TAILIEUCHUNG - French Trust Reporting Rules Should Not Apply to U.S. CIVs Regulated under the Investment Company Act of 1940

Client brokerage commissions, where applicable, are used as payment for order execution services or research services. The portfolio advisors or Manager may select brokers, including their affiliates, who charge a commissions in excess of that charged by other brokers (“soft dollars”) if they determine in good faith that the commission is reasonable in relation to the order execution and research services utilized. It is the Manager's objective that over time, all clients receive benefits from the client brokerage commissions. Transaction costs, such as brokerage commissions, incurred in the purchase and sale of securities by the Fund are expensed and included in “Commissions and other portfolio transaction costs” in the Statement of Operations | INVESTMENT COMPANY INSTITUTE 1401 H Street NW Washington DC 20005-2148 USA 202 326-5800 Keith Lawson SENIOR COUNSEL - TAX LAW 202 326-5832 FAX 202 326-5841 lawson@ By Electronic Delivery 26 September 2012 Mrs. Charlotte Chevalier Sous-directrice de la fiscalite des personnes Direction de la Législation Fiscale Bâtiment Vauban 139 rue de Bercy Télédoc 549 75572 Paris Cedex 12 RE French Trust Reporting Rules Should Not Apply to . CIVS Regulated under the Investment Company Act of 1940 Dear Mrs. Chevalier The Investment Company Institute ICI 1 respectfully requests confirmation that the new French trust reporting rules do not apply to any . collective investment vehicle CIV that is regulated under the . Investment Company Act of 1940 the Investment Company Act .2 This request obviously is limited to those CIVs that are organized under state law as trusts in contrast to those CIVs organized as state law corporations . The Investment Company Act as discussed below is in all relevant respects equivalent to the UCITS Moreover the investors ownership interests in . CIVs and in UCITS are comparable. In each case the investors own shares or units in the investment entity CIV or UCITS the investment entity s assets are owned by the entity itself. Because UCITS are exempt from the trust reporting rules the same exemption should apply to all . CIVs regulated under the Investment Company Act. 1 The Investment Company Institute is the national association of . investment companies including mutual funds closed-end funds exchange-traded funds ETFs and unit investment trusts UITs . ICI seeks to encourage adherence to high ethical standards promote public understanding and otherwise advance the interests of funds their shareholders directors and advisers. Members of ICI manage total assets of trillion and serve over 90 million shareholders. 2 15 United States Code 80a-1 et seq. 3 A UCITS fund is one that satisfies the .

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