appropriate consultation took place for difficult or contentious matters? If yes, Please describe the policies and procedures. If no, How does the firm ensure that the difficult or contentious matters have been

licensed to undertake derivatives business in the category of derivatives brokerage. “ assets of client ” means: (1) assets which a derivatives broker receives or holds as collateral for satisfying

information to the prospective investors. The management company may offer the units for sale upon satisfying the conditions in (2); (2) the offering of the units may commence upon complete compliance with the