| Manager Compliance Questionnaire |
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December 31, 2009 |
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| 1 |
Have there been any
changes in your organization? Have you undergone any change in ownership or
control? No |
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| 2 |
Have there been any
changes in your investment philosophy? No |
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| 3 |
Have there been any
changes in your staff of investment professionals? No |
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| 4 |
Have you lost a
substantial amount of business (amount of percentage of assets under
management)? $0.6 million/ .03% |
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| 5 |
Have you gained a
substantial amount of business (amount of percentage of assets under
management)? $80 million/ 3.7% |
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| 6 |
Have there been any
new investigations begun by any state or federal government or their
agencies, or any charges filed, with regard to any division or unit of your
company, and in particular anyone who directly or indirectly performs
services for this client? Please provide details (if there is any doubt,
please err on the side of providing too much information). No |
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| 7 |
For managers, with
fixed income portfolios that we monitor, are you currently invested in
commercial mortgage backed securities (CMBS)? (If yes, please give % of fixed
portfolio) No |
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| 8 |
Are you invested in
any unhedged and/or leveraged derivatives? No |
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| 9 |
What
percentage of equity is international?
3.6%
The
manager must immediately notify the Board and the Consultant when the
international exposure reaches ten percent (10%). An explanation will be
needed as to why the manager is changing their discipline. (This does not
apply to managers that are 100% international equity and to those that have
been previously given permission by the board and the consultant) |
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| 10 |
Are you invested in any
companies on the SBA's website? (Please review list of scrutinized companies
on the following website:
http://www.sbafla.com/fsb/ProtectinginvestmentsAct/tabid/402/Default.aspx
No |
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| 11 |
Name of person
completing this form (please include company name)? |
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Michael C. Harhai Buckhead Capital Management |
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Page 8b |
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