1109013 Informal Interpretation

Date:
Rule:
Item 1(a), 1(g) and Associates and GPs
Staff:
Michael Verne
Response/Comments:

  No need to correct this time, but for future reference: Item 1(a) requires a website Item 1 (g) requires a second contact person Just for my education, is the (redacted) family of funds structured so that (redacted) Corporate Investors VII is not the GP for any other funds? Is that true throughout the family each investment fund has its own GP and those GPs are not under common investment management (i.e., there is no top level entity that ties the GPs together)?

Question

From: (Redacted)
Sent: Thursday, September 22, 201110:12 AM
To: Verne,B. Michael
Cc: (Redacted)
Subject: RE: (Redacted)

Mike,

Tothe best of my understanding, the (redacted) funds are notnecessarily organized by industry but simply organized over time. I am copying (redacted),who is familiar with the (redacted) funds in case you have furtherquestions.

(Redacted)

From: Verne, B. Michael [mailto:MVERNE@ftc.gov]
Sent: Thursday, September 22, 20119:50 AM
To: (Redacted)
Subject: RE: (Redacted)

Are the families of funds under one GP generally investingin the same industry sector?

From: (Redacted)
Sent: Thursday, September 22, 20119:42 AM
To: Verne,B. Michael
Subject: RE: (Redacted)

ThanksMike.

(Redacted) Investors VII is the GP for otherfunds in the Fund VII family but none of those funds currently hold operatingbusinesses so there are no associate holdings to assess here. Generally, (redacted)organizes funds by "families" with multiple funds in each familyultimately managed by one top family GP. There is no top level GP entity acrossfamilies of funds that ties all the top family GPs together.

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