The 150 inquiries.

Whether RCM routes pooled-client assets into family-owned vehicles (including Beach Front), and how the client-consent and conflict-disclosure arrangements governing that are structured.

Reference: Form ADV

A single shared Chief Compliance Officer (Mr. Ha) serving both the controlling adviser (RCM) and the controlled adviser (Dalton), and how compliance independence is maintained between them.

Reference: Primary records provided in the accompanying evidence binder

RCM's trading and recordkeeping being conducted by Dalton, the entity that RCM majority-owns, and how that arrangement is structured.

Reference: Form ADV

One Chief Investment Officer (Mr. Rosenwald III) allocating investment opportunities across the RCM, Rising Sun, NAVF, and Dalton books, which carry differing fee economics, and how those allocations are governed.

Reference: Primary records provided in the accompanying evidence binder

Cross-trades among related-owned funds, and the written-client-approval mechanism the adviser relies on for principal transactions under Section 206(3).

Reference: Primary records provided in the accompanying evidence binder

The approval of Mr. Rosenwald III's outside directorships (Glass House, BFPM, Hogy) through the firm's compliance function, and how Item 11 outside-board approvals are handled.

Reference: Primary records provided in the accompanying evidence binder

The Hogy Medical take-private, in which Mr. Rosenwald III served as an issuer director while advised funds tendered or reinvested, and how that transaction was handled.

Reference: Primary records provided in the accompanying evidence binder

Whether the same individual carries two different Form ADV Part 2B biographies, with the Rovida/Roditi history appearing in the Dalton clients' version but not in the RCM clients' version, and how that difference arises.

Reference: Primary records provided in the accompanying evidence binder

The RCM Part 2A describing the Family Trust as owning '100%' of RCM while Part 1 Schedule A codes the Trust at ownership code E (75% or more), and how those two figures reconcile.

Reference: Primary records provided in the accompanying evidence binder

The basis for the Beach Front entity name appearing differently across same-day RCM filings ('Properties, LLC' in Part 1 versus 'Property Management, Inc.' in Part 2A/2B).

Reference: Primary records provided in the accompanying evidence binder

V.O.C. Investment Co. and other ICIJ offshore entities of which Mr. Rosenwald III was a director during Dalton's SEC-registration period, and whether and how they appear in the Form ADV Item 7.A / Item 10 disclosures.

Reference: ICIJ Offshore Leaks (public) record

Rising Sun Management operating as an unregistered relying adviser under RCM, and the conditions governing that relying-adviser arrangement.

Reference: Primary records provided in the accompanying evidence binder

The ERISA-pension cross-trade and affiliated-investment exposure on the FedEx, Northrop, and Resolute mandates, and how it is addressed under the Advisers Act and ERISA.

Reference: Primary records provided in the accompanying evidence binder

Jocelyn Rosenwald's role chairing the Glass House audit committee together with her position as a co-founder, daughter of the ~14% voting holder, and a family beneficiary of the related-party flows the committee reviews, and how any conflict is addressed.

Reference: Glass House Brands 40-F

The Series E related-party financing being routed through the Delaware operating subsidiary (GH Group) rather than the BC parent, and how the MI 61-101 minority-approval and valuation requirements were applied.

Reference: Glass House Brands 40-F

The nature of Mr. Rosenwald III's three simultaneous capacities in relation to Glass House — an approximately 10% holder, a 'control or direction' insider, and the adviser-CIO whose advisory pool (per RCM ADV 10(E)) invests client capital into the family vehicles — and how any conflict is addressed.

Reference: Form ADV

Mr. Rosenwald III's seat on the Hogy Medical board in relation to the family-controlled bloc's tender of its approximately 26-27% stake into a Carlyle take-private with an up-to-approximately 20% LP rollover, and how that transaction was structured.

Reference: Japan EDINET large-shareholding report

A single shared Chief Compliance Officer (Christopher Ha), and historically a single GC/CCO (Michelle Lynd), over RCM, Dalton, Rising Sun, and the NAVF Select funds, and how independent compliance oversight is maintained across the commonly-controlled advisers.

Reference: Primary records provided in the accompanying evidence binder

Interlocking directors among Dalton's pension clients (Mr. Turley serving on Citigroup and Northrop; Ms. Ovrum on TechnipFMC and FMC) and any Clayton Act Section 8 considerations.

Reference: Primary records provided in the accompanying evidence binder

Two seated Dalton/RSM directors at Helios Techno (Nishida and Mizuochi) plus a negotiated Anicom seat (Hayashi), and how the director-fee income and board roles are handled.

Reference: Primary records provided in the accompanying evidence binder

Whether three Rosenwald family members (JBR III, Jocelyn, Ha) serve simultaneously on the officer/director rolls of both SEC advisers (RCM and Dalton), and how any related-party governance is handled.

Reference: Primary records provided in the accompanying evidence binder

The audit-committee chair's insider-reporting timeliness under NI 55-104, and how that reporting is handled.

Reference: Canadian SEDI insider-transaction record

NAVF Select LLC (the domestic feeder) standing at 88 of the 100-investor ceiling for its claimed Section 3(c)(1) exemption, and how the Form D / Investment Company Act limits are monitored.

Reference: Primary records provided in the accompanying evidence binder

NAVF Select (Offshore Fund) Ltd.'s Form D claiming only 3(c)(1) with no Reg D exemption item, and which Securities Act exemption (Reg S or Reg D) is relied upon.

Reference: Primary records provided in the accompanying evidence binder

The application of Regulation FD to the Glass House Brands disclosures, given the company's foreign-private-issuer status.

Reference: Glass House Brands 40-F

Whether the GH Group / Glass House related-party preferred and note conversions relied on private-placement exemptions from Securities Act registration.

Reference: Glass House Brands 40-F

Whether the late or bunched SEDI insider filings carry any U.S. securities-reporting obligation in addition to the Canadian one.

Reference: Canadian SEDI insider-transaction record

The difference between the approximately 9.3% voting figure and the approximately 0.18% combined-voting-power figure reported for Jocelyn Rosenwald, and the underlying multiple-voting-share holdings by holder.

Reference: Glass House Brands 6-K

Nasu Denki-Tekko (TSE 5922) and the FIEA Section 27-25(1) amendment that was filed one business day after the deadline, and how that filing timing is addressed.

Reference: Japan EDINET large-shareholding report

The FIEA filing-timeliness across the bloc, including the extent of last-day filing reflected in the reports.

Reference: Japan EDINET large-shareholding report

How the concert-party (kyodo hoyu) holdings are aggregated and reported across the joint filings.

Reference: Japan EDINET large-shareholding report

How FIEA Articles 166/167 apply to the 60-day transaction tables around the Hogy/Carlyle tender offer.

Reference: Japan EDINET large-shareholding report

How Mr. Rosenwald III's seat on the Hogy Medical board relates to the tender of the family bloc and to any carried interest.

Reference: Japan EDINET large-shareholding report

How the Dalton/Rising Sun directorships at Helios Techno (TSE 6927) are structured, including the two currently-seated directors and the 28.74% bloc held during the third-party tender offer, and the director-fee arrangements.

Reference: Japan EDINET large-shareholding report

The 2024 FIEA reform (effective May 1, 2026) lowering the mandatory tender-offer threshold to 30% and extending it to on-market purchases, and the Eiken Chemical (4549) bloc position of approximately 32.8% relative to that threshold.

Reference: Japan EDINET large-shareholding report

Whether there has been any SESC/FSA enforcement, recommendation (kankoku), or surcharge (kachokin) against Dalton, NAVF, NAVF Select, Rising Sun, Dalton Advisory KK, or any Rosenwald principal.

Reference: Primary records provided in the accompanying evidence binder

The nature and basis of the disclosed activist intent (hoyu mokuteki / juyo teian koi to) described in the EDINET reports.

Reference: Japan EDINET large-shareholding report

JBR III's FBAR (FinCEN 114) reporting obligations over the Cayman/Bermuda offshore-entity portfolio (Kings Bay, Rovida, V.O.C., Asia Securitas, DOIT, Dalton Cayman feeders).

Reference: Form ADV

JBR III's Form 5471 reporting obligations (for U.S. officers, directors, or shareholders of foreign corporations) across the same Cayman/Bermuda corporations.

Reference: ICIJ Offshore Leaks (public) record

JBR III's Form 8938 (FATCA) specified-foreign-financial-asset reporting obligations arising from his offshore-entity interests.

Reference: ICIJ Offshore Leaks (public) record

PFIC (Form 8621) exposure for any U.S. person holding Nippon Active Value Fund plc or the Cayman offshore feeder funds.

Reference: Nippon Active Value Fund prospectus

The grantor-trust characterization and Form 1041 treatment of the JBR IV Trust (the vehicle through which the Glass House Brands shares are held).

Reference: Canadian SEDI insider-transaction record

Whether the Kings Bay GLASF liquidation (drawn to zero in approximately December 2025, approximately $2.57M) and the July 2025 Glass House Series E related-party preferred exchange are taxable events for the family sleeves.

Reference: Canadian SEDI insider-transaction record

The Orinoco Trust named as Laura Parker Rosenwald's FEC 'employer,' and whether it is an income-producing trust requiring Form 1041 and family-income reporting.

Reference: Primary records provided in the accompanying evidence binder

Whether the Form ADV Schedule D 7.B disclosure of Kings Bay and Rosenwald Partners corresponds to any separate FBAR, Form 5471, or Form 8938 reporting for those entities.

Reference: Primary records provided in the accompanying evidence binder

The FBAR and related foreign-reporting obligations associated with Kings Bay and James B. Rosenwald III's directorship of it.

Reference: Primary records provided in the accompanying evidence binder

The Hogy Medical approximately 27.58% tender into the Carlyle take-private (March 2026) and the carried-interest / capital-gain characterization for tax purposes.

Reference: Primary records provided in the accompanying evidence binder

Whether Forms 3520/3520-A (foreign-trust reporting) and Form 8865 (foreign-partnership reporting) apply to the family trusts and offshore vehicles.

Reference: Primary records provided in the accompanying evidence binder

Glass House Brands' disclosed cannabis exposure as 100% U.S. (federally Schedule-I) cannabis, and the disclosed 'forfeiture of entire investment' risk, and how that exposure is characterized for the marital estate's GLASF stake (including Benno via the JBR IV Trust).

Reference: Glass House Brands 40-F

The IRC 280E tax positions Glass House discloses — $31.7M cumulative unrecognized tax benefits 'based on legal interpretations that challenge the Company's tax liability under Section 280E' — and how they are structured.

Reference: Glass House Brands 40-F

Whether the Rosenwald family members are disclosed to the California DCC as statutory 'Owners' / financial-interest holders of the license-holding GH subsidiaries.

Reference: Glass House Brands information circular

The DCC management-disqualification disclosure that GLASF makes — 'management team or other owners could be disqualified from ownership' — and how a Rosenwald owner's conduct or non-disclosure would bear on the licenses.

Reference: Primary records provided in the accompanying evidence binder

The cannabis-banking situation that Glass House Brands discloses, including the absence of a federal statutory safe harbor for banks serving cannabis businesses.

Reference: Primary records provided in the accompanying evidence binder

Whether the charitable foundations (Abrons, Rita Allen, Rippel) and the YMCA Retirement Fund have any indirect cannabis / Glass House exposure through Dalton-managed funds.

Reference: Primary records provided in the accompanying evidence binder

The nature and basis of the cannabis-related related-party flows to the Rosenwald family (BFPM consulting, Jon A. Neu Insurance, and GH Group preferred dividends).

Reference: Glass House Brands 40-F

The nature and timing of the approximately $7.97 million in Glass House Brands sales, including the Kings Bay liquidation, that occurred during the pendency of this action.

Reference: Canadian SEDI insider-transaction record

The role of the Family Trust in funding personal expenses and its characterization in Benno's financial affidavit.

Reference: Primary records provided in the accompanying evidence binder

The court's finding regarding the trust-distribution source and the relationship between that source and the income used to determine alimony.

Reference: the Memorandum of Decision (in the case record)

The July 1, 2019 restructuring of the Dalton ownership (55 days before the marriage) and its effect on the interests held through the family trusts.

Reference: Primary records provided in the accompanying evidence binder

Whether the JBR IV Trust appears as an indirect owner on the RCM Schedule A, and how Benno's Dalton/RCM beneficial interest is reflected on the marital balance sheet.

Reference: Primary records provided in the accompanying evidence binder

The nature and terms of the rent-free occupancy of 923 Fifth Avenue, Apartment 4C (approximately $360,000 per year in fair rental value; approximately $2.09 million open mortgage).

Reference: Primary records provided in the accompanying evidence binder

The basis for the estimate of Benno's earning capacity (approximately $1.16M per year) relative to the reported $312K W-2, and the corporate-card / trust-conduit funding of household expenses.

Reference: Primary records provided in the accompanying evidence binder

The $1.45M settlement note and the $1.2M joint-Schwab commitment, and how they appear on Benno's financial affidavit.

Reference: the dissolution financial affidavit (in the case record)

The minor child A.R.'s separate Rosenwald Partners LP interest, and whether it appears on Benno's affidavit.

Reference: Primary records provided in the accompanying evidence binder

The minor child E.R.'s separate Rosenwald Partners LP interest, and whether it appears on Benno's affidavit.

Reference: Primary records provided in the accompanying evidence binder

The nature and terms of the approximately $23 million intra-family migration of Glass House Brands shares to Jocelyn Rosenwald between the first and second quarters of 2026, during the pendency of this action.

Reference: Primary records provided in the accompanying evidence binder

The 2026 intra-family promissory notes and encumbrances and their effect on reportable net worth.

Reference: the dissolution financial affidavit (in the case record)

The status of the $5,000 per month alimony order and the $24,980 arrears wire that was returned rather than received.

Reference: Primary records provided in the accompanying evidence binder

The pendente-lite alimony award relative to the marital standard of living (reported at approximately $50K per month).

Reference: the Memorandum of Decision (in the case record)

The effect of the $5,000 per month award on housing eligibility, given landlord income and asset screening requirements.

Reference: the Memorandum of Decision (in the case record)

The California payroll tax reflected for a sworn Connecticut resident, and the underlying economic domicile (the RCM / Redondo Beach hub).

Reference: Primary records provided in the accompanying evidence binder

How 15 Horseshoe Road (Cos Cob), reported at full fair market value, is treated in relation to a $1 million family-trust acquisition note, and whether that note has been disclosed.

Reference: Primary records provided in the accompanying evidence binder

The LASC 26STCV10838 action (in which RCM is a named defendant) and its relationship to the marital-estate assets.

Reference: Primary records provided in the accompanying evidence binder

The nature of the approximately $262 million Hogy Medical exit as a realization event and how it affects the Family-Trust Dalton equity.

Reference: Primary records provided in the accompanying evidence binder

The Dalton Investments LLC Paycheck Protection Program loan of $665,600 (approved April 14, 2020, MidFirst Bank, SBA loan number 5923317103, NAICS 523920 — portfolio management), forgiven in full ($672,903.11) on May 21, 2021 while the firm was an SEC-registered investment adviser, and how the eligibility and the certification that adequate credit was not available elsewhere are addressed.

Reference: U.S. Small Business Administration PPP FOIA dataset (loan no. 5923317103)

The Rosenwald Capital Management, Inc. PPP loan of $123,600 made the same day (April 14, 2020, U.S. Bank, SBA loan number 6351357102, NAICS 523930 — investment advice), forgiven in full ($124,737.80) while the firm was an SEC-registered investment adviser, and how its eligibility is addressed.

Reference: U.S. SBA PPP FOIA dataset (loan no. 6351357102)

The Beach Front Property Management, Inc. First Draw PPP loan of $1,641,372 (April 12, 2020, Farmers & Merchants Bank of Long Beach, SBA loan number 4090457110, NAICS 531311), reporting 277 jobs, forgiven in full ($1,656,526.59), and how its eligibility is addressed.

Reference: U.S. SBA PPP FOIA dataset (loan no. 4090457110)

The Beach Front Property Management, Inc. Second Draw PPP loan of $1,644,000 (February 1, 2021, SBA loan number 1313348407), reporting 281 jobs, forgiven in full ($1,653,728.88), and how the separate certification of a 25% or greater revenue decline was addressed.

Reference: U.S. SBA PPP FOIA dataset (loan no. 1313348407)

The John A. Neu Insurance Services, Inc. PPP loan of $147,177.50 (April 28, 2020, American Business Bank, SBA loan number 8046927208, NAICS 524210), forgiven in full ($148,693.63), and how its eligibility is addressed.

Reference: U.S. SBA PPP FOIA dataset (loan no. 8046927208)

A Nevada entity named 'Dalton Investments Inc.' that received a PPP loan of $22,524 (May 1, 2020, Wells Fargo Bank, SBA loan number 4922267704, with a blank NAICS code and HUBZone and LMI certifications), forgiven in full ($22,738.75), and how this 'Inc.' entity relates to the documented February 2024 conversion of Dalton Investments LLC to Dalton Investments, Inc.

Reference: U.S. SBA PPP FOIA dataset (loan no. 4922267704)

The approximately $4,244,273 in PPP funds received across these entities, all forgiven in full (approximately $4,279,329), and how the eligibility and certifications supporting the loans and their forgiveness are addressed. I would be grateful to understand the eligibility and certifications supporting the loans and their forgiveness.

Reference: U.S. SBA PPP FOIA dataset, release 240930

Beach View Property Ltd. (a Barbados entity) and Beach Bay Holdings, which appear in the Paradise Papers, and whether either has any relationship to Beach Front Properties or to the family's real-estate interests.

Reference: ICIJ Offshore Leaks database, nodes 100328701 and 82012385

Whether the Cayman real-estate vehicle Rovida Estates Limited has any relationship to the Beach Front or Glass House real-estate interests.

Reference: ICIJ Offshore Leaks database, node 80119152

The terms of the February 2024 conversion of Dalton Investments LLC to Dalton Investments, Inc. and the July 2024 transaction by which Rosenwald Capital Management became the majority owner of Dalton, and whether any beneficial interest connected to this household was diluted, redeemed, or otherwise affected.

Reference: SEC Form ADV filings for CRD 109538 and 308609; Nevada and Delaware corporate filings

Whether the management business of Rovida Asset Management was consolidated into the Dalton complex, and if so, on what terms and with what effect on the value of the enterprise.

Reference: ICIJ Offshore Leaks database, node 82001548; SEC Form ADV history