'40 Act Compliance CONSULTING

Valerie Y. Pierrat is the Director of '40 Act Compliance and a Chief Compliance Officer with over 20 years of institutional knowledge and expertise in designing and implementing policies and procedures for compliance with the Investment Advisers Act of 1940 and Investment Company Act of 1940.  She has designed and implemented compliance policies and procedures for private fund real estate clients, performed risk assessments, and annual reviews under Investment Adviser Act Rule 206(4)-7 and Investment Company Act Rule 38a-1, reported to the boards of large fund complexes on compliance matters, and coordinated several SEC routine exams and inquiries during her career.  Prior to her consulting work, Ms. Pierrat served as Chief Compliance Officer for the wealth management division of City National Bank, reporting to the asset management division and the board of the bank's proprietary mutual fund complex. Prior to assuming the CCO role at City National Bank, Ms. Pierrat was employed with the Capital Group, where she managed compliance reporting for Capital Guardian's closed-end interval institutional Emerging Market Growth Fund and two retail balanced funds in the American Funds complex. Prior to joining The Capital Group, Ms. Pierrat spent 10 years at Morgan Stanley in New York, where she managed board reporting for 14 closed-end funds, five mutual funds and several off-shore funds. Ms. Pierrat was graduated from Claremont Graduate Schools and received her undergraduate degree from Tufts University. Ms. Pierrat is a member of the '40 Acts California Group.