Bristol Group Inc

Fees and Compensation
   Description
      Bristol Group has different fee arrangements with each of its clients. Bristol
      Group currently charges its base advisory fees based on one or more of the
      following: (1) a fixed annual fee, (ii) a percentage applied to contributed
      capital and/or unfunded capital commitments, (iii) a percentage applied to
      distributed cash flow, and/or (iv) a percentage applied to the principal balance
      of third party debt. Bristol Group also has agreements with clients to receive
      performance based compensation tied to annual and/or cumulative
      performance metrics based on actual distributed cash flow or on realized
      proceeds from dispositions. Different fee structures may also be
      contemplated for development projects.
       Bristol Group does not issue any publications or reports on a subscription
       basis or for a fee.

   Fee Billing
       Bristol Group bills its clients for its base investment management fees on
       either a monthly or quarterly basis, in arrears, with such fee calculation based
       on the respective governing Agreement. Performance based compensation,
       when earned, is generally billed annually, in arrears, or at the time an event
       triggers performance based compensation, and generally is approved by
       clients prior to being paid.
       Bristol Group’s separate account clients receive billing invoices from Bristol
       concurrent with, or prior to, such fees being paid and are subject to annual
       independent audit.

                                  Bristol Group, Inc.

       For Bristol Group’s private funds, the fee calculation is included in Bristol’s
       quarterly investment reports which are delivered to all investors in the private
       funds and are subject to annual independent audit.
       No compensation is received in advance.
       Clients must consent in advance to direct payment of fees from investment
       accounts.

   Other Fees
       In general, other than a development fee that may be charged for new
       ground-up developments and real estate projects with a significant
       redevelopment component, Bristol Group charges no other fees for its
       services.

   Past Due Accounts and Termination of Agreement
       Bristol Group reserves the right to take all remedies allowed in the
       aforementioned agreements in the event fees due to Bristol Group become
       significantly overdue. No such remedies have been necessary.

Types of Clients
   Description
      Bristol Group generally provides investment management services to major
      public and corporate pension funds, trusts, estates, and other qualified
      investors.
       Client relationships vary in scope and length of service.

                                  Bristol Group, Inc.

   Account Minimums
      Bristol Group determines account minimum sizes on a case by case basis.

Methods of Analysis, Investment Strategies and Risk of Loss