From: Ada Clapp <1 To: Brad Wechsler <1 CC: Jeffrey Epstein <[email protected]> Subject: RE: Re AP Investco Date: Tue, 02 Jun 2015 20:09:11 +0000 I am not sure I understand your question. Let me confirm with PW but my understanding is that if you are doing the trading as a paid employee of Elysium (whether you are doing it under a POA or an investment agreement) —you may be viewed as being compensated for providing investment advice. In that case, we would want the trading accounts to be in the name of Elysium and to ensure that Elysium falls within the definition of "family office" to take advantage of the registration exception provided to family offices. I will let you know what PW thinks. What was the purpose behind the Investco wrapper? To segregate investment activities from other family office activities? Ada Clapp From: Brad Wechsler Sent: Tuesday, June 02, 2015 2:42 PM To: Ada Clapp Cc: Jeffrey Epstein Subject: Re: Re AP Investco If I was running elysium as an employee but haad a simple poa from leon individually that's not as clean I guess? Sent from my Verizon Wireless BlackBerry From: Ada Clapp Date: Tue, 2 Jun 2015 18:14:50 +0000 To: Brad Wechsler< Subject: RE: Re AP Investco Marco and Phil work with Josh on this. I asked how Josh does it but they would not say (understandable--client confidentiality and all)—but they did say they would recommend this approach. I don't know what JEE's goals for tax reporting are. That has not been shared with me. If you are asking whether you need investco to do the investing, I think the answer is no. Leon could just hire an investment advisor to do his trading pursuant to an investment advisory agreement and avoid violating the Apollo compliance rules by using the certification Cindy Michel sent. However, I don't know how you would get around the registration requirement if you are the investment advisor (I assume you are not a RIA) without the family office exception. Ada Clapp Chie