2010004 Informal Interpretation

From: Berg, Karen E.

Sent: Thursday, October 22, 2020 9:38:27 AM (UTC-05:00) Eastern Time (US & Canada)

To: [Redacted]

Cc: [Redacted]

Subject: RE: Size of Person Test

Confirmed.

From: [Redacted]

Sent: Wednesday, October 21, 2020 4:41:07 PM (UTC-05:00) Eastern Time (US & Canada)

To: [Redacted]

Subject: Size of Person Test

Hi folks.

I am writing to confirm that the informal interpretation printed below still reflects the PNO's position on this issue.

Specifically Fund's regularly prepared balance sheet does not include a line item for unfunded capital commitments and does not include this amount when its lists the Fund's total assets. However, the footnotes to such balance sheet do describe the unfunded capital commitments.

We understand that under Informal Interpretation #1501003 we would not have to include or consider such unfunded capital commitments when assessing whether the Fund satisfies the HSR size of person test because they are not listed in a line item in the balance sheet.

Do you agree?