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rth in Section 10.1(b)(i). "Transferor" shall have the meaning set forth in Section 10.1(bXi). "Treasury Regulations" shall mean the regulations of the Treasury Department issued pursuant to the Code, as amended from time to time. "UBS" shall mean UBS AG and any of its affiliates. "UBSFA" shall mean UBS Fund Advisor,
riod commencing on the date hereof and ending upon the termination of the investment period of the Underlying Fund, in accordance with the terms of the Underlying Fund Documents. "Investment Period Expiration Date" shall mean the expiration of the final date of the Investment Period, in accordance with the terms of the Unde
nsult with their tax advisors to fully understand the tax consequences of an investment in the AlphaKeys Fund. This summary is based upon the Code, the U.S. Treasury regulations ("Treasury Regulations") promulgated thereunder, published rulings, court decisions and other applicable authorities, all as in effect
other documents referred to herein related to the Underlying Fund. This Memorandum contains information concerning the AlphaKeys Fund Agreement and the Underlying Fund Documents. However, the information set forth in this Memorandum does not purport to be complete and is subject to and qualified in its entirety by reference
nsult with their tax advisors to fully understand the tax consequences of an investment in the AlphaKeys Fund. This summary is based upon the Code, the U.S. Treasury regulations ("Treasury Regulations") promulgated thereunder, published rulings, court decisions and other applicable authorities, all as in effect
other documents referred to herein related to the Underlying Fund. This Memorandum contains information concerning the AlphaKeys Fund Agreement and the Underlying Fund Documents. However, the information set forth in this Memorandum does not purport to be complete and is subject to and qualified in its entirety by reference
Entities connected to both U.S. Treasury and the Underlying Fund Documents

United States
LOCATION
Ghislaine Maxwell
PERSON
New York
LOCATION
UBS AG
ORGANIZATION
Philadelphia
LOCATIONCayman
LOCATION
the Internal Revenue Service
ORGANIZATION
Federal Reserve
ORGANIZATIONthe District of Columbia
LOCATIONKeogh
ORGANIZATION
FDIC
ORGANIZATION
Paul Volcker
PERSONErnst & Young LLP
ORGANIZATIONthe Federal Reserve System
ORGANIZATIONthe New York Stock Exchange
ORGANIZATIONthe U.S. Department of Labor
ORGANIZATION
Cayman Islands
LOCATION
Fannie Mae
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
Millennium
ORGANIZATION