EFTA Document EFTA01358592

(b) If you are registering or registered with the SEC and you have answered "yes," to question 8(a) above, have you overcome the r r presumption that you are not operationally independent (pursuant to rule 206(4)-(2)(d)(5)) from the related person and thus are not required to obtain a surprise examination for your clients' funds or securities that are maintained at the related person? (c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office