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Regulatory Disclosures
 

U.K. REGULATORY DISCLOSURES

When issued in or from the UK, the information contained herein is issued by Wedge Alternatives Ltd which is authorised and regulated by the Financial Services Authority (“FSA”).  Wedge Alternatives Ltd (and other companies in the Wedge Alternatives group) market a range of funds all of which are defined by UK law as “Unregulated Collective Investment Schemes” (“UCIS”) and the promotion of a UCIS either within the UK or from the UK is severely restricted by statute.  Consequently, this document is only made available to professional clients, eligible counterparties and certain other professional client categories as defined by the FSA.  Past performance of funds should not be seen as an indicator of future performance and potential investors should note that investing in a UCIS may carry significant risk.

U.S. REGULATORY DISCLOSURES

SEC Registered Broker Dealer - All offerings to U.S. investors are offered through Wedge Alternatives LLC, an SEC registered broker-dealer, registered under the Securities Exchange Act of 1934, and a member of FINRA and SIPC.

FINRA Public Disclosure Program - FINRA requires that we notify you in writing of the availability of an investor brochure that includes information describing FINRA’s Public Disclosure Program.  To obtain a brochure or more information about the program or FINRA, contact the FINRA Public Disclosure Program Hotline at
(800) 289-9999, or access the FINRA web site at www.finra.org.

Complaints - Any customer wishing to contact Wedge Alternatives LLC regarding a complaint should contact the Chief Compliance Officer, Sean O’Brien at Wedge Alternatives LLC, 500 Fifth Avenue, New York, New York or call (212) 730-9086.

Anti-Money Laundering Policies & Customer Identification Program

The USA PATRIOT Act and other applicable regulations require all financial institutions to obtain, verify and record information that identifies each person or entity that establishes a client relationship. We will ask you for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

If you (as an institution) enter into a customer relationship with Wedge Alternatives LLC and are subject to the definition of customer as applied to AML rules, we will ask for corporate information that identifies the name of the entity, its location, offices, types of firm, regulatory filings and some other particular information.  The firm will then do a non-documentary verification to identify the existence of the entity.

What happens if I don’t provide the information requested or my identity can’t be verified?  We may not be able to establish or maintain a business relationship with you.  If you establish a relationship and refuse to provide this information, we may be required to report this action to appropriate governmental authorities.

Wedge Alternatives LLC Privacy Policy

Pursuant to Regulation S-P, Wedge Alternatives LLC provides the following disclosure in relation to its use and protection of customer information:

Wedge Alternatives LLC values its relationship with you and considers your privacy an important priority in maintaining that relationship.  We are committed to protecting the security and confidentiality of your personal information.

Sources of Information - We collect nonpublic personal information about you from the following sources:

  • Information we receive from you, or your broker-dealer, investment adviser or financial representative through interviews, applications, agreements or other forms;
  • Information about your transactions with us; and
  • Information we receive from your inquiries by mail, e-mail or telephone.

Information Collected - The type of data we collect may include your name, address, social security number, age, financial status, assets, income, tax information, retirement and estate plan information, transaction history, account balance, payment history, investment objectives, marital status, family relationships and other personal information.

Disclosure of Information - We do not disclose any nonpublic personal information about our customers or former customers except as permitted by law.  These permitted uses include the disclosure of such information to unaffiliated financial service providers and other companies for the following reasons:

  • In order to provide you with services and to effect transactions in a private placement.  We may disclose your personal information as described above to unaffiliated financial service providers and other companies that perform administrative or other services on our behalf, such as transfer agents, custodians and trustees, or that assist us in the distribution of investor materials such as trustees, banks, financial representatives, proxy services, solicitors and printers.
  • We may also release such information about you if you direct us to do so, if we are compelled by law to do so, or in other legally limited circumstances (for example, to protect your account from fraud).

Confidentiality and Security - With regard to our internal security procedures, Wedge Alternatives LLC, restricts access to your nonpublic personal information to those Wedge Alternatives LLC employees who need to know that information to provide products or services to you.  We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.  For disposal, records are shredded.

Policy Updates and Inquiries - As required by federal law, we will notify you of our privacy policy annually.  We reserve the right to modify this policy at any time, however, if we do change it, we will tell you promptly.  For questions about our policy, please contact us at 212 730 9086.

Business Continuity Plan

Wedge Alternatives, LLC has developed a Business Continuity Plan to address how we will respond to events that significantly disrupt our business.  Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur.  With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us – If after a significant business disruption you cannot contact us as you usually do at (212) 730-9086, you should call our alternative number at Wedge Alternatives Ltd, 33 Lowndes Street,  London SW1X 9HX :  (011) 44 20 7245-1400  or go to our web site at www.wedgealternatives.com.

Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business.  In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. 

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, and bank  impact; regulatory reporting; and assuring our customers prompt access to their transactional information if we are unable to continue our business.

Wedge backs up its important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, our objective is to restore operations and be able to facilitate transactions within 1-5 days. 

Varying Disruptions – Significant business disruptions can vary in scope, affected our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region.  Within each of these areas, the severity of the disruption can also vary from minimal to severe.  In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 1-5 days.  In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 1-5 days.  In either situation, we plan to continue in business and notify you through our web site.

For more information – If you have questions about our business continuity planning, you can contact us at
(212) 730-9086 or email us at sean@wedgealternatives.com

 

 

 
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