Rule(s):	801.1(d)(2)
Staff:	Michael Verne
Response / Comments:	01/20/2012 – Yes to all three. K Walsh concurs.
	Original Image File

To:             Verne, B. Michael; Walsh, Kathryn
Cc:            (Redacted)
Subject:   Associates

From:        (Redacted)
Sent:         Friday, January 20, 2012 10:38 AM
To:             Verne, B. Michael; Walsh, Kathryn
Cc:            (Redacted)
Subject:   Associates

I have a few questions related to the associate concept and the decision tree on the PNO's website.

(1)   LP1 in the chart is termed the acquiring person. Is it also the acquiring entity?

(2)   What if GP Sub is an LLC and Mr. X manages the investment decisions of GP Sub under contract? Would Mr. X be an associate of LP1?

(3)   What if LP1 controls partnerships A, B, and C and A is the acquiring entity. If under contract Mr. Y manages the investment decisions of B, would Mr. Y be an associate of LP1?