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Q. 49.1: Questions 49(c) and 49(e) and Questions 61(b) and 61(d) ask about the percentage of a reporting fund’s net asset value that may be subjected, or is subject, to material restrictions on investor withdrawals/redemption. When responding to these questions, should I take into account every type of material liquidity restrictions associated with the reporting fund?

A. 49.1: The instructions to Question 49 and Question 61 note that you should make a good faith determination of withdrawal/redemption provisions that would likely be triggered during conditions that you view as significant market stress. Accordingly, when responding to these questions, you should only take into account discretionary restrictions that the adviser or fund governing body may impose on the reporting fund above any baseline liquidity restrictions an investor is already subject to in the ordinary course as terms of its investment in the fund. For example, if a fund you manage generally imposes a 1-year initial lock-up period before an investor may make withdrawals/redemptions or only allows for annual withdrawals/redemptions upon 60 days’ notice, you should not take any of these restrictions into account when responding to Question 49 and Question 61 because these restrictions will be accounted for in responses to Question 50. (Updated January 18, 2017)

Q. 49.2: Should I include assets subject to a side-pocket arrangement when responding to Questions 49(c) and 49(e) and Questions 61(b) and 61(d) regarding the reporting fund’s net asset value that may be subjected, or is subject, to material restrictions on investor withdrawals/redemptions?

A. 49.2: No. You should, however, report the percentage of the reporting fund’s net asset value, if any, that is actually in a side-pocket as of the data reporting date in Question 48(a). (Updated January 18, 2017)