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Adviser Profile

As of Date 10/30/2024
Adviser Type - Large advisory firm
- An investment adviser to a company which has elected to be a business development company
Number of Employees 20
of those in investment advisory functions 19
Registration SEC, Approved, 07/06/2001

Client Types

- Business development companies
- Pooled investment vehicles
- Insurance companies
- Corporations or other businesses not listed above

Advisory Activities

- Portfolio management for investment companies
- Portfolio management for pooled investment vehicles
- Portfolio management for businesses
- Selection of other advisers

Compensation Arrangments

- A percentage of assets under your management
- Performance-based fees

Recent News

Reported AUM

Discretionary
Non-discretionary
11B 10B 8B 6B 5B 3B 2B
2015 2016 2017 2018 2019 2020 2021 2022 2023

Private Funds



Employees

Private Funds Structure

Fund Type Count GAV
Fund TypeHedge Fund Count4 GAV$908,064,029
Fund TypePrivate Equity Fund Count32 GAV$4,582,218,149
Fund TypeSecuritized Asset Fund Count2 GAV$95,774,149

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Adviser Hedge Fund Liquidity Fund Private Equity Fund Real Estate Fund Securitized Asset Fund Venture Capital Fund Other Fund Total Private Fund GAV AUM #Funds
Adviser CDH INVESTMENT ADVISORY PRIVATE LIMITED Hedge Fund132.6m Liquidity Fund- Private Equity Fund3.7b Real Estate Fund- Securitized Asset Fund- Venture Capital Fund- Other Fund- Total Private Fund GAV3.9b AUM3.6b #Funds4
Adviser TSPI, LP Hedge Fund1.8b Liquidity Fund- Private Equity Fund890.4m Real Estate Fund- Securitized Asset Fund- Venture Capital Fund- Other Fund- Total Private Fund GAV2.7b AUM2.4b #Funds4
Adviser BURFORD CAPITAL INVESTMENT MANAGEMENT LLC Hedge Fund- Liquidity Fund- Private Equity Fund3.4b Real Estate Fund- Securitized Asset Fund- Venture Capital Fund- Other Fund- Total Private Fund GAV3.4b AUM3.4b #Funds12
Adviser CORMORANT ASSET MANAGEMENT, LP Hedge Fund1.9b Liquidity Fund- Private Equity Fund2.1b Real Estate Fund- Securitized Asset Fund- Venture Capital Fund- Other Fund- Total Private Fund GAV4.0b AUM4.0b #Funds6
Adviser RRG CAPITAL MANAGEMENT LLC Hedge Fund296.7m Liquidity Fund- Private Equity Fund1.5b Real Estate Fund- Securitized Asset Fund- Venture Capital Fund- Other Fund- Total Private Fund GAV1.8b AUM2.5b #Funds8
Adviser SAGEVIEW CAPITAL LP Hedge Fund19.5m Liquidity Fund- Private Equity Fund1.6b Real Estate Fund- Securitized Asset Fund- Venture Capital Fund- Other Fund- Total Private Fund GAV1.6b AUM2.1b #Funds7
Adviser GRATUS CAPITAL, LLC Hedge Fund- Liquidity Fund- Private Equity Fund- Real Estate Fund- Securitized Asset Fund- Venture Capital Fund- Other Fund- Total Private Fund GAV- AUM2.7b #Funds-
Adviser GOLDEN GATE CAPITAL Hedge Fund8.8b Liquidity Fund- Private Equity Fund910.9m Real Estate Fund- Securitized Asset Fund- Venture Capital Fund- Other Fund- Total Private Fund GAV9.7b AUM10.5b #Funds18
Adviser LUPA RIA INVESTMENT MANAGEMENT LLC Hedge Fund17.0m Liquidity Fund- Private Equity Fund674.7m Real Estate Fund- Securitized Asset Fund- Venture Capital Fund- Other Fund- Total Private Fund GAV691.7m AUM1.7b #Funds6
Adviser MORGAN CREEK CAPITAL MANAGEMENT, LLC Hedge Fund51.7m Liquidity Fund- Private Equity Fund1.1b Real Estate Fund- Securitized Asset Fund- Venture Capital Fund- Other Fund- Total Private Fund GAV1.1b AUM1.4b #Funds34

Brochure Summary

Overview

Overview of BlackRock Registered Investment Advisers Each BlackRock entity listed below (individually, an “Adviser”) is registered as an investment adviser with the SEC and is a wholly-owned subsidiary of BlackRock, Inc., a publicly traded company. Although referred to collectively throughout this Brochure as the Advisers, each Adviser is a separate and distinct company with its own investment capabilities and functions. The Advisers generally have common policies and procedures with respect to United States (“U.S.”) investment advisory clients and share senior management teams. This Brochure provides an overview of each Adviser listed in the table below, showing Client Assets Managed1 as of (12/31/2023): BlackRock – Advisers SEC File # In Business Since2 Discretionary Non-Discretionary Total BlackRock Financial Management, Inc. ("BFM") 801-48433 10/21/1994 29 years 1,285,414,048,014 3,083,758,425 1,288,497,806,439 BlackRock Advisors, LLC ("BAL") 801-47710 9/23/1994 29 years 869,677,370,186 -- 869,677,370,186 BlackRock International Limited ("BIL") 801-51087 10/4/1995 28 years 48,141,818,006 -- 48,141,818,006 BlackRock Capital Management, Inc. ("BCM") 801-57038 11/19/1999 24 years 110,923,554,810 -- 110,923,554,810 BlackRock Investment Management, LLC ("BIM") 801-56972 9/28/1999 24 years 360,677,383,435 97,514,127,314 458,191,510,7493 BlackRock Fund Advisors ("BFA") 801-22609 9/20/1984 39 years 3,047,294,350,591 -- 2,406,691,634,676 BlackRock (Singapore) Limited ("BSL") 801-76926 12/20/2000 23 years 50,657,385,763 -- 50,657,385,763 BlackRock Asset Management North Asia Limited ("BAMNAL") 801-77343 8/10/1998 25 years 96,927,116,767 -- 96,927,116,767 BlackRock Asset Management Schweiz AG ("BAMS") 801-78476 6/17/2005 18 years 1,267,893,232 -- 1,267,893,232 BlackRock Capital Investment Advisors, LLC ("BCIA") 801-112118 11/2/2017 6 years 50,708,850,726 -- 50,708,850,726 Tennenbaum Capital Partners, LLC (“TCP”) 801-60384 5/26/1999 24 years 6,087,355,192 -- 6,087,355,192 SVOF/MM, LLC (“SVOF/MM”) 801-63473 6/10/2004 19 years 203,495,921 -- 203,495,921 1 The assets reported as Client Assets Managed include those assets for which an Adviser acts as the primary adviser and/or the Adviser has been delegated investment management authority of all or a portion of the assets of a client of another Adviser. Assets reported as Client Assets Managed excludes assets for which a contracting Adviser has delegated discretionary investment advisory authority to another Adviser. 2 “In Business” is based on each Adviser’s date of incorporation or organization, as appropriate. 3 BIM’s “Non-Discretionary” assets include: $126,520,257 with respect to which BIM is responsible for making investment recommendations to clients and, if approved by such clients, placing trades in their accounts to implement such recommendations; and $74,592,672,396 with respect to which BIM provides investment services (in the form of model portfolios) to third-party investment managers and such managers are responsible for placing trades in their client accounts based on such model portfolios (please see references below to “Model-Based SMA Programs” for more information on BIM’s participation in such Model-Based SMA Programs). Advisory Services As part of their investment management services, the Advisers collectively offer a range of investment solutions from fundamental and quantitative active management to indexing strategies designed to gain broad exposure to the world’s capital markets. Each Adviser generally provides investment management services in accordance with applicable investment guidelines and restrictions, including applicable restrictions on investing in certain securities, or types of securities or other financial instruments, that are developed in consultation with the Client, or in accordance with the mandate selected by the Client (e.g., fixed income, cash management, equity, private market, index or multi-asset). Each pooled investment vehicle managed or otherwise advised by an Adviser (e.g., U.S. registered investment companies, including ETFs, and private investment funds) is managed in accordance with its investment guidelines and restrictions and generally is not tailored to the individualized needs of any particular fund shareholder or fund investor, and an investment in such a vehicle does not, in and of itself, create an advisory relationship between the shareholder or investor and an Adviser. The Advisers use both automated and/or manual processes to manage portfolios in accordance with their stated portfolio investment guidelines and restrictions. An overview of each Adviser and its primary focus is provided in the table below: 4 BIL is located in the United Kingdom and authorized by the Financial Conduct Authority of the United Kingdom. In some cases, laws, rules and regulations applicable to BIL differ from those described generally herein. In such cases, BIL has separate policies and procedures in support of such laws, rules and regulations. 5 BSL is located in Singapore and licensed by the Monetary Authority of Singapore. In some cases, laws, rules and regulations applicable to BSL differ from those described generally herein. In such cases, BSL has separate policies and procedures in support of such laws, rules and regulations. 6 BAMNAL is located in Hong Kong and licensed by the Hong Kong Securities and Futures Commission in Hong Kong. In some cases, laws, rules and regulations applicable to BAMNAL differ from those described generally herein. In such cases, BAMNAL has separate policies and procedures in support of such laws, rules and regulations. Advisers Primary Focus BFM Manages assets for institutional and high net worth clients, separate accounts, pooled investment vehicles, private investment funds and U.S. registered investment companies. Mandates include cash management, equity, fixed income, private market, multi-asset and quantitative equity strategies. BAL Manages assets primarily for U.S. registered investment companies and 529 Plans. Has a small number of institutional separate account clients. Mandates include cash management, equity, fixed income, private market, multi-asset and quantitative equity strategies. BIL4 Manages assets for institutional clients, separate accounts, pooled investment vehicles and U.S. registered investment companies, including ETFs. Mandates include equity, fixed income, cash management and multi- asset strategies. BCM Manages assets for institutional and high net worth clients, separate accounts, pooled investment vehicles, private investment funds, and U.S. registered investment companies. Mandates include cash management, fixed income and equity strategies. BIM Manages assets for institutional clients, high net worth and other individual clients, separate accounts, pooled investment vehicles and U.S. registered investment companies. Also sponsors an SMA (“wrap fee”) program. Mandates include cash management, equity, fixed income, private market and multi-asset strategies. BFA Manages assets for institutional clients and U.S. registered investment companies, including ETFs. Mandates include cash management, equity, fixed income, multi-asset and index strategies. BSL5 Manages assets for institutional clients, pooled investment vehicles and U.S. registered investment companies. Mandates include fixed income, private market and equity strategies. BAMNAL6 Manages assets for institutional clients, pooled investment vehicles and U.S. registered investment companies, including ETFs. Mandates include equity and real estate strategies. The Advisers’ investment management services are offered (directly or indirectly through a sub-advisory arrangement with the Client's primary investment adviser) to registered investment companies, single- investor funds, discretionary and non-discretionary advisory programs, commingled investment vehicles, other investment advisers, and individuals and institutional investors through separate account management. The types of clients to which each Adviser provides investment management services are disclosed in each Adviser’s Form ADV Part 1 and summarized in Item 7 ("Types of Clients") of this Brochure. Depending on the investment strategy or strategies that a Client wishes to pursue, the Client's ultimate contractual relationship can be with one or more of the Advisers. For example, a Client that engages an Adviser to perform U.S. fixed income and non-U.S. equity investment services can have two contractual relationships, one with BFM and one with BIL. Institutional Separate Accounts and SMAs Certain Advisers provide investment management services directly to institutional clients and/or high net worth and other individual clients through SMAs. Institutional clients typically retain an Adviser to manage their accounts pursuant to a negotiated IMA between the Adviser and the Client. As part of their institutional separate account business, the Advisers have developed many investment strategies to meet individual client risk profiles. The Advisers' institutional fixed income strategies span the yield curve and incorporate the expertise of various U.S. and non-U.S. sector specialists. The guidelines for each Client's fixed income strategy are tailored to reflect the Client’s particular investment needs with respect to interest rate exposure, sector allocation, and credit quality. The Advisers' cash management strategies typically emphasize quality and liquidity. The Advisers offer both U.S. and non-U.S. equity investment strategies to institutional clients using a variety of investment styles, including growth, value, core and enhanced equity, that are targeted to specific market capitalization ranges, including small-cap, mid-cap, small/mid-cap, large-cap and all-cap, as well as geographic and industry sectors which can be tailored to meet the specific needs of clients. The Advisers also offer private market asset and multi-asset separate account strategies to institutional clients, including strategies that permit the Advisers to allocate all or a portion of the portfolio management to unaffiliated investment advisers selected by the Advisers. 7 BAMS is located in Switzerland and authorized as a fund management company with the Swiss Financial Market Supervisory Authority. In some cases, laws, rules and regulations applicable to BAMS differ from those described generally herein. In such cases, BAMS has separate policies and procedures in support of such laws, rules and regulations. Advisers Primary Focus BAMS7 Manages assets for institutional clients, pooled investment vehicles and separate accounts. Mandates include fixed income, equity, private equity and infrastructure strategies. Also engages in distribution activity in relation to non-U.S. domiciled collective investment schemes, as well as U.S. and non-U.S. ETFs. BCIA Manages assets for institutional clients, pooled investment vehicles, U.S.-registered investment companies, business development companies and private investment funds. Mandates focus on credit, private equity and secondaries opportunities. TCP Manages assets for pooled investment vehicles, U.S.-registered investment companies, business development companies and private investment funds. Mandates focus on credit opportunities. SVOF/ MM Manages assets for private investment funds. Mandates focus on credit opportunities. Individual Clients can retain an Adviser to manage their accounts by participating in a SMA Program sponsored either by the Adviser or by a third-party investment-adviser, broker-dealer or other financial services firm (the “Sponsor”). Depending on the structure of the program, an SMA Program client enters into an investment advisory agreement with the Adviser and/or the third-party Sponsor. BIM sponsors Private Investors, an SMA Program. Through Private Investors, BIM offers a variety of equity, fixed income, and multi-asset investment strategies to Clients generally referred by Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) pursuant to an endorsement arrangement between BIM and MLPF&S which is described in Item 14 (“Client Referrals and Other Compensation”) of this Brochure. Additional information about Private Investors is available through its disclosure document (the “Private Investors Brochure”), which is available to current and prospective Private Investors clients. As the sponsor of Private Investors, BIM provides Private Investors clients with the Private Investors Brochure. On June 30, 2020, the Private Investors program was “soft closed”. Effective October 15, 2020, this program status change means that only Clients who meet specific criteria set by MLPF&S can open new accounts on the Private Investors platform, subject to certain exceptions agreed to by MLPF&S from time to time. However, existing Private Investors clients will be able to add and withdraw funds in their existing accounts as well as make strategy changes after this date. BIM also participates as an investment manager in SMA Programs sponsored by third-party Sponsors, including in certain cases where BIM acts as sub-adviser to Clients who authorize their investment advisers to retain BIM (directly or indirectly, including through a turnkey asset management platform) to act as a discretionary investment manager. The SMA Programs in which BIM currently participates are identified in BIM’s Form ADV Part 1. BIM requires a minimum account size for certain of its investment strategies, which varies among SMA Programs. In most SMA Programs, the Sponsor is responsible for establishing the financial circumstances, investment objectives, and investment restrictions applicable to each Client, often through a client profile (the “Profile”) and discussions between the Client and the Sponsor’s personnel. Each Client typically completes a Profile in addition to executing a program contract with the Sponsor. In some SMA Programs (often referred to as “Dual Contract SMA Programs”), Clients are required to execute a separate agreement directly with each investment manager (such as BIM) or the investment
manager is made a party to the client/Sponsor agreement. The Client’s program agreement with the Sponsor generally sets forth the services to be provided to the Client by or on behalf of the Sponsor, which can include, among other things: (i) manager selection; (ii) trade execution, often without a transaction-specific commission or charge; (iii) custodial services; (iv) periodic monitoring of investment managers; and (v) performance reporting. Clients typically are charged by the Sponsor quarterly, in advance or in arrears, a comprehensive or wrap fee based upon a percentage of the value of the assets under management to cover such services. The wrap fee often, but not always, includes the advisory fees charged by BIM (or other participating managers) through the program. Where the services provided by BIM (or another participating manager) are included in the wrap fee, the Sponsor generally collects the wrap fee from the Client and remits the advisory fee to BIM (or other participating manager). In Dual Contract SMA Programs, the investment manager’s fee typically is paid directly by the Client pursuant to a separate agreement between the investment manager and the Client. SMA Program Clients also are subject to additional fees, expenses, and charges (e.g., commissions on transactions executed by a broker-dealer other than the Sponsor or the program’s designated broker- dealer(s), expenses with respect to investments in pooled vehicles (such as ETFs and money market funds and other registered investment companies), dealer mark-ups or mark-downs on principal transactions, and certain costs or charges imposed by the Sponsor or a third-party, such as odd-lot differentials, exchange fees, and transfer taxes mandated by law). Generally, Sponsors are responsible for providing Clients with both this Brochure and other applicable brochures for the Sponsor's program (the “Program Brochure”). The Program Brochure for each Sponsor is also available through the SEC’s Investment Adviser Public Disclosure (IARD) website. SMA Program Clients should review the Sponsor’s Program Brochure for further details about the relevant program. Such Clients should consider that, depending upon the rate of the wrap fee charged, the amount of trading activity, the value of custodial and other services provided and other factors, the wrap fee could exceed the aggregate costs of the services provided if they were to be obtained separately (although, in some cases, it is possible to obtain such services only through the program) and, with respect to brokerage, any transaction-based commissions paid by the account. BIM is not responsible for, and does not attempt to determine, whether a third-party SMA Program is suitable or advisable for program participants. BIM reserves the right, in its sole discretion, to reject any account referred to it by a Sponsor for any reason, including, but not limited to, the Client’s stated investment goals and restrictions. BIM’s fees for managing SMA Program accounts can be less than the fees it receives for managing similar accounts outside of an SMA Program. However, Clients should be aware that, as discussed above, the total fees and expenses associated with an SMA Program can exceed those available if the services were acquired separately. An institutional Client typically consults with an Adviser at the outset of the adviser-client relationship to establish customized investment guidelines applicable to the Adviser’s management of the Client’s separate account, and such guidelines often vary significantly among institutional Client separate accounts with the same investment objective. An SMA Program Client typically selects (in its program agreement) an investment strategy for BIM to utilize in connection with its management of the Client’s account (e.g., U.S. large-cap equity, U.S. short-term taxable fixed income). As discussed in Item 8 (“Methods of Analysis, Investment Strategies and Risk of Loss”) of this Brochure, SMA Program accounts following the same investment strategy typically are managed by BIM in accordance with a “target portfolio” (for equity securities) or “model guidelines” (for fixed income securities), subject to any reasonable investment restrictions imposed by Clients. Therefore, SMA Program accounts following the same investment strategy typically hold the same or similar securities in accordance with the target portfolio or model guidelines, as applicable. In addition, BIM typically effects equity transactions for SMA Program accounts with the program’s designated broker-dealer, whereas an Adviser usually effects equity transactions for institutional separate accounts with a variety of broker-dealers. For additional information please refer to Item 12 (“Brokerage Practices”) of this Brochure. Since an SMA Program account is generally only one component of a Client’s overall portfolio, BIM will not approve or otherwise monitor compliance with the Client’s investment policy statement(s) (IPS) applying to the Client’s overall portfolio when provided in connection with the opening of an account in the SMA Programs described in this Brochure. BIM will not be responsible for ensuring that a Client’s investment policy guidelines and asset allocation choices comply with all specific legal, actuarial or other requirements that may apply as part of the IPS. That responsibility rests solely with the Client who should consult with their legal and tax advisors regarding those matters. Certain investment strategies offered in some SMA Programs and institutional separate accounts invest in securities that are not traded in U.S. markets. As a result, certain securities are subject to state or territory registration requirements. If a security an Adviser wishes to purchase for such an SMA Program or institutional separate account is not registered or exempt from registration in a particular state or territory, applicable regulatory requirements can restrict the purchase of that security for residents of that state or territory, which could affect portfolio composition, diversification and performance. Model-Based SMA Programs In certain SMA Programs (referred to below as “Model-Based SMA Programs”), BIM provides non- discretionary investment services (often in the form of model portfolios) to an overlay portfolio manager (“OPM”) retained by the Sponsor which may utilize BIM’s model portfolios in connection with its management of client accounts. Generally, it is only the OPM, and not BIM, which acts as investment adviser to program clients, and in most of the Model-Based SMA Programs in which BIM participates, the OPM, and not BIM, is responsible for implementing trades in Client accounts. In most of the Model-Based SMA Programs in which BIM participates, Clients are able to designate the particular model portfolios to be utilized by the OPM in managing their accounts, the OPM typically implements BIM’s model portfolios (subject only to account-specific restrictions imposed by Clients), and the fees payable to BIM for providing such model portfolios typically are paid by the Sponsor or OPM based on the amount of their clients’ assets that are managed by the OPM. A model portfolio may include equity and/or fixed income securities including, but not limited to, shares of exchange-traded funds and mutual funds, some of which may Affiliated Funds) that are in addition to any fees received by BIM for providing non-discretionary investment services. BIM generally includes such assets in its Non-Discretionary Client Assets Managed set forth above in the table under “Overview of BlackRock Registered Investment Advisers” in Item 4 (“Advisory Business”) of this Brochure. The Model-Based SMA Programs to which BIM currently provides model portfolios are identified in BIM’s Form ADV Part 1. Delivery of Model Portfolios BlackRock, through various business units, offers non-discretionary model portfolios, some of which may be customized, to registered investment advisers and other financial institutions (“Financial Intermediaries”). Such model portfolios may be composed of either: (i) all Affiliated Funds; or (ii) a significant allocation to Affiliated Funds and the remaining allocation to Third Party Funds. In certain instances, model portfolios that include Third Party Funds target a minimum allocation to Affiliated Funds but can also allocate up to 100% in Affiliated Funds. Access to model portfolios may be made available through agreements with the financial institutions or through BlackRock’s Research and Digital Services (as described below), and a Financial Intermediary is responsible for determining the suitability of a particular model portfolio for its clients. When Third Party Funds are included in a model portfolio, BlackRock will not review the entire universe of available Third Party Funds that may be appropriate for a model portfolio, but rather will only consider for inclusion a subset of such Third Party Funds that have been reviewed and approved by BlackRock as determined in its sole discretion. As a result, there may be one or more Third Party Funds that would be a more appropriate addition to the model portfolio than the investment product selected by BlackRock, from the standpoint of the factors that BlackRock has taken into consideration or other factors not considered. Such Third Party Funds not selected may outperform the investment product selected for the model portfolio. When a model portfolio includes only Affiliated Funds, BlackRock will not review or consider Third Party Funds. As a result, there may be one or more Third Party Funds that would be a more appropriate addition to the model portfolio than the Affiliated Fund selected by BlackRock, from the standpoint of the factors that BlackRock has taken into consideration or other factors not considered. Such Third Party Funds not selected may outperform the Affiliated Fund selected for the model portfolio. Please refer to Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”) of this Brochure and the disclosure under the headings “Use of Affiliated Products” and “Use of Unaffiliated Products” for a discussion of conflicts associated with the use of Affiliated Funds and Third Party Funds. BlackRock is not responsible for implementing trades in the accounts of Client accounts. Generally, it is the Financial Intermediary, and not BlackRock, which is responsible for implementing trades in Client accounts (subject only to account-specific restrictions imposed by clients). Portfolio Research Services and Digital Investment Tools and Analysis In certain instances, BFM and BFA provide impersonal, non-discretionary portfolio research services and digital tools and analysis (“Research and Digital Services”) to: (i) institutional investors and/or fiduciaries acting on behalf of institutional investors, in the case of BFM; and (ii) financial advisers and other representatives of a registered investment adviser, in the case of BFA and BFM (each, a “Research and Digital Service Recipient”). Such Research and Digital Services may be provided to Research and Digital Service Recipients through: (i) BlackRock’s website or (ii) a digital property made available on BlackRock’s or a third-party’s website. The Research and Digital Service Recipient may use the Research and Digital Services, which may include model portfolios provided by BlackRock or by third-party providers, for investment research or portfolio analysis and is under no obligation to implement any output or analysis from the Research and Digital Services. Neither BFM nor BFA is responsible for any model portfolios or other information provided by third parties for use in the Research and Digital Services. Services of Affiliates BlackRock, Inc. operates its investment management business through the Advisers, as well as through multiple affiliates, some of which are also investment advisers registered with the SEC, one of which is a limited purpose national banking association chartered by the U.S. Department of Treasury's Office of the Comptroller of the Currency, some of which are registered only with non-U.S. regulatory authorities and some of which are registered with multiple regulatory authorities. The Advisers use the services of their broker- dealer affiliates which are registered under the Securities Exchange Act of 1934, as amended (the “Exchange Act”) and members of the Financial Industry Regulatory Authority (“FINRA”), as needed. For additional information, please refer to Item 10 (“Other Financial Industry Activities and Affiliations”) and Item 12 (“Brokerage Practices”) of this Brochure. The Advisers use the services of one or more BlackRock, Inc. subsidiaries or appropriate personnel of one or more BlackRock, Inc. subsidiaries for investment advice, portfolio execution and trading, operational support, and client servicing in their local or regional markets or their areas of special expertise without specific consent by the Client, except to the extent explicitly restricted by the Client in or pursuant to its IMA, or inconsistent with applicable law. Arrangements among affiliates take a variety of forms, including but not limited to dual employee, delegation, participating affiliate, sub-advisory, sub-agency, or other servicing agreements. This practice is designed to make BlackRock’s global capabilities available to an Adviser’s Clients in as seamless a manner as practical within a varying global regulatory framework. In these circumstances, the Adviser with which the Client has its IMA remains fully responsible for the account from a legal and contractual perspective. No additional fees are charged for the affiliates’ services except as set forth in the Client’s IMA, governing documents and/or offering memorandum (“OM”). Please refer to Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”) of this Brochure and the section of disclosure headed “Potential Conflicts That Arise With Respect to Services Provided by or Through Various BlackRock Entities” for a discussion of conflicts associated with the use of Affiliated services.