Important Disclosures

Important Notes

Legal Notices


IMPORTANT NOTES

Generally

This material has been prepared by Commonfund Asset Management Company, Inc. (“Comanco”) and/or Commonfund Capital, Inc. (“CCI”) (each, an “Investment Manager”), each of which are indirect wholly owned subsidiaries of The Common Fund for Nonprofit Organizations (“TCF” and, together with Comanco, CCI, Commonfund Securities, Inc. (“CSI”) and its or their affiliates, “Commonfund”).

The information in this material is for illustration and discussion purposes only. It is not intended to be, nor should it be construed or used as, investment, tax or legal advice, any recommendation or opinion regarding the appropriateness or suitability of any investment or strategy, or an offer to sell, or a solicitation of an offer to buy, any interest in any security, including any interest in a private fund, pool, investment product, managed account or other investment vehicle (each, an “Investment Product”). This material is qualified in its entirety by the information contained in any Investment Product’s offering documents, including the governing partnership or operating agreement, investment management agreement, subscription agreement, or an Investment Product’s prospectus or other offering memorandum related thereto, as applicable (collectively, a “Prospectus”).

Any offer or solicitation of an investment in an Investment Product may be made only by delivery of the Investment Product’s Prospectus to qualified investors by CSI. Prospective investors should rely solely on the Prospectus in making any investment decision. The Prospectus contains important information, including, among other information, a description of an Investment Product’s risks, investment program, fees and expenses, and should be read carefully before any investment decision is made. This material does not take into account the particular investment objectives, restrictions, or financial, legal or tax situation of any specific investor. An investment in an Investment Product is not suitable for all investors.

Each Investment Manager is registered with the SEC as an investment adviser. CSI is registered as a broker-dealer with the U.S. Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). The registrations and memberships above in no way imply that the SEC, FINRA or SIPC have endorsed any of the entities, products or services discussed herein.

Distribution

Distribution of this material and the offer of an Investment Product may be restricted in certain jurisdictions. This material is not intended for distribution or use by any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation. This material and the information contained in this material is confidential, is the property of Commonfund, is intended only for intended recipients and their authorized agents and representatives and may not be reproduced or distributed to any other person without prior written consent.

This material is as of the date indicated, may not be complete, is subject to change and does not contain material information regarding an Investment Product, including specific information relating to an investment in an Investment Product and related risks factors. Unless otherwise stated, information provided in this material is derived from one or more parts of Commonfund’s databases and internal sources.

Certain information has been provided by and/or is based on third-party sources and, although believed to be reliable, has not been independently verified. An Investment Manager is not responsible for errors or omissions from these sources. No representation is made with respect to the accuracy, completeness or timeliness of information and Commonfund assumes no obligation to update or otherwise revise such information. Unless the context otherwise requires, the term “investor” and “client” may be used interchangeably.

Investment Process

No representation is made that an Investment Manager’s or an Investment Product’s investment process, investment objectives, goals or risk management techniques will or are likely to be achieved or successful or that an Investment Product or any underlying investment will make any profit or will not sustain losses. An investment in an Investment Product involves risk, as disclosed in the Prospectus. An Investment Manager may engage in investment practices or trading strategies that may increase the risk of investment loss and a loss of principal may occur. The risk management techniques which may be utilized by an Investment Manager cannot provide any assurance that an Investment Product will not be exposed to risks of significant trading losses.

Any descriptions involving investment process, investment examples, statistical analysis, investment strategies or risk management techniques are provided for illustration purposes only, will not apply in all situations, may not be fully indicative of any present or future investments, may be changed in the discretion of an Investment Manager and are not intended to reflect performance.

Any portfolio characteristics and limits reflect guidelines only and are implemented, and may change, in the discretion of an Investment Manager. Investments are selected by, and will vary in the discretion of, an Investment Manager and are subject to availability and market conditions, among other factors without prior notice to investors. There is no requirement that an Investment Manager or an Investment Product observe these guidelines, or that any action be taken if these guidelines are exceeded or are not met or followed.

Market Commentary

Any opinions, assumptions, assessments, statements or the like (collectively, “Statements”) regarding future events or which are forward-looking, including regarding portfolio characteristics and limits, constitute only subjective views, beliefs, outlooks, estimations or intentions of an Investment Manager, should not be relied on, are subject to change due to a variety of factors, including fluctuating market conditions and economic factors, and involve inherent risks and uncertainties, both general and specific, many of which cannot be predicted or quantified and are beyond an Investment Manager’s or an Investment Product’s control. Future evidence and actual results (including actual composition and investment characteristics of an Investment Product’s portfolio) could differ materially from those set forth in, contemplated by, or underlying these Statements, which are subject to change without notice. There can be no assurance and no representation is given that these Statements are now, or will prove to be accurate, or complete in any way. The Investment Manager undertakes no responsibility or obligation to revise or update such Statements. Statements expressed herein may not be shared by all personnel of Commonfund.

Survey Rankings

The Commonfund rankings cited are from Market Strategies International. Cogent Reports™. US Institutional Investor Brandscape: February 2018 and are based on respondents’ answers to questions in which they were asked to rank 55 asset managers on various brand attributes. The results were reported by Cogent based on four groups of respondents: Pension <$500M, Pension $500M+, Non-Profit <$500M, Non-Profit $500+. The survey was fielded online October 13, 2017 to November 28, 2017 and 371 investors with $100 million or more in institutional investable assets participated in the survey. Survey participants were required to play a direct role in the evaluation and selection of investments or asset managers within their organization. In determining the sampling frame for this study, Cogent indicated that it relied upon Standard & Poor’s Money Market Directories (MMD) database of institutional investors. MMD supplied Cogent with a list of contacts at pensions and non-profits with a minimum of $100 million in investable assets. Cogent further reported that, to ensure the population for this research was representative of the universe of institutional investors, strict quotas were established by Cogent based upon a nested classification of institutional investor by category and size of assets. It also represented that data were weighted to be representative of the distribution of institutions by asset size and category according to the most recent MMD data. The data have a margin of error of +5.0% at the 95% confidence level.

Performance | Open-End Investment Products

Unless otherwise indicated, performance of open-end Investment Products shown is unaudited, net of applicable management, performance and other fees and expenses, presumes reinvestment of earnings and excludes investor specific sales and other charges. Fees may be modified or waived for certain investors. Please refer to an Investment Product’s Prospectus or the Investment Manager’s Form ADV Part 2A for more information regarding the Investment Product’s fees, charges and expenses. An investor’s actual performance and actual fees may differ from the performance information shown due to, among other factors, capital contributions and withdrawals or redemptions, different share classes and eligibility to participate in “new issues.”

Performance | Closed-End Investment Products

Unless otherwise indicated, performance of closed-end Investment Products shown is net of all fees and any carried interest and excludes commitments by the applicable general partner and any limited partners that do not pay a management fee. Each Investment Product’s Internal Rate of Return (“IRR”) should be evaluated in light of the information and risks disclosed in the respective Prospectus. Certain investors in an Investment Product may receive a management fee and management fee discount; performance data herein reflects the weighted average blended management fee applicable to actual limited partners of such vehicles. Return information is calculated on a dollar-weighted (e.g., internal rate of return), since inception basis. There can be no assurance that unrealized investments ultimately will be realized at the valuations used in calculating IRRs or Net Multiples or that the calculated IRRs will be obtained. Actual realized returns will depend on, among other factors, future operating results, the value of assets and market conditions at the time of disposition, any related transaction costs and the timing and manner of sale. Certain Investment Products use leverage to finance investments, which may involve a high degree of financial risk. Such Borrowings has the potential to enhance overall returns that exceed the Investment Product’s cost of borrowed funds; however, borrowings will further diminish returns (or increase losses on capital) to the extent overall returns are less than the Investment Product’s cost of borrowed funds. Where applicable, returns take into consideration the reinvestment or “recycling” of investment proceeds.

Hypothetical Portfolios and Hypothetical Results | Generally

Certain asset-allocation framework depicted in this presentation is hypothetical and does not represent the investment performance or the actual accounts of any or investors (“Hypothetical Portfolio”).
Performance of Hypothetical Portfolios and other composite performance results (based on sector attribution and other dissections and combinations of actual Investment Product performance) should be considered hypothetical results (collectively, “Hypothetical Results”). Hypothetical Portfolios and Hypothetical Results do not reflect actual trading or performance by an Investment Product or an investor, or a recommendation on the part of an Investment Manager or CSI to any particular investor; nor should they be considered as indicative of the skills of the Investment Adviser. Hypothetical Portfolios and Hypothetical Results are provided for illustrative purposes only and do not guarantee past or future investment results. Hypothetical Results are based on assumptions, and do not reflect the impact that economic and market factors may have on investment decisions for an Investment Manager. Differences between the hypothetical assumptions and an actual investment are material and decrease substantially the illustration value of any Hypothetical Results. Hypothetical Portfolios may not take into account the goals, risk tolerance and circumstances of each investor. An investment decision should not be based on Hypothetical Results.

Advisory Services

Advisory services, including those described under the trade names “Commonfund Strategic Solutions” and “Commonfund Custom Investment Office,” are generally provided by Comanco or, on occasion, by CCI and subject to an investment advisory agreements. Comanco’s and CCI’s Form ADV Part 2A will be provided upon request.

Benchmarks and Financial Indices

Benchmarks and financial indices are shown for illustrative purposes only. They provide general market data that serves as point of reference to compare the performance of Investment Product’s with the performance of other securities that make up a particular market. Such benchmark and indices are not available for direct investment and their performance does not reflect the expenses associated with the management of an actual portfolio, the actual cost of investing in the instruments that comprise it or other fees. An Investment Product’s investment objective is not restricted to the securities and instruments comprising any one index. No representation is made that any benchmark or index is an appropriate measure for comparison. For a list of commonly used indices, please visit https://www.commonfund.org/important-disclosures/#comm_indices. This list may not represent all available indices or those indices used in this material.

Certain Risks

Portfolio, volatility or return targets or objectives, if any, are used solely for illustration, measurement or comparison purposes and as an aid or guideline for prospective investors to evaluate a particular Investment Product’s strategy, volatility and accompanying information. Such targets or objectives reflect subjective determinations of an Investment Manager based on a variety of factors including, among others, the Investment Product’s investment strategy and prior performance (if any), volatility measures, portfolio characteristics and risk, and market conditions. Volatility and performance will fluctuate, including over short periods, and should be evaluated over the time period indicated and not over shorter periods. Actual volatility and returns will depend on a variety of factors including overall market conditions and the ability of an Investment Manager to implement an Investment Product’s investment process, investment objectives and risk management. Performance targets or objectives should not be relied upon as an indication of actual or projected future performance; such targets or objectives may not be achieved, in whole or in part. For a list of commonly used measures of risk, please visit https://www.commonfund.org/important-disclosures/#risk_rptg.

The above summary is not a complete list of the risks, tax considerations and other important disclosures involved in investing in an Investment Product and is subject to disclosures in such Investment Product’s Prospectus. Please refer to and review carefully the Investment Product’s applicable Prospectus for a more detailed list of the Investment Product’s risks and other disclosures prior to making any investment in such Investment Product.

Past performance is not indicative of future results. An investor may lose all or a substantial portion of their investment in an Investment Product.

Commonfund Securities, Inc., member FINRA, SIPC.

https://www.commonfund.org/important-disclosures/

Composite Benchmarks | MSE Funds Composite Benchmark

The MSE Funds Composite Benchmark is calculated using the following components’ weights: for time periods after April 1, 2017, S&P 500 (85%) and MSCI All Country World Index excluding the U.S. Net (15%); and for time periods prior to April 1, 2017, S&P 500 (75%), MSCI All Country World Index excluding the U.S. Net (15%), and HFRI Fund of Funds Composite Index (10%). The monthly return used for the HFRI Composite FOF Index, a component of the MSE Funds Composite Benchmark, is the Flash Update return that is published by HFRI by the 5th business day of the following month. HFRI reserves the right to adjust the monthly return of the HFRI index up to four months after the month end performance date. Monthly returns for the MSE Funds Composite Benchmark may be retroactively restated based on later adjustments to the HFRI index.

Composite Benchmarks | Global Multi-Asset Portfolio (GMAP) Composite Benchmark

The GMAP Composite Benchmark consists of the following components: MSCI ACWI Total Return Index (50.0%), Bloomberg Barclays Aggregate Total Return Index (20.0%), HFRI FOF Conservative Index (17.5%), MSCI U.S. REIT Total Return Index (5.0%), Bloomberg Commodities Total Return Index (5.0%) and S&P Global Natural Resources Total Return Index (2.5%).

Commonly Used Indices

Barclays Capital U.S. Treasury Inflation Protected Securities (“TIPS”): Index includes all publicly issued, U.S. Treasury inflation-protected securities that have at least one year remaining to maturity, are rated investment grade and have $250 million or more of outstanding face value.

Bloomberg Barclays Capital U.S. Aggregate Bond Index: measures the performance of the U.S. investment grade bond market. The index invests in a wide spectrum of public, investment-grade, taxable, fixed income securities in the U.S. – including government, corporate, and international dollar-denominated bonds, as well as mortgage-backed and asset-backed securities, all with maturities of more than 1 year.

Bloomberg Commodity Index (“BCOM”): is calculated on an excess return basis and reflects commodity futures price movements. The index rebalances annually weighted 2/3 by trading volume and 1/3 by world production and weight-caps are applied at the commodity, sector and group level for diversification. Roll period typically occurs from 6th-10th business day based on the roll schedule.

BofA Merrill Lynch 1-3 Year US Treasury Index: is an unmanaged index that tracks the performance of the direct sovereign debt of the U.S. Government having a maturity of at least one year and less than three years. It is not possible to invest directly in an unmanaged index. BOFA Merrill Lynch is licensing the BOFA Merrill Lynch Indices “As Is,” makes no warranties regarding same, does not guarantee the suitability, quality, accuracy, timeliness, and/or completeness of the BOFA Merrill Lynch Indices or any data included in, related to, or derived therefrom, assumes no liability in connection with their use, and does not sponsor, endorse, or recommend Commonfund, or any of its products or services.

Citigroup World Government Bond Index (“WGBI”): measures the performance of fixed-rate, local currency, investment grade sovereign bonds. The WGBI is a widely used benchmark that currently comprises sovereign debt from over twenty countries, denominated in a variety of currencies, and has more than twenty-five years of history available. The WGBI provides a broad benchmark for the global sovereign fixed income market. Sub-indices are available in any combination of currency, maturity, or rating.

CS Leveraged Loan Index: is an index designed to mirror the investable universe of the U.S. dollar denominated leveraged loan market. The index inception is January 1992. The index frequency is monthly. New loans are added to the index on their effective date if they qualify according to the following criteria: loans must be rated “5B” or lower; only fully-funded term loans are included; the tenor must be at least one year; and the Issuers must be domiciled in developed countries (i.e., issuers from developing countries are excluded). Fallen angels are added to the index subject to the new loan criteria. Loans are removed from the index when they are upgraded to investment grade, or when they exit the market (for example, at maturity, refinancing or bankruptcy workout). Note that issuers remain in the index following default. Total return of the index is the sum of three components: principal, interest, and reinvestment return. The cumulative return assumes that coupon payments are reinvested into the index at the beginning of each period.

Dow Jones U.S. Select Real Estate Securities Index (“RESI”): represents equity real estate investment trusts (“REITs”) and real estate operating companies traded in the U.S. The Dow Jones U.S. Select REIT Index is a subset of the Dow Jones Americas Select RESISM and includes only REITs and REIT-like securities.

HFRI Monthly Indices (“HFRI”): Most HFRI are equally weighted performance indices, utilized by numerous hedge fund managers as a benchmark for their own hedge funds. The HFRI are broken down into four main strategies, each with multiple sub-strategies. All single-manager HFRI Index constituents are included in the HFRI Fund Weighted Composite, which accounts for over 2000 funds listed on the internal HFR Database. Funds included in the HFRI Monthly Indices must: report monthly returns; report net of all fees returns; report assets in U.S. dollars; and, have at least $50 million under management or have been actively trading for at least twelve months. Funds are eligible for inclusion in the HFRI the month after their addition to HFR Database. If a fund in an index liquidates or closes, that fund’s performance will be included in the HFRI up to the fund’s last reported performance update. Fund of Funds are not included in the HFRI Fund Weighted Composite Index. Both domestic and offshore funds are included in the HFRI. In cases where a manager lists mirrored-performance funds, only the fund with the larger asset size is included in the HFRI. FX-hedged versions of HFRI Indices are calculated by applying to the USD index value the cost of a rolling monthly foreign exchange contract on the relevant currency. The HFRI are updated three times a month. The current month and the prior three months are left as estimates and are subject to change. All performance prior to that is locked and is no longer subject to change. Due to contractual obligations, Comanco does not disclose the particular funds behind any index. See https://www.hedgefundresearch.com/hfri-index-methodology.

ICE Bo/AML 9-12 Month US Treasury Bill Index: is a subset of ICE BofAML US Treasury Bill Index including all securities with a remaining term to final maturity greater than or equal to 9 months and less than 12 months. Inception date: June 30, 1992

MSCI ACWI Index: is a free float-adjusted market capitalization weighted index that is designed to measure the equity market performance of developed and emerging markets. The MSCI ACWI consists of 46 country indexes comprising 23 developed and 23 emerging market country indexes. The developed market country indexes included are as follows: Australia, Austria, Belgium, Canada, Denmark, Finland, France, Germany, Hong Kong, Ireland, Israel, Italy, Japan, Netherlands, New Zealand, Norway, Portugal, Singapore, Spain, Sweden, Switzerland, the United Kingdom and the U.S.

The emerging market country indexes included are: Brazil, Chile, China, Colombia, Czech Republic, Egypt, Greece, Hungary, India, Indonesia, Korea, Malaysia, Mexico, Peru, Philippines, Poland, Qatar, Russia, South Africa, Taiwan, Thailand, Turkey, and United Arab Emirates. (List as of January 2016.)

MSCI ACWI ex USA net Index: captures large and mid-cap representation across 22 of 23 developed markets countries – excluding the U.S. With 1,003 constituents, the index covers approximately 85% of the free float-adjusted market capitalization in each country.

MSCI EAFE Index (Europe, Australasia, Far East): is a free float-adjusted market capitalization index that is designed to measure the equity market performance of developed markets, excluding the U.S. & Canada. The MSCI EAFE Index consists of the following 21 developed market country indexes: Australia, Austria, Belgium, Denmark, Finland, France, Germany, Hong Kong, Ireland, Israel, Italy, Japan, the Netherlands, New Zealand, Norway, Portugal, Singapore, Spain, Sweden, Switzerland, and the United Kingdom. (List as of January 2016.)

MSCI Emerging Markets Index: is a free float-adjusted market capitalization index that is designed to measure equity market performance of emerging markets. The MSCI Emerging Markets Index consists of the following 23 emerging market country indexes: Brazil, Chile, China, Colombia, Czech Republic, Egypt, Greece, Hungary, India, Indonesia, Korea, Malaysia, Mexico, Peru, Philippines, Poland, Qatar, Russia, South Africa, Taiwan, Thailand, Turkey and United Arab Emirates. (List as of January 2016.)

MSCI US REIT Index: is a free float-adjusted market capitalization weighted index that is comprised of Equity REIT securities. The MSCI US REIT Index includes securities with exposure to core real estate (e.g., residential and retail properties) as well as securities with exposure to other types of real estate (e.g., casinos, theaters).

Russell 2000 Index: measures the performance of the small-cap segment of the U.S. equity universe. The Russell 2000 Index is a subset of the Russell 3000 Index representing approximately 10% of the total market capitalization of that index. It includes approximately 2000 of the smallest securities based on a combination of their market cap and current index membership. The Russell 2000 is constructed to provide a comprehensive and unbiased small-cap barometer and is completely reconstituted annually to ensure larger stocks do not distort the performance and characteristics of the true small-cap opportunity set.

Russell 3000 Index: measures the performance of the largest 3,000 U.S. companies representing approximately 98% of the investable U.S. equity market. The Russell 3000 Index is constructed to provide a comprehensive, unbiased and stable barometer of the broad market and is completely reconstituted annually to ensure new and growing equities are reflected.

S&P 500 Index: is a widely recognized gauge of the U.S. equities market. This index is an unmanaged capitalization-weighted index consisting of 500 of the largest capitalization U.S. common stocks. The returns of the S&P 500 include the reinvestment of dividends.

S&P Global Natural Resources Index: includes 90 of the largest publicly-traded companies in natural resources and commodities businesses that meet specific investability requirements, offering investors diversified and investable equity exposure across three primary commodity-related sectors: agribusiness, energy, and metals & mining.

S&P/LSTA Leveraged Loan Index: is a market value-weighted index designed to measure the performance of the U.S. leveraged loan market based upon market weightings, spreads and interest payments. Eligible for inclusion in the LLI loans are U.S. dollar denominated senior secured loans with a minimum initial term of one year, minimum initial spread of LIBOR + 125 basis points and initial funding of $50M. The index covers all issuers regardless of origin, however all facilities must be denominated in U.S. dollar.

Risk Reporting

Value at Risk (“VaR”): VaR measures the potential loss of value resulting from market movements over a specified period of time within a specified probability of occurrence. VaR is calculated for an Investment Product by setting the confidence level to a specific value (0-100) over a one year period. For example, if the monthly VaR of a portfolio is 5 percent at a 95 percent confidence level, then there are five chances in 100, under normal market conditions, of a loss greater than 5 percent. An Investment Manager’s calculations are based on the portfolio constituents’ monthly returns with weekly frequency looking back five years, and greater weight is given to more recent returns than less recent returns. The resultant returns time series has a one-year half-life.

The VaR method relies on simplifying assumptions which are not always present in real investing environments or that may not be realized. The projections or other information generated by VaR analysis are not guarantees of future results and do not take into account abnormal market conditions – situations in which the risk of loss may be greatest. VaR is not a ‘worst case’ scenario and can understate the amount of actual loss to which an investor may be exposed.

Conditional Value at Risk (“CVaR”): While VaR is useful in understanding the maximum potential loss in a given portfolio 95 percent of the time, CVaR attempts to measure the average downside risk in a portfolio the remaining 5 percent of the time. For example, if the monthly CVaR of a portfolio is 10 percent at a 95 percent confidence level, then the average loss is 10 in those 5 percent of outcomes where VaR is exceeded – note that this calculation predicts the average loss, not the worst potential loss. CVaR calculations are based on the portfolio constituents’ monthly returns with weekly frequency looking back five years, and greater weight is given to more recent returns than less recent returns. CVaR calculations may be less reliable than VaR calculations because there are typically fewer data points.

Standard Deviation: This is a measure of how much a portfolio’s value can deviate in one year. It is calculated as annualized standard deviation of the portfolio monthly returns with weekly frequency time series looking back five years, weighting recent returns more heavily. This generates a half-life of one year.

Historical Beta (ß): This is a measure of the risk arising out of the movement of market factors. A beta (or ß) of 1.0 indicates that an up/down movement in the benchmark will generate an equal percent movement in the portfolio. Any idiosyncratic factor in the portfolio can generate an up/down move in addition to the beta.

Historical Stress Tests: We report the portfolio risk as the profit/loss it will generate if six major historic market events were to recur independently. These metrics are calculated by combining the portfolio constituents’ movements during those events for the portfolio as a whole.

Hypothetical Factor Stress Tests: We also report the portfolio risk as the profit/loss it will generate if five hypothetical market movements were to occur independently. These metrics are calculated by combining the portfolio constituents’ current sensitivity to the movements in these market factors.

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Affiliation with Commonfund Securities, Inc.

Notice of Investor Education and Protection Information Pursuant to FINRA Rule 2267

Interests in Commonfund funds and those offered by Commonfund’s affiliates are placed by Commonfund Securities, Inc., a broker-dealer that is a member of the Financial Industry Regulatory Authority (“FINRA”). Commonfund Securities, Inc. is an indirect, wholly-owned subsidiary of Commonfund. Please refer to FINRA’s website (www.finra.org) and/or FINRA BrokerCheck (https://brokercheck.finra.org or Hotline Number (800) 289-9999) for more information about FINRA and its member organizations.

FINRA BrokerCheck is a resource tool to help investors check the professional background of current and former FINRA-registered securities firms and brokers. Features of FINRA BrokerCheck include:

  • Search capabilities for both a broker and brokerage firm

  • Online delivery of a report on a broker or brokerage firm

  • Explanatory information to help investors better understand the content, context and source of the information provided

  • Links to additional resources and tools

The information made available through FINRA BrokerCheck is derived from the Central Registration Depository (CRD®), the securities industry online registration and licensing database, as reported on industry registration/licensing forms brokers, brokerage firms and regulators complete. More detailed information regarding FINRA BrokerCheck is contained in an investor brochure which is available via the FINRA website.

Notice Pursuant to SEA Rule 17a-3(a)(18)(ii)

Any complaints concerning or relating to an investor or client account may be directed to the Investor Services Department at 203-563-5000, or at 15 Old Danbury Road, Wilton, CT 06897.

Notice Pursuant to FINRA Rule 2261

Investors and clients may request certain information relative to Commonfund Securities, Inc.’s financial condition by contacting the Investor Services Department at 203-563-5000, or at 15 Old Danbury Road, Wilton, CT 06897.

Statements on Web Site by Commonfund Investors

Statements by investors in funds maintained by Commonfund may not be representative of the views or experiences of others. A particular investor’s views, experience, or investment results provide no assurance of future performance or success.

Business Continuity

Commonfund has developed a business continuity plan that is designed to minimize the impact of computer or facilities related emergencies or external events, such as a natural disaster, on Commonfund and our ability to provide service to our clients. The goal of our plan is that we will continue, or resume as quickly as possible, critical business operations during these types of disruptions.

Our plan addresses the actions that we will take in the event that the significant disruption affects a single building, a business district, a citywide area, or an entire region. We have different planned recovery times depending on the severity of the significant business disruption. In most of the scenarios addressed by our plan, we anticipate recovery times within 24 hours from the significant business disruption. Even in the most significant business disruption scenario addressed by our plan, we anticipate that critical business operations could be resumed within five days.

To support our Business Continuity Plan recovery times, we maintain a back-up facility, including a secondary data center for all of our branches. Our back-up facility is located well away from our primary facilities so that it would not be affected by a regional disruption. Account access would be available through the data center at our back-up facility. Our plan will be reviewed, updated and tested periodically. If a material change to the plan occurs, this Notice of Business Continuity Preparedness will be updated as appropriate. We may modify this notice at any time with such modifications becoming effective upon posting to our web site. You may obtain a current copy of this notice by clicking here, or Commonfund will mail you a copy upon request.

Miscellaneous

This agreement has been made in and shall be construed and enforced in accordance with New York law. Any action to enforce this Agreement shall be brought in the federal or state courts located in New York City.

Notice of Anti-Money Laundering Customer Identification Requirements Important Information About Procedures for Opening a New Account

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each customer who opens an account.

What this means for you: When you open an account, we may ask for documents or information related to: your principal place of business, local office or other physical location; taxpayer identification number; and other documents demonstrating your lawful existence such as certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust agreement, and other identifying documents.

Privacy Policy

This policy governs the manner in which Commonfund safeguards Social Security numbers collected from investors and Commonfund personnel. The purpose of this policy is to establish measures by which to safeguard Social Security numbers and to minimize the abuses associated with the fraudulent use of Social Security numbers by attempting to restrict their use as an identifier.

Commonfund personnel (including, without limitation, employees and contractors) and anyone accessing Commonfund’s non-public computer systems shall not:

  1. Communicate, or otherwise make available, to the general public any individual’s Social Security number;

  2. Publicly display any individual’s Social Security number either within or outside Commonfund systems or facilities;

  3. Intentionally print or embed an individual’s Social Security number on any card required for an investor or employee to access products, services or benefits;

  4. Require an individual to transmit the individual’s Social Security number over the Internet or to store Social Security numbers on any laptop or other portable computing device, unless the connection is secure or the Social Security number is encrypted in accordance with Commonfund’s Information Security Policy;

  5. Require an individual to use the individual’s Social Security number to access an Internet website, unless a password or unique personal identification number or other authentication device is also required to access the Internet website;

  6. Print an individual’s Social Security number on any materials that are mailed (including facsimile and e-mail) unless required by law or on documents sent as part of an application, an amendment, or termination of the account, in which case the number may not be on a postcard or visible through an envelope. Approval from the Information Security Policy Program Administrator is required for inclusion of Social Security numbers in a mailing;

  7. Require use of a Social Security number as an ID number;

  8. Display a Social Security number on any document intended to be recorded by a county recorder;

  9. Use a Social Security number as a PIN code;

  10. Sell, lease, loan or otherwise intentionally disclose a Social Security number to third parties without written consent from the investor, employee, contractor or other individual to whom the Social Security number belongs in accordance with applicable laws; and

  11. Show a Social Security number in a paystub or other format.

Use of a Social Security number is permitted if the use, collection or release of the number is required by law, or if the use is for internal verification or administrative purposes. Commonfund personnel must consult with the Information Security Policy Program Administrator if they are unsure whether use of a Social Security number is permissible in a particular situation.