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W E D STATES SE-IES AND EXCHANGE COMMISSTON INFORMATION REQUEST LIST

Registrant File No.: Date: May 3,2006

Please fhmbh the infinmation listed below for the above-referenced entity. Please also use your judgment regarding whether rewrds quested in both electronic fbrmat and hard ~ o p y should only be provided electm~cally. Where necessary, furnish responses on Registrant's letterhead. Unless otherwise indicated, please provide the requested information for the time period of January 1, 2005 to April 28, 2006 (the "inspection period"). This request for information is divided into two main parts. The £ht parf which covers all items listed in Sections A and B, idenrifies infomation that is to be provided at the outset of the inspection. The second part, which includes all items in Section C, lists information that may be requested if Registrants compliance program is deemed to be weak or if other infirmation w e review indicates to us that additional smtiny of any area is necessary.

At .this time, cbpies need not be made of information in any of the secticms to which only access is requested- However, please have such infbrmation collecred and ready for the staffs rfzview. While certain information is specifically identified in this document, during the inspection thc staff may request additional information if it becomes necessary.

At the commencement of our fieldwork, we wodd like to speak with at least one member of senior management to obtain an overall view of Registrant's organization, business, control environment, and compliance culture. Also during our fieldwork, we would like to discuss in more d~tail with the Chief Compliance Officer and Risk Manager (if Registrant has such a position), and orher persons as relevant, Registrm's compliance program, as well as rhe specific compliance risks Registrant has identified and rhe policies and procedures used to mitigate and manage such risks in the areas listed in Section A. At various times during our fieldwork, we will also want to interview persons responsible for functions such as portfolio magemen\ trade execution, pricing, back office/administration, information technology, anti-money laundering, and marketing-

A- Risk Manamanent and Internal Controls

Rule 206(4)-7 under the Investment Adviser's A G ~ (compliance date October 5, 2004) is designed to protect investors by ensuring that all advisers have' internal programs to enhance compliance with the federal securities laws. To assist w in evaluating Rtgistrant's compliance program, please provide relevant infonnation that documents and substantiates the effectiveness of Registrant's compliance policies and procedures in each of the areas identified below. In addition to policies, procedures, and rmmpliance manuals, please make avaiIable documents such as: exception reports .together with documentation of fbllow-up work, completed compliance checklists, reconciliations, management reports, documents containing supevisory approval of overrides in various areas, warning or sanction notices to staff rhat violated a policy or-pmcedure, results of and related analpes of ~zansaccional (qualiry control) and forensic testing, follow-up work performed based upon such analyses, self-assessments of the effectiveness of Registrant's compliance policies and procedures, internal audit reports, and so on.

NOTE Jn responding to our requests f6r information below, you should provide infomation t3at demonstrates how the policies and procedures used by Registrant to mitigate and manage its compliance dsks are applied in practice- In this regard, procedures and compliance manuals represent a useful starting poinr; these manua1s do not, however, provide infformation about how compliance policies and procedures are being applied in practice or how effective such policies and procedures may be in preventing, detecting and correcting compliance problems As a result, you can demonstrate the effectiveness of your compliance processes only by providing documents that contain "output" &om the applicarion of such compliance policies and procedures to the daily work flows of Regisrrant.

Failure to provide inmation that documents how your compliance program operates in practice may result in our concluding that Registranr has weak or heffenive risk management and control processes and is not in compliance with Rule 206(4)-7,

Al. Registrant's overall process for and commitment to establishing and maintaining an effective compliance culture (its ̂ tone at the rap").

A2. The specific compliance policies, techniques and procedures used in achieving rhe fbllowing important objectives:

a. Portfolio management decisions are consistent with clients7 mandates (invcstmenr objectives, resmctions and risk tolerance), regulatory requiremcnts,~disclosures and fiduciary obligations.

Decisions made and costs incutred in establishing and maintaining Registrant's brokerage arrangements and placing orders (trades) frJr clients are consistent with maximizing the value of clients' accounts, disclosures made to clients, regulatory requirements and fiduciary obligations.

Allooarions among clients' awounts of IPOs, other investment opportunities, and blocked ad - crossed t d e s in issues traded on secondary.markets are fair and consistent with h~sclosures, regulatory requirements and fiduciary obligations-

Prices used to value positions in clients' accounts, including all clients that are commingled accounts/funds, reflect accurately current rrrarket conditions and the prices that could be realized upon a current sale of those positions; the process used to calculate NAVs of commingled accounts/funds results in consistently accurate allocations of the commingled accounts' ner assets among participantdhd shareholders and is consistent with disclosures and regularory requirements.

Advisory clients' assets, including those of commingled accounts/h~ds, are held and moved in ways that protect them from theft, misappmpiatioqmisuse, and loss.

,Information provided to advisory clients and commingled account/fiand shsreholdcn regarding mansactions in and balanccs of their accounts reflects accurately the actual transactions in and balances of those accounts and reflects fkirly all decisions affecting these accounts.

Personal trading activities of access persons and investment decisions for proprietary accounts of Registrant are consistent with codes of ethics, regulatory requirements, disclosures and fiduciary obligations.

Performance and other information used in advertisements and other r n a k ~ a p materials is c&culatG accurately and fairly and is used in ways that are not misleading and marketing and dislriibutioll activities are consistent with regulatory requirements and disclosures.

Information about Regisa-ant's operations and activily in client accounts is timely and accurarely~reateb capturd and compiled, and is safe ed fhm unauthorized acoess, use,

manipulation, alteration, and untimely destruction; such information is used to provide complete, accurate and timely reports and statements to management, clients, and regulators.

j. Registrant's compliance program is adequately designed and maintained so as to prevent, find and resolve violation^ of relevant statutes, rules and other regulatory guidance.

k. Anti-money laundering programs effkctively prevent,Regisrrant fhm being a uarhr ta monev laundering or tertorist financing schemes.

A3. ' Provide the following documents .pertaining to Registrant% compliance program:

a. A copy of the standard operating pcedures ("SOP") for the risk identification and assessment process, which is lbe process by which Registrant identifies risks and problems likely to be present at the adviser.

A copy of the minutes of any risk committee meetings that were held during the inspeotion period. Please note that advisers are not requiTed to have a risk committee.

A current inventory of compliance risks. If chainges were made to this inventory of risks during the inspection period, please indicate what these changes were and the corresponding date of the change. Plcase p v i & this information, if possible, in Word, Excel or tbe equivalent foxmat on 3.5-inch diskettes or CD-ROM/DVD.

A cunent list of and a corresponding copy of all compliance policies and procedures. (Yozr do not need to provide a copy ifyou intend to provide one ifi response to another item, please just r$menc& the appropriate response). In addition to providing a list of the complian~e policies and procedures, please also provide a list of corresponding compliance documents. These compliance documents may include exception reports, compliance check lists, management reports, etc. that are produced in accordance with the compliance policies and proceduree- Please provide this information, if possible, in Excel fbrmat on 3.5-inch diskettes or CD- ROMIDVD.

The SOP covering the process used tn create ,and maintain the co-mpliance policies and procedures mentioned above.

Any document Registrant has, such as a matrix 6r a spreadshet, that maps its inventory oft( risks idmtified above to its written policies anci procedures.

Information regarding the means by which Registrant's personnel have ready and continuing access to these policies and procedures.

If Registrant performed any forensic tests (i.e. compliance rests that a~ztllyze information over time in order to identifl unusual patterns) during the inspection period, perhaps as a component of its annual review of its compliance program, provide a list of the forensic tests performed, and the corresponding objectives and results of each forensic test

A copy of all annual and in~erim reports regarding the review of Registrant's compliance P r o P - A copy of any SOP that govcms the process used by Registrant to conduct the annual review of its compliance program and related report preparation.

Access to workpapers that were prepared during Regiswnt's reviews of its compliance program.

Access to reports, summaries and other information a fund received from,or. pcrtains to compliance programs and activities the fund's service providers.

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m. Access to Registrid's budgets or financial plans for compliance activities during the inspection period

B. Initial Requests for Information

Please provide items B1- B14 to ouroffice by Monday, May 8,2006..

B1. Registrant's organization chart, employee list and a schedule or chart of all affiliated entities. Please include all advisory representatives and/or indepadent contractors.

B2. A copy of rbe pspectus aud statement of additional information f i r each munral 5hd managed during the period.

B3- Form ADV Part I1 c m t l y furnished to clients and any alternative disclosure document given in conjunction with or in lieu of Part II. In addifion. please include a copy bf Registrant's Form ADV Part 1A.

B4, A copy of Regishant's Code of Ethics and insider trading policies and those of participating diliates, and a list of all access persons, including contract employees, required to repart traneactiom.

B5. Policies and procedures adopt& if not incorporated in Registrant's Code &Ethics, to address employee m n a l trading hardship exemptions from Registrant's personal trading policies.

B6. Access to written plans, policies, and procedures that provide guidance in preparing for and responding to emergencies, contingencies, and disasters.

B7. Documentation regarding the results of Registrant's most recent test of its business continuity plan-

B8. Registrant's trading blotter or purchase and sales journal for the October 1, 2005 through April 28, 2006, prefably formatted in Microsoft Excel as indicated in Exhibit 1, attached. Please also include the transactions of Registrant's access persons and proprietary accounts in this record.

B9. Registrant's current standard client advisory colltract or agreement.

B10. Registrant's fee scheduic(s) currently in use, if not stated in the advisary con-.

Ell. A copy of all advertisements (cg., newspaper or magazine ads, radio scripts, reprints, etc.) used to infann or solicit clients during the inspection period. If Registrant makes information about its services available on the Intemef including websites and blogs, please include a printout.

B12. A copy of any promotional brochures, pamphlets or other materials fbrnishcd to existing andlor prospective clients during the inspection period.

1813. A oopy of any composite or representative perfmnance reports, data or graphs disseminated to ~lients or prospective clients during. the period.

B14. Registrant's balance shee~ trial balance, income saternent, cash receipts and disbursements joumal, and cash flow statements dated as of the end of its most recent fiscal year and the most current year-to-date.

Page 4 of 10

Please provide Items B15 - BQ2.at the start of the examination.

BlS. Provide a wrirttn summary of any business transaction, investment oppornmity, deal, side deal, arrangement, or similar matter that, since January 1, 2005, Registrant was asked to consider but rejected because the proposal was deemed inadvisable, inappropriate, unethical or possibly illegal. The sunrmary should include a detailed descxiption of rhe matter, the name and contact information of all. involved firms and persons, and the reason(s) for rhe proposal being rejected Copies of any pertinent documents including letters or electronic commwications should also be provided.

'. B16. Provide &mplete information about all undisclased arrangements or side arrangements that adversely

impact advisory clients and d-1y or indirectly benefit any person or entity other than advisory clients.

817. A copy of any repat or letter sllbmiited to management by Registrartt's independent auditors concerning internal controls (including any report cm letter to the board of direotors o f any affiliated fund group).

B18. (i) A list of cu*t clients (excluding wrap fee clients) featuring far each:

a. ~ c c o k t number, awount name and the ammt balance;

b. Whether the client is a related person or a pmprietmy account;

c. Account custodian, including name and location;

d Type of account (e.g., individual, &mi$ office, defined benefit ~&rement plan, registered fund, private in-at fimd, other unregistered fund);

e. Jnvemnent strategy (e.g., global equity, high-yield, aggressive grmvth, long-short, statistical arbitrage);

f. Whether or nor Registrant has discretionary authorw,

g. Whether client has a dire!cted brokerage errangement (include narne of broker and purpose fbr such dimtion, if known);

h. Value of each olicnt's account at end of period that was used for purposes of calculating its advisory fee for the most recent billing period;

i. Whether the client pays a performance fe;

j. Whether the client noeives aecomt statements directly b m the custodian.

(ii) The W,value of assets under management fbr all clients combined.

Please provide this recold electronically, preferably formatted in Microsoft Excel-

B19. A list of clierrts lost during the inspection period, their e M v e dates of bdnatian, the asset value at termination, and the reason for wmination. Please provide this record both on a bard copy and in e1ectroxiic format

Page 5 of 10

.J320. A list of officers or directors who either mdgned or were terminated 'during the period with an explanation regarding the nason far their departure.

Bz~. A list of employees who were termhated during the period with an explanation regarding the reason for their departure.

B22. A list of threatened, pending and settled litigation or arbitration tb whioh Registrant was a parry during the inspection period. Provide a description of the allegations forming the basis for each issue, the status of each pending issue, and a brief dewription - of any "out of coud' or . infomi Settlement. If none, please provide a written statement to that effect.

B23. Access to all advisory diem and hedge fund investor oomplaints received during the inspection period and information regarding how each complaint was resolved. Such information could be a copy of any communications sent to the complainant.

B24. Any no-action letters or exemptive orders relied upon by Registrant.

B25. If separate from Registrant's Code of Ethics, a copy of its policy governing receipt by officers and employees of gifts and entertainmenf. Provide access to any file or log maintained of gifts and entextaimnent received by Registrant's directom, officers and employees. Note lbat Registrant is not explicitly required to maintain any such log or file.

B26. &cards of violations of the Code of Ethics during the inspection period. - B27. Provide access to the files or database that contains "holdingsn infarmation reported by access pemons

under Registrant's Code of Ethics.

B28. List of afRliated broker-dealers featuring their affiliation and a description of their clearing amgements-

B29. A list of dl employees or their relatives who me principals or registered represmtarives of a broker- dealer.

B30. A list bf the soft-dollar arrangements, both third-party and proprietary, to which Registrant was a party during the inspection period. This list should be provided in Excel format and should include the following infirmation for each arrangement:

a The name of the broker or other entity involved in eaah arrangement;

b. The nature of the goods or services received by Registrant under the arrangement;

c. Whether the goods or services are third-party or proprietary or both;

d. A detailed demription of how the product or service is used by Registrant;

e. The 'approximate muaI amount of commissions on sexmities tzamactions needed to satisfy each arrangement;

f. The softaollar ratio with retipea to each arrangement;

g. Whether the product or service received is within the Section 28(e) safe harbor;

Page 6 of 10

h. The allocation procedures uscd if this item is considered to be mixed use;

i. The total brokerage commissions uscd to obtain each product or service fbr the current year te date and the previous yew,

j. The types of transactions used to generate soft dollars for this agreement (i.e. equiv or fixed income, listed or OTC, agency or principal, or new issue designations);

k The current mount of soft dollar credits genmted by securities transactions placed by the adviser for the current year to date and the previous year;

I. Whether or not invoices or statements which record seft andlor hard doll~rs paid are sent to Registrant and, if so, how often;

m. A copy of any writtm agreement; and

n. Whether the brokerdealer providing the pmduct or sewice is contractually obligated to pay the oost of the product or service.

B3 1. A list of W i n g e m s (e.g., bought mther than sold, entered limit order at wrong priee, entmd for wrong account, etc.) that occurred in client or proprierary accounts during the inspeaion, period fearunng the tcansaction date, the semuiw, the account and broker-dealer involved, and a summary of the error and its ultimate disposition, including the conditions of any financial settlement

B32. List of approved brokerdealers m t l y in use by Registraxxt's trading staff.

B33. A list of cross transa~tims whi~h took place during the inspection period in which any client was a participant. These transactions would include those where a broker was used or where Registrant. acting without a broker, effkcted the transactions-

B34- A list of securities which Registrant or any affiliate underwrote or with respect to which Registrant participated in such securities' underwriting as underwriting manager or member of a purchase p u p (or syndicate) or selling group during rhe inspection period and which were purchased by or for any client For each situation identified ptovide the approximate date of the u n d d t i n g .

B35. List of securities for which Registrant-or an affiliate was a market maker during the inspection period.

B36. A list of broker-dealers with whom Registrant has or had rev-ue sharing agreements for aSY PUTPOse during the inspection period.

A list of all initial public offerings during the inspection period in which Registrant's clients (including registered and unredstered iunds), proprietary accounts or its access persons participated (i.e., purchased shares). lndicate whether such shares traded at a premium over the public offering price when mading in secondary markets began ("hot issues7'). Please include the security name, symbo1, total aumber of shaies, and the clients involved in the transacrions.

B38- Any written trade allocatha policies and procedures, if not provided in response to another item.

B39. Copy of powers of attorney or disdonziry authority R e g i m z obtainti b clients if not incorporated directly in the advisory conmacts.

Page 7 of 1.0

B40- A copy of any anti-money laundering policies and pmcedum adopted.

B41. Documentation of any annual review conducted of Registrant's anti-money laundering. policies and procedures.

B42. Any regulatory compliance manual sot ahady pmvided in response to a previoul item.

C. Secondarv Requests for Information

Based on our discussions with Registrant's staff, our review and analysis of the items requested above, and our evaluation of the effectiveness of Registrant's tornpliance processes for the areas -identified in Section A., we may ask for .additional boob and records regarding specific activities. Below is a list of infiarion that should be readily available if a request is made by the examiners.

C1. A list of any joint ventures ar any other businesses in which Registrant or any officer, director, portfolio manager or trader participates or has any interest (other than their employment with Registrant), including a description of each relationship.

C2. During the examination, the examiners will review Re@s&ds records pertaining to certain clients. Be prepared to furnish the following records far review fir each client indicated:

a. Advisory oonftact;

b. Custodial or trust agreement;

c. New accomt infhnati01~ forms, Xapplioable;

d. Cliem oorrespondeace;

e. Documentation of annual offix pursuant to Rule 204-3 under the Investment Advisers Act of 1940;

f. Fee invoices fkr a period to be determined;

g. Custodial statements, and, if applicable, internally generated statements that correspond with the .

above-selwted f ke invoices;

h. Any reconciliations between the above-refcrcnccd statements;

i. Performance appraisals for a period to be determined;

j. For terdnated clients, the date of termhatien, reason and, if applicable, evidence of refhded advisory fees where s u ~ h fees are paid in advance; and

k If applicable, notice of assignment of the client's advisory contrast and their consent related to acquisition-

423. A list of all incentive and bonus prognuns DEW by Registtanr to its a d h r y represmtatiiues-

C4. A copy of my securities lending procedures.

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C5. A list of all &ties of clients that were loaned during the inspection period together with the net amount earned by each client for each secutity loaned.

C6. A copy of any minutes from inveslment committee meetings or board of trustees meetings tbr any funds managed.

C7. A list ofall derivatiire or synthetic products purchased or sold (written) for any clients during the inspection period.

C8. A copy of bkcrage allocation reprts fix year-end December 31,2005, featuring the name of the firm, aggregate amount cif agency commissions by the firm, and aggregate principal values or- impTed compensation for principal transactions by the,fim- ' Please provide this record in electmnic format (prefmbly in Microsoft Excel format).

C9. A list of all trades where Registcant bad the executing broker c3repout" all or a portion of the entire mmsaction to another broker fir settlement and confirmatioh, including the trade date, security, executing broker and conflmhg broker identities, the total number of shares filled by the executing broker, and the number of shares stepped-out by the broh.

C10. Any wittcm tmhg deptmer~t policies and procedura, inoluding order entry and execution allocation polioies.

C11. A list of all brokerdealers, including Ems, affiliated or unaffiliated, that, to Registrant's howledge, received order flow payments or rebates related to executing transactions fbr client ponfolios.

C12. A recard of all mitten achowledgernents as required by. Rule 204A-l(a)(S) fbr each person.who is, er was within the past five years, asupexvised person of Registrant.

C13. A record supporting the decisions to approve securities acquisitions by atxess persons under Rule 204A- 1 (c).

C14. Access to re&& of employee personal scdt ies transactions during the inspection period kept pursuant to Rule 204-2(a)(12) under the Investment Advisers Act of 1946.

C15. Custodial statements for any proprietary/investment accounts of Registrant for the inspection period.

C16. A copy of any newsletters sent to clients during the inspection perid

C17. A statement of the account inclusion criteria Registrant employs in the construction of m y composite p d i a n c e results.

C18. Registrant's revenue and expense jou&als and ledgers for the inspection period, including ba* statements, ioan agreements, bills and statements.

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C19. Copies of any written policies and procedures that address the reconcilmg of client security holdings to outside custodiau records.

C20. To the extent. Registrant has a valuation committee, copies of any minutes of the committee's meedings.

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Exhibit 1

Layout for S e d t i e s Trading Blot(er/Purcbnse and Sales Journal

In conjunction with h e scheduled exmination, the M requests r~cords for all purchases and sales of securities for poffilios of advisory clients and prvprietary accounts being advised by Registrant. Please provide this record in Microsoft Excel format on either 3.5-inch disketles or compact discs. This record should include the fields of information lisled below in a similar format.

Please provide separate workrheets for (1) equities (Nok ETF trades should be inclnded with equities), (ir'' Tied income, (tw cash or cash equivalents, maturities, calk, pay-downs, expirations, or reinveshaents of mutual fund dividends or capital gains d ibut ions , (h) mutual fund8, md (v) optlons, futures, swaps and other derivatives.

Examples:

A. Sample Trading Blotter for Eqtuty Securities

B. Sample Trading Blotter kr Fixed-Income Securities

Client Name/#

155

123

Trade Date

1/1/00

1/2/00

client'

Namel t!

155

123

6578

Settle Date

1/3/00

1/5/00

Trade Date

1/2&9

1/3/00

Buy/ Sell

B

S

Settle Date

4/6f98

1/5/99

1/6/00

Buy Sell

B

S

B

Broker

BEST

HRZG

CUSP

1234567

891011 12

CUSP

802586AGZ

908640105

912795CJ8

Security Symbol

MSFT

IBM

Fees

$1.67 I

Broker

S d m

Schwab

Auction

Security Description 1

(rssuer)

SANTARoSA FACS DIST

UNION TEXAS PETRO mc

TREASURY IJNlTED BILu

' Net Proceeds

$9,990

$49,948.33

Security Description

Microsoft Corp

IBMCorp.

Security Dacripfion 2

(Coupon Maturity,

et c) 4'MPh

07-02-2004 4.75%

9-1 5-2004

D I E 6/18/00

Quantity

100

500

Quantity

50,000 -------- 2o

100,000

Unit Price

$100.00

$100,00

Unit Price

100

102

97.78 1

Principal/ Proceeds/ Notional

Value $10,000

$50,000

Total Commission

$10.00

$50.00

Accrued Interest

195.83

$304.60

$0

Total Commlsslon

$0

$39.95

$0

Prfndpal Value 1

Proceeds

$50,000

%20,400

' 597,78 1

Net Proceeds

550,095.83

$20,664.65

$97,78 1