financial condition, or market conditions. Income from municipal securities may be subject to state or local taxes, capital gains taxes, and, in certain circumstances, the alternative minimum tax (“AMT”). Past performance is not indicative of future results.

Nothing published through Belle Haven Social Media Platforms should be construed as tax, legal, or accounting advice. Investors should consult their own professional advisers regarding their individual financial situation, tax circumstances, investment objectives, and suitability considerations before making any investment decision.

Third-party content, hyperlinks, reposts, or references are provided solely for informational purposes and do not constitute an endorsement, sponsorship, or approval by Belle Haven of any third-party, its products, services, or opinions. Belle Haven does not control and is not responsible for the content, privacy practices, or security policies of external websites or third-party platforms.

Belle Haven does not accept trading instructions, account instructions, or transaction orders through social media platforms. Users are advised not to transmit personal, confidential, or account-related information through these channels. Belle Haven reserves the right to remove, restrict, or report content posted on its social media platforms, including content deemed inappropriate, misleading, promotional, offensive, or otherwise inconsistent with applicable laws, regulations, or Firm policies.

Belle Haven Investments, L.P. is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser and is a member of the Financial Industry Regulatory Authority (”FINRA”) and Municipal Securities Rulemaking Board (“MSRB”). Additional information about Belle Haven, including the Firm’s Form ADV Part 2A Brochure and Form CRS, is available at www.adviserinfo.sec.gov.

GENERAL INVESTMENT RISKS

Investing in securities involves risk, including the possible loss of principal, and clients should be prepared to bear such risks. The risks associated with fixed income investments will vary based on factors including the investment strategy employed, portfolio composition, market conditions, and the specific securities held within an account. There can be no assurance that any investment objective, risk management objective, or investment strategy will be successful or that a positive return will be achieved.

Fixed income investments are subject to various risks, including, but not limited to, interest rate risk, credit risk, default risk, issuer risk, market risk, liquidity risk, reinvestment risk, inflation risk, and call risk. In addition, portfolios may be subject to risks associated with sector concentration, geographic concentration, market volatility, changes in economic conditions, changes in tax laws, and evolving regulatory or market structures. Changes in interest rates, credit spreads, issuer financial condition, market liquidity, or broader economic conditions may adversely affect the value and performance of fixed income investments.

Municipal securities involve additional considerations and may not be appropriate for all investors or account types. Municipal bond income may be subject to federal, state, or local taxes, including capital gains taxes and, in certain circumstances, the alternative minimum tax (“AMT”). Tax-aware or tax-sensitive investment strategies, including tax loss harvesting, may not be suitable for all investors and may result in increased transaction activity, realized gains or losses, or associated costs.

Any investment processes, portfolio construction techniques, risk management approaches, or investment guidelines described by Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) represent general investment approaches or objectives only and should not be construed as guarantees or assurances regarding investment outcomes or risk mitigation. Past performance is not indicative of future results.

Additional information regarding the risks associated with Belle Haven’s investment strategies, services, and conflicts of interest is available in the Firm’s Form ADV Part 2A Brochure, which should be reviewed carefully prior to investing.

Materials prepared or distributed by Belle Haven are provided for informational purposes only and should not be considered a substitute for official account records. Custodial account statements, trade confirmations, and other records provided by a client’s custodian remain the official books and records for account holdings, transactions, and valuations. Clients are encouraged to review and compare all information received from Belle Haven with records provided by their custodian.

Nothing contained herein should be construed as tax, accounting, or legal advice. Each client’s financial and tax circumstances are unique, and investors should consult their own professional advisers regarding their individual situation, investment objectives, tax considerations, and suitability requirements before making any investment decision.

RATING DISTRIBUTION

Credit ratings are provided by nationally recognized statistical rating organizations (NRSROs) and are subject to change. Bond ratings, reflecting the issuer's financial strength, range from AAA (best) to D (worst) and may vary over time. Securities rated BBB and above are classified as investment-grade. Ratings are not a guarantee of credit quality and do not eliminate market risk. The holdings and characteristics of a portfolio, including their weightings, are subject to change and may fluctuate over time.

PERFORMANCE AND PORTFOLIO RISK DEFINITIONS

Definitions are provided for informational purposes only and are intended to assist investors in understanding commonly used investment, fixed income, and portfolio measurement terminology. Definitions and calculation methodologies may vary among industry participants, custodians, index providers, reporting platforms, and third-party data providers. Certain metrics may be based on assumptions, estimates, or prevailing market conditions and should not be viewed as guarantees of future performance or investment results.

Performance and risk statistics are shown for illustrative and informational purposes only and may be calculated using different methodologies, time periods, valuation sources, benchmarks, or assumptions than those used by other firms or reporting platforms. Portfolio characteristics, yields, durations, and other statistics are subject to change without notice and may differ from those shown in client-specific reports or custodial records.

Alpha is a statistical measure commonly used to evaluate an investment’s risk-adjusted return relative to a benchmark index.

Average Coupon represents the weighted average stated interest rate of the underlying bond holdings within a portfolio.

Average Maturity measures the weighted average length of time until the principal amount of the underlying bond holdings is scheduled to be repaid.

Average Rating refers to the market value-weighted average credit rating of portfolio holdings as assigned by nationally recognized statistical rating organizations (“NRSROs”), such as Moody’s Investors Service (“Moody’s”) and S&P Global Ratings (“S&P”). Securities that are not rated by an applicable rating agency may be excluded from the calculation. Credit ratings are subject to change and are not a guarantee of credit quality.

Benchmark refers to an index or comparative measure used to evaluate portfolio characteristics or investment performance. Indexes are unmanaged, unavailable for direct investment, and do not reflect fees, expenses, or transaction costs.

Beta is a statistical measure of an investment’s sensitivity or volatility relative to movements in a broader market index or benchmark.

Down Capture Ratio measures how a portfolio performs relative to a benchmark during periods when the benchmark experiences negative returns.

Duration is a measure of a bond’s or fixed income portfolio’s sensitivity to changes in interest rates.

Duration-to-Worst (“DTW”) measures the interest rate sensitivity of a bond or fixed income portfolio based on the assumption that the bond will be redeemed or called on the date that results in the lowest yield-to-worst outcome. Duration-to-Worst is commonly used for callable bonds and portfolios containing securities with embedded optionality.

Expected Yield-to-Worst (“Expected YTW”) represents an estimate of the lowest potential yield a bond or portfolio may generate, taking into account assumptions regarding expected calls, prepayments, redemptions, or other factors that may affect future cash flows. Expected Yield-to-Worst is based on assumptions and market expectations that may not be realized and may differ from actual investment results.

Modified Duration measures the estimated percentage change in the price of a bond or fixed income portfolio resulting from a change in interest rates. Generally, bonds or portfolios with higher modified duration are more sensitive to changes in interest rates than those with lower modified duration.

Projected Earned Annual Income represents an estimate of the annual income a bond or portfolio is expected to generate over a specified period based on current holdings, stated coupon rates, projected cash flows, and prevailing market assumptions. Projected Earned Annual Income is hypothetical in nature, subject to change, and does not represent or guarantee future income, yield, or investment performance.

R-Squared (“R²”) measures the percentage of an investment’s movements that may be explained by movements in its benchmark index.

Sharpe Ratio is a commonly used measure of risk-adjusted return that evaluates excess return relative to the volatility of returns.

Standard Deviation is a statistical measure of the variability or dispersion of investment returns relative to their average return over a specified period.

Tax-Equivalent Yield (TEY) is a calculation used to compare the yield of a tax-exempt investment to the yield of a taxable investment by adjusting for an assumed federal income tax rate and, where applicable, certain additional taxes.

Total Market Value represents the aggregate market value of all securities, cash, and other holdings within a portfolio or account based on current market prices or available pricing information as of a specified date. Market values are subject to change and may fluctuate due to market conditions, interest rates, credit factors, liquidity, or other economic and issuer-specific considerations.

Total Return measures the overall return of an investment over a specified period, including income, interest payments, and changes in market value.

Up Capture Ratio measures how a portfolio performs relative to a benchmark during periods when the benchmark experiences positive returns.

Yield-to-Maturity (YTM) represents the estimated total return anticipated on a bond if held until maturity, assuming all scheduled principal and interest payments are made.

Yield-to-Worst (YTW) represents the lowest potential yield that may be received on a bond without the issuer defaulting, taking into account applicable call features or other early redemption provisions.

AWARDS AND RECOGNITION

Any awards, rankings, recognitions, or references to third-party ratings referenced by Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) are issued by independent third-party organizations and may be based on a variety of quantitative and qualitative factors, including investment performance, assets under management, peer group comparisons, firm submissions, or other criteria established by the applicable third party. The criteria, methodologies, evaluation processes, and time periods used in determining such awards or rankings may vary among organizations and are subject to change without notice.

Third-party ratings, awards, or recognitions should not be construed as an endorsement, recommendation, or guarantee of future investment performance or client experience. Awards and rankings are not indicative of future results and may not be representative of any one client’s experience. In certain circumstances, participation in awards or ranking programs may require the submission of information by Belle Haven and may involve the payment of application, licensing, subscription, marketing, or other fees.

Belle Haven does not independently verify the accuracy, completeness, or consistency of third-party ratings, rankings, or methodologies and makes no representation regarding the appropriateness of any such award or recognition. Additional information regarding the criteria, methodologies, and assumptions used in determining any referenced award or ranking is available from the applicable third-party organization and/or upon request.

For additional information regarding Belle Haven’s investment strategies, services, or referenced awards and recognitions, please contact service@bellehaven.com.

Lipper Criteria

While the Lipper Investment Manager Database is very open in terms of accepting a variety of calculation and reporting methodologies, only those performance streams which meet the qualifications outlined below are considered for the World's Best Money Managers rankings.

Once again, Lipper does not imply or represent that only performance which meets these qualifications are "valid”. Rather, the qualifications are enforced for the sole purpose of ensuring comparability between managers. If you have any comments regarding these requirements, feel free to Contact Us.

Here are the minimum criteria for inclusion in Best Money Managers:

1. Performance must be calculated "net” of all fees and brokerage commissions. This means after all fees have been deducted.

This standard is somewhat controversial, as the SEC requires that only "net” of fees numbers be presented publicly, while GIPS (Global Investment Performance Standards) prefers that "gross” numbers be presented along with a fee schedule.

Since the SEC is a regulatory authority, and since complete fee schedule presentation would be impractical in this "ranking" format, we require "net” numbers.

2. Performance must be calculated inclusive of all cash reserves.

To explain, any given investment portfolio will hold some level of cash over a particular reporting period. Even equity portfolios which specifically seek to be fully invested in the market at all times will temporarily have dividend payments and other ordinary cash flows which cannot instantaneously be invested in the market.

These cash holdings obviously will have an effect on the performance of the overall portfolio – negative when cash returns are low relative to returns of the asset class, and positive if the opposite is true.

While presentation of "equity-only” (for example) returns may provide a valuable insight into the security selection skills of the manager, we require for comparability's sake that performance results be inclusive of cash reserves for consideration in the rankings.

3. Performance results must be calculated in U.S. dollars, that is, from the perspective of a U.S.-based investor.

Currency holdings can have a very significant impact on the performance of a portfolio with international holdings. While this will always be the case (as we do not make distinctions between hedged and unhedged portfolios), we require that performance must be translated into U.S. dollars to ensure comparability to the point where these are all returns that would be seen by a U.S.-based investor.

4. Performance results must be calculated on an asset base which is at least $10 million in size for "traditional” U.S. asset classes (equity, fixed income, and balanced accounts) or at least $1 million in the case of international and "alternative” U.S. asset classes.

This minimum ensures that the firm and product are somewhat established. The goal is to not taint the rankings with "flashes in the pan” while also not excluding promising emerging managers.

The minimum asset base requirement, therefore, is set at a level which balances these objectives.

5. The classification of the product must fall into one of the categories which we rank. We only publish rankings for categories/time period combinations for which we have at least 20 contenders.

PSN Top Guns Criteria

Commingled Fund Universes: include commingled funds and pooled funds.

Non-Commingled Fund Universes: include PSN Products excluding mutual funds, commingled funds, pooled funds collective trusts, limited partnerships, offshore funds, wrap products, hedge funds and MLP's.

1 QTR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. These top performers are strictly based on current quarter returns.

1 Year CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. These top performers are strictly based on returns for the one year period.

3 Year CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. These top performers are strictly based on returns for the three year period.

4 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. Products must have an r-squared of 0.80 or greater relative to the style benchmark for the recent five year period. Moreover, products must have returns greater than the style benchmark for the three latest three-year rolling periods. The top ten returns for the latest three-year period then become the TOP GUNS.

5 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. Products must have an R-Squared of 0.80 or greater relative to the style benchmark for the recent five year period. Moreover, products must have returns greater than the style benchmark for the three latest three-year rolling periods. Products are then selected which have a standard deviation for the five year period equal or less than the median standard deviation for the peer group. The top ten returns for the latest three-year period then become the TOP GUNS.

6 STAR CATEGORY: The peer groups were created using the information collected through the PSN investment manager questionnaire and uses only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. Products must have an R-Squared of 0.80 or greater relative to the style benchmark for the recent five year period. Moreover, products must have returns greater than the style benchmark for the three latest three-year rolling periods. Products are then selected which have a standard deviation for the five year period equal or less than the median standard deviation for the peer group. The top ten information ratios for the latest five-year period then become the TOP GUNS.

Manager of the Decade

Top Guns Manager of The Decade Criteria: The PSN universes were created using the information collected through the PSN investment manager questionnaire and use only gross of fee returns. PSN Top Guns investment managers must claim that they are GIPs compliant. Mutual fund and commingled fund products are not included in the universe. Products must have an r-squared of 0.80 or greater relative to the style benchmark for the latest ten year period. Moreover, products must have returns greater than the style benchmark for the latest ten-year period and also standard deviation less than the style benchmark for the latest ten-year period. At this point, the top ten performers for the latest ten-year period become the PSN Top Guns Manager of the Decade.

The content of PSN Top Guns is intended for use by qualified investment professionals. Please consult with an investment professional before making any investment decisions using content or implied content from PSN Top Guns. Due to the short term nature of a one quarter performance benchmark, please be advised that the 1 QTR PSN Top Guns award is intended for informational purposes only and should be used only in a one-on-one and face-to-face presentation where an investment professional is present. Any other usage of the 1 QTR PSN Top Guns is strictly prohibited, not advised, and not permitted by Informa Business Intelligence.

All Rights Reserved. PSN Top Guns is powered by PSN. PSN is an investment manager database and is a division of Informa Business Intelligence (IBI). No part of PSN Top Guns may be reproduced in any form or by any means, electronic, mechanical, photocopying, or otherwise without the prior written permission of Informa Business Intelligence.

Because of the possibility of human or mechanical error by IBI sources or others, IBI does not guarantee the accuracy, adequacy, completeness or availability of any information and is not responsible for any errors or omissions or for the results obtained from the use of such information. THERE ARE NO EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE. In no event shall IBI be liable for any indirect, special or consequential damages in connection with use of any information or derived using information based on PSN Top Guns results.

The content of the PSN Top Guns is intended for use by qualified investment professionals. Please consult with an investment professional before making any investment decisions using content or implied content from PSN Top Guns.