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nd Expenses" in Part Two of the Underlying Fund Memorandum for further discussion of the Underlying Fund's and Underlying Master Fund's expenses. BNY Mellon Alternative Investment Services (the "Sub- Administrator") performs certain administration, accounting and investor services for the AlphaKeys Fund and other investment funds spon
all years of the Underlying Fund and the Underlying Master Fund unless revoked with the consent of the IRS. As a result of the Underlying Fund's and the Underlying Master Fund's mark-to-market election, the AlphaKeys Fund will generally be required to recognize ordinary gain or loss on all of the securities held by the Unde
Part Two of the Underlying Fund Memorandum for further discussion of the Underlying Fund's and Underlying Master Fund's expenses. OTHER EXPENSES BNY Mellon Alternative Investment Services (the "Sub-. Administrator") performs certain administration, accounting and investor services for the AlphaKeys Fund and other investment funds sp
ing obligations in non-U.S. jurisdictions, including withholding taxes on dividends, interest and proceeds. In particular, the Underlying Fund's and the Underlying Master Fund's non- U.S. investments may cause some of the income or gains of the AlphaKeys Fund to be subject to withholding or other taxes of non-U.S. jurisdicti
the Underlying Fund Memorandum for further discussion of the Underlying Fund's and Underlying Master Fund's expenses. OTHER EXPENSES MEVIAXWELL BNY Mellon Alternative Investment Services (the "Sub-. Administrator") performs certain administration, accounting and investor services for the AlphaKeys Fund and other investment funds sp
ing obligations in non-U.S. jurisdictions, including withholding taxes on dividends, interest and proceeds. In particular, the Underlying Fund's and the Underlying Master Fund's non- U.S. investments may cause some of the income or gains of the AlphaKeys Fund to be subject to withholding or other taxes of non-U.S. jurisdicti
Entities connected to both BNY Mellon Alternative Investment Services and the Underlying Master Fund's

United States
LOCATION
Millennium
ORGANIZATION
Ghislaine Maxwell
PERSONCustodian
ORGANIZATION
UBS AG
ORGANIZATIONTrigger Event
ORGANIZATION
Paul Volcker
PERSON
U.S. Treasury
ORGANIZATIONthe Federal Reserve System
ORGANIZATIONNon-U.S. Investments
ORGANIZATION
the Internal Revenue Service
ORGANIZATION
New York
LOCATIONthe District of Columbia
LOCATIONErnst & Young LLP
ORGANIZATIONClasses of Interests
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONSchulte Roth & Zabel LLP
ORGANIZATIONAnti-Money Laundering
ORGANIZATIONCayman
LOCATIONThis Confidential Memorandum
ORGANIZATION