(b) [Meetings were conducted by Dan Zwim and Vasan Kesavan, in most cases by telephone.] (c) [Some investors made follow-up calls, mostly to Dan Zwim.] (d) The investors were told about all issues. F. Reasons DBZ initially decided not to disclose the management fee and plane expense issues to investors. 1. Disclosure was not initially made to the investors because: (a) Both issues were discovered internally; DBZ's compliance procedures worked. (b) Investors had been made whole. (c) The wrongdoer (Gruss) was removed from the firm. (d) The management fee and plane expense issues (both individually and collectively) were determined to be immaterial from the perspective of the funds and the investors. D0C rD.10279525.5 (I) Materiality was considered from both a legal and an accounting perspective. (ii) Materiality was considered from both a quantitative and qualitative perspective. (iii) From a quantitative perspective, the amounts involved were immaterial. a. For the plane: (1) The payments for the plane ($3.8 million) represented approximately 27 basis points ($3.8 million of 21 DECCO_FTC0025499 CONFIDENTIAL EFTA00593388