REYL Overseas Ltd

Item 7. Types of Clients
ROVS manages many client accounts and as a
result of differences in the fees charged on various    ROVS offers investment management services to
accounts, ROVS has conflicts related to such side-      high-net-worth individual clients, insurance
by-side management of different accounts. For           companies, investment companies and pooled
example, ROVS advisors may manage more than             investment vehicles.
one account according to the same or a                  Generally, ROVS prefers its client relationships to
substantially similar investment strategy and yet       have a minimum of $ 1,000,000 of AUM or AUA.
have a different fee schedule applicable to such        ROVS may accept accounts below the minimum
account as a result of the respective clients’ AUM      requirements or may retain accounts that have
with ROVS.                                              dropped below the minimum requirement due to
                                                        market fluctuation or investment performance.
Side-by-side management of different types of           Accounts that have family, corporate, or other
accounts may raise conflicts of interest when two       relationships may be aggregated for purposes of
or more accounts invest in the same securities or       the minimum account size.
pursue a similar, although not identical, strategy.
These potential conflicts include the favorable or