Disclosures - Belle Haven Investments

Important Disclosures and Regulatory Information

Belle Haven Investments, L.P. is dually registered as an investment adviser and broker-dealer with the U.S. Securities and Exchange Commission (“SEC”). The Firm is also a member of the Financial Industry Regulatory Authority (“FINRA”), and the Municipal Securities Rulemaking Board (“MSRB”). Additional information about Belle Haven 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

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 - October 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 information and materials available on this website are provided by Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) for informational and educational purposes only. Unless otherwise indicated, views and opinions expressed are those of Belle Haven as of the date presented, are subject to change without notice, and should not be construed as investment, tax, accounting, or legal advice; a recommendation to buy or sell any security; or an offer or solicitation to engage in any investment strategy or advisory service.

Information presented on this website is not intended to serve as the primary basis for an investment decision. Investment decisions should be based on an investor’s individual objectives, financial circumstances, tax considerations, risk tolerance, and other relevant factors. Investors should consult their own financial, tax, and legal advisers as appropriate.

Belle Haven may use information and data obtained from third-party sources believed to be reliable; however, the Firm does not guarantee the accuracy, completeness, or timeliness of such information. References or links to third-party websites, publications, products, services, or other content are provided for informational purposes and do not constitute an endorsement, sponsorship, or approval by Belle Haven unless expressly stated otherwise.

Certain information may include forward-looking statements, projections, estimates, expectations, or other predictive information regarding future events, market conditions, or investment outcomes. Such information is based on assumptions and expectations at the time presented and is inherently subject to uncertainty. Actual events, market conditions, and investment results may differ materially from those anticipated, and no forward-looking statement should be viewed as a guarantee of future results.

Certain materials may also contain hypothetical, targeted, projected, back-tested, model, or other illustrative performance information. Such information does not represent the performance of an actual client account or the actual trading of client assets and is subject to important assumptions, risks, and limitations. Actual results may differ materially from those presented, and there can be no assurance that any hypothetical, targeted, or projected results will be achieved. Additional information regarding applicable assumptions, criteria, risks, and limitations will be provided with or made available in connection with the applicable presentation.

Investing involves risk, including the possible loss of principal. Past performance does not guarantee future results. Investment objectives, portfolio characteristics, risk management techniques, and investment processes described on this website represent objectives, general guidelines, or investment approaches and are not guarantees of investment results or assurances that risks will be avoided. Additional information regarding investment risks, strategy characteristics, performance, credit ratings, and other important considerations is provided in the applicable disclosure sections on this page and in Belle Haven’s Form ADV Part 2A.

This website is not directed to any person or entity in any jurisdiction where its distribution or use would be contrary to applicable law or regulation. Website content may not be reproduced, redistributed, transmitted, or otherwise used, in whole or in part, without Belle Haven’s prior written consent.

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

Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) maintains a presence on various social media and digital communication platforms, which may include LinkedIn, X, YouTube, Spotify, podcasts, and other channels (collectively, “Belle Haven Social Media Platforms”). Content published or shared through these channels is provided for informational and educational purposes only and should not be construed as investment, tax, accounting, or legal advice; a recommendation to buy or sell any security; or an offer or solicitation to engage in any investment strategy or advisory service.

Views and opinions expressed by Belle Haven are as of the date presented, are subject to change without notice, and may not reflect subsequent market events or developments. Information may be obtained from third-party sources believed to be reliable; however, Belle Haven does not guarantee its accuracy, completeness, or timeliness.

References to particular securities, issuers, sectors, markets, investment themes, transactions, or portfolio examples are provided for illustrative or informational purposes only and should not be considered recommendations to buy or sell any security. Securities discussed may not represent all securities purchased, sold, or recommended for client accounts, and there should be no assumption that any security or investment discussed was or will be profitable. Belle Haven may or may not currently hold, or intend to hold, securities referenced in social media content.

Third-party follows, likes, shares, reposts, comments, reactions, or other interactions with Belle Haven's social media content are independent third-party activity and do not necessarily reflect the views of Belle Haven. Such interactions should not be interpreted as an indication of client experience, an endorsement of Belle Haven or its services, or an indication of future investment results. Belle Haven does not control independent third-party social media activity.

Belle Haven may share, repost, reference, or link to third-party content for informational purposes. Unless expressly stated otherwise, such activity does not constitute Belle Haven's endorsement, sponsorship, or approval of the third party or its products, services, views, or opinions. Belle Haven does not control and is not responsible for the content, availability, privacy practices, or security policies of third-party websites or platforms.

Belle Haven does not accept trading instructions, transaction orders, account instructions, or other requests requiring action through social media platforms. Users should not transmit personal, confidential, or account-related information through social media channels. Account-related questions or requests should be directed to Belle Haven through the Firm's established communication channels.

Belle Haven may moderate its social media channels and reserves the right to remove, restrict, hide, or report content or activity that it determines to be inappropriate, misleading, unlawful, promotional, offensive, or otherwise inconsistent with applicable law, regulation, platform requirements, or Firm policies.

Investing involves risk, including the possible loss of principal. Past performance does not guarantee future results. The Firm and Website Disclosures, General Investment Risks, Performance Information, and other applicable disclosures contained on this website apply, as relevant, to content distributed through Belle Haven Social Media Platforms.

GENERAL INVESTMENT RISKS

Investing involves risk, including the possible loss of principal. The nature and degree of investment risk will vary based on the investment strategy, portfolio composition, securities held, market conditions, and client-specific investment guidelines or restrictions. There can be no assurance that any investment objective will be achieved, that any investment strategy or risk management approach will be successful, or that an investment will generate a positive return.

Fixed income securities are subject to a variety of risks, including interest rate risk, credit and default risk, issuer risk, market risk, liquidity risk, reinvestment risk, inflation risk, call and prepayment risk, and other risks associated with changing market and economic conditions. Changes in interest rates, credit spreads, issuer financial condition, market liquidity, or broader economic conditions may adversely affect the value, income, liquidity, and performance of individual securities and portfolios. Portfolios may also be subject to risks associated with sector or geographic concentrations, security selection, portfolio positioning, and changes in tax laws, regulations, or market structure. Diversification and other portfolio management techniques are intended to manage certain risks but do not eliminate the possibility of loss.

Municipal securities involve additional risks and considerations, including the financial condition of the issuer or obligor, the source of repayment, market liquidity, and changes in tax laws or tax treatment. Income from municipal securities may be subject to federal, state, or local taxes, including capital gains taxes and, in certain circumstances, the alternative minimum tax (“AMT”). The tax treatment of municipal securities depends on an investor's individual circumstances and may change over time.

Tax-aware or tax-sensitive strategies, including tax-loss harvesting, may not be appropriate for all investors or account types. Tax-related portfolio activity may result in additional transactions, realized gains or losses, transaction costs, or other consequences and may not achieve the intended tax result. Investment processes, portfolio construction techniques, diversification practices, risk management approaches, and investment guidelines described by Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) represent general investment approaches or objectives and should not be interpreted as guarantees of investment results or assurances that investment risk will be reduced or avoided. Past performance does not guarantee 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.

CREDIT RATINGS & PORTFOLIO CLASSIFICATIONS

Credit ratings are provided by nationally recognized statistical rating organizations (“NRSROs”), are subject to change, and are not guarantees of credit quality, market value, or future performance. Bond ratings reflect an NRSRO’s assessment of credit worthiness and generally range from AAA/Aaa (highest) to D/C (lowest), depending on the rating agency. Securities rated BBB-/Baa3 or higher are generally considered investment grade. Ratings presented may reflect credit enhancements, including bond insurance, guarantees, letters of credit, or other credit support, and may differ from the rating of the underlying issuer or security without such enhancement. Belle Haven does not independently assign NRSRO credit ratings. For portfolio reporting purposes, certain pre-refunded municipal securities may be classified as U.S. Government securities when secured by qualifying U.S. Government obligations. This classification is based on the security's source of repayment and does not represent an NRSRO credit rating or indicate that the municipal security itself was issued or guaranteed by the U.S. Government. Belle Haven relies on ratings and related information from applicable NRSROs and third-party data providers as part of its credit process. References to a strategy's average credit rating do not represent a minimum rating for each security. Individual securities may be rated above or below the stated average or may be unrated. Portfolio rating distributions and weightings are subject to change.

INVESTMENT & PORTFOLIO DEFINITIONS

The following definitions are provided to assist investors in understanding investment, fixed income, performance, and portfolio characteristics referenced in Belle Haven materials. Calculation methodologies may vary among investment managers, custodians, index providers, reporting platforms, and other third-party data providers. Certain measures rely on assumptions, estimates, market values, or prevailing market conditions and are subject to change.

Performance and risk measures are based on historical information and should not be considered predictive of future results. Portfolio characteristics, yields, durations, ratings, and other measures may change over time and may differ from client-specific or custodial reporting based on methodology, timing, data sources, or other factors.

Alpha measures an investment's commonly risk-adjusted performance relative to a benchmark index. A positive alpha indicates performance above that predicted by the measure's benchmark relationship, while a negative alpha indicates performance below it.

Average Coupon represents the weighted average stated coupon rate of the bond holdings in a portfolio.

Average Maturity represents the weighted average of time remaining until the bond holdings in a portfolio are scheduled to mature and principal is repaid.

Average Rating represents 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”). Ratings used for portfolio reporting may reflect applicable credit enhancements or the treatment of certain pre-refunded securities. Securities not rated by an applicable rating agency may be excluded from the calculation. Average Rating does not represent a minimum rating for individual securities, which may be rated above or below the portfolio average or may be unrated. Credit ratings are subject to change and are not a guarantee of credit quality or investment performance.

Benchmark refers to an index or other comparative measure used to evaluate investment performance or portfolio characteristics. Indices are unmanaged, are not available for direct investment, and generally do not reflect investment management fees or other expenses. An index may have materially different holdings, characteristics, objectives, or risks than the strategy being compared.

Beta measures an investment’s sensitivity to movements in a benchmark. A beta of 1.0 generally indicates that the investment has moved in line with the benchmark; a beta above or below 1.0 generally indicates greater or lesser sensitivity, respectively.

Down Capture Ratio measures a portfolios performance relative to a benchmark during a period when the benchmark had negative returns. A ratio below 100% generally indicates that the portfolio declined less than the benchmark during those periods; a ratio above 100% generally indicates that it declined more.

Duration measures the sensitivity of a bond’s or fixed income portfolio’s price to changes in interest rates. Generally, higher duration indicates greater sensitivity to changes in interest rates.

Duration-to-Worst (“DTW”) estimates the interest rate sensitivity of a bond or portfolio based on the redemption scenario that produces the lowest yield-to-worst, taking into account applicable call or other early-redemption features.

Expected Yield-to-Worst (“Expected YTW”) represents an estimated yield based on assumptions regarding expected calls, prepayments, redemptions, or other factors that may affect future cash flows. Expected YTW is based on assumptions that may not occur and may differ from actual yield or investment results.

Modified Duration estimates the percentage change in the price of a bond or fixed income portfolio resulting from a 1% (100 basis point) change in interest rates, assuming other factors remain constant. Generally, higher modified duration indicates greater sensitivity to changes in interest rates.

Projected Earned Annual Income represents an estimate of the annual income expected to be generated by a bond or portfolio based on current holdings, stated coupon rates, expected cash flows, and applicable assumptions. Projected income is subject to change and is not a guarantee of future income or investment results.

R-Squared (“R²”) measures the degree to which an investment's historical return movements are explained by movements in its benchmark. R² is generally expressed on a scale from 0 to 100, with a higher value indicating a stronger historical relationship to the benchmark.

Sharpe Ratio measures risk-adjusted performance by comparing an investment's excess return to the volatility of its returns. Generally, a higher Sharpe Ratio indicates greater historical return per unit of volatility.

Standard Deviation measure the variability of investment returns around their average over a specified period and is commonly used as an indicator of historical volatility. A higher standard deviation generally indicates greater variability in returns.

Tax-Equivalent Yield ("TEY") estimates the yield a taxable investment would need to generate to equal the after-tax yield of a tax-exempt investment, based on an assumed tax rate. TEY will vary depending on the tax rate and assumptions used and does not allows reflect an investor's individual tax circumstances.

Total Market Value represents the aggregate market value of securities, cash, and other holdings in a portfolio or account based on available pricing information as of a specified date. Market values are subject to change and may vary based on market conditions, pricing sources, liquidity, or other factors.

Total Return measures an investment's overall return over a specified period, including income and changes in market value, and generally assumes the reinvestment of income.

Up Capture Ratio measures a portfolio's performance relative to a benchmark during periods when the benchmark had positive returns. A ratio above 100% generally indicates that the portfolio gained more than the benchmark during those periods; a ratio below 100% generally indicates that it gained less.

Yield-to-Maturity ("YTM") represents the estimated annualized return of a bond if held until maturity, assuming all scheduled principal and interest payments are made and coupon payments are reinvested at the same rate. YTM is based on the bond's current market price and does not guarantee the return an investor will actually receive.

Yield-to-Worst ("YTW") represents the lowest estimated yield of a bond among applicable maturity and call or other early-redemption scenarios, assuming the issuer does not default. YTW is an estimate and does not guarantee the yield an investor will actually receive.

AWARDS AND RECOGNITION

Awards, rankings, recognitions, and third-party ratings referenced by Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) are provided by third-party organizations based on criteria and methodologies established by the applicable provider. Evaluation criteria may include investment performance, assets under management, peer group comparisons, risk measures, firm or strategy information, or other quantitative or qualitative factors. Criteria, methodologies, eligibility requirements, peer groups, and evaluation periods vary by provider and may change over time.

Awards, rankings, recognitions, and third-party ratings are provided for informational purposes only and should not be construed as a recommendation or endorsement of Belle Haven, its advisory services, or any particular investment strategy. They do not represent the experience of any individual client, are not indicative of future performance or results, and should not be viewed as a guarantee that a client or prospective client will experience similar results.

Belle Haven may provide information or submit materials for consideration in connection with certain awards or rankings. In some cases, Belle Haven may pay application, subscription, licensing, marketing, reprint, or other fees in connection with participation in an award program or the use or promotion of an award or recognition. Unless otherwise disclosed, no fee is paid by Belle Haven to obtain a favorable rating, ranking, or award.

Belle Haven does not control the criteria, methodology, or evaluation process established by third-party providers. Material information regarding the applicable award or ranking, including the provider, date or evaluation period, relevant category or peer group, and material criteria or methodology, is provided with the applicable award or recognition or is otherwise made available through the related disclosure.

Additional information regarding the methodology, criteria, or limitations applicable to a referenced award, ranking, recognition, or third-party rating is available from the applicable provider or by contacting Belle Haven at 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.