GLDUS125 Gerald Ford Section 9: Certain Legal. ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund IV, LP U.S. Commodity Exchange Act of 1936 Each of the Manager and the General Partner is exempt from registration with the U.S. Commodity Futures Trading Commission (the "CFTC) and is not registered with the CFTC as a commodity pool operator ("CPO"), pursuant to an exemption under CFTC Regulation Section 4.13(a)(3) for pools (a) whose interests are exempt from registration under the Securities Act and are offered and sold without marketing to the public in the U.S., (b) whose participants are limited to accredited investors and (c) whose investments in commodity interest positions are limited such that either (1) the aggregate initial margin, premiums, and required minimum deposit for retail forex transactions (as defined in CFTC Regulation Section 5.1(m)) required to establish such positions, determined at the time of the most recently established position, does not exceed 5% of the liquidation value of the pool's portfolio, after taking into account unrealized profits and unrealized losses on any such positions it has entered into, provided, that, in the case of an option that is in4he- money at the time of purchase, the in4he-inoney amount as defined in CFTC Regulation Section 190.01(x) may be excluded in computing such 5% or (2) an aggregate net notional value of such positions, determined at the time of the most recently established position, does not exceed 100% of the liquidation value of the pool's portfolio, after taking into account unrealized profits and unrealized losses on any such positions it has entered into. Therefore, unlike a registered CPO, neither the General Partner nor the Manager is required to deliver a disclosure document (as defined in the CFTC Regulations) and a certified annual report to investors. The CFTC does not pass upon the merits of participating in a pool or upon the adequacy or accuracy of