Private company

Citigroup Alternative Investments LLC

Citigroup Alternative Investments LLC is a limited liability company registered in the United States, active since 2002.2 It is headquartered in New York, United States.2

Last updated Oct 21, 2026.

Overview

  • HeadquartersNew York, United States2
  • Incorporated inDE3
  • Business address731 Lexington Avenue, 28Th Floor, New York, Ny 100223
  • Legal formLimited Liability Company2
  • LEI549300F0GMNPJY5M0C572
  • StatusActive2
  • LEI statusIssued and current2
  • Registered addressCORPORATION TRUST CENTER 1209 ORANGE ST, 19801 Wilmington, United States2
  • Registered withDivision of Corporations, Department of State, 34909292

Corporate structure

Citigroup Alternative Investments LLC is part of a group headed by Citigroup. 764 entities, 43 countries on record. Switch between the flow chart and the network, and select any entity to see its details.

  • Citigroup New York, New York, United States
    • CITIBANK EUROPE PUBLIC LIMITED COMPANY Dublin, Ireland
      • Bank Handlowy Warszawa, Poland
        • 6 more
      • CEP CBRE UK AFFORDABLE HOUSING NOMINEE 1 LIMITED Subsidiary · London, United Kingdom
      • CEP CBRE UK PROPERTY NOMINEE 1 LIMITED Subsidiary · London, United Kingdom
      • CITI CG AAM PC LTAF NOMINEE LTD Subsidiary · London, United Kingdom
      • CITICAPITAL LEASING (MARCH) LIMITED Subsidiary · London, United Kingdom
      • CITICLIENT (CPF) NOMINEES NO 2 LIMITED Subsidiary · London, United Kingdom
      • CITICLIENT NOMINEES NO 9 LIMITED Subsidiary · Canary Wharf, United Kingdom
      • VIDACOS NOMINEES LIMITED Subsidiary · London, United Kingdom
      • CITIBANK EUROPE PUBLIC LIMITED COMPANY Branch · Dublin, Ireland
      • TDP BALANCED DEDICATED SUB-FUND # 6 Fund · Bertrange, Luxembourg
      • TDP CONSERVATIVE DEDICATED SUB-FUND # 7 Fund · Bertrange, Luxembourg
    • CITICORP LLC New York, New York, United States
      • CITI GSCP INC. Subsidiary · Wilmington, Delaware, United States
        • 3 more
    • Banco Nacional de México Subsidiary · Ciudad de México, Mexico
      • Fondo Banamex de Capitales SA de CV Sociedad de Inversion de Capitales Subsidiary · Mexico City, Mexico
      • IMREF SA DE CV Subsidiary · Cuauhtemoc, Mexico
      • INMUEBLES BANAMEX SA DE CV Subsidiary · Ciudad de México, Mexico
      • Nueva Promotora de Sistemas de Teleinformatica, S.A. de C.V. Subsidiary · Mexico City, Mexico
      • PLANEACION DE RECURSOS HUMANOS SA DE CV Subsidiary · Ciudad de México, Mexico
      • PROMOTORA DE SISTEMAS DE TELEINFORMATICA SA DE CV Subsidiary · Mexico City, Mexico
      • Servicios Corporativos de Finanzas, S.A. de C.V. Subsidiary · Mexico City, Mexico
      • TARJETAS BANAMEX SA DE CV SOFOM ER Subsidiary · Alcaldía Álvaro Obregón, Mexico
    • Citibank Subsidiary · Sioux Falls, South Dakota, United States
      • ASSOCIATES CAPITAL INVESTMENTS, L.L.C. Wilmington, Delaware, United States
        • 2 more
      • CITIBANK OVERSEAS INVESTMENT CORPORATION New Castle, Delaware, United States
        • 91 more
      • AJIAL HOLDINGS LIMITED Subsidiary · George Town, Cayman Islands
      • AMATRA INVESTMENTS LIMITED Subsidiary · St Helier, Jersey
      • AMETHYST I B.V. Subsidiary · Amsterdam, Netherlands
      • ATOP I, LLC Subsidiary · Wilmington, Delaware, United States
      • BANCO DE HONDURAS S.A. Subsidiary · Tegucigalpa, Honduras
      • BCA LOAN FUNDING LLC Subsidiary · Wilmington, Delaware, United States
      • BOWER 1 LLC Subsidiary · New York, New York, United States
      • CANADA SQUARE INVESTMENTS LIMITED Subsidiary · London, United Kingdom
      • Carver CDC-Subsidiary CDC 20 LLC Subsidiary · New York, New York, United States
      • CCBC HOLDINGS, INC. Subsidiary · Makati City, Philippines
        • 2 more
      • CCD MORTGAGE SECURITIES, INC. Subsidiary · Wilmington, Delaware, United States
      • CFNA Receivables (MD), Inc. Subsidiary · Baltimore, Maryland, United States
      • CFNA Receivables (PA), Inc. Subsidiary · Baltimore, Maryland, United States
      • CHIMES FUND 0762 L.P. Subsidiary · George Town, Cayman Islands
      • CITI (NOMINEES) LIMITED Subsidiary · Hong Kong, Hong Kong
      • CITI AFFORDABLE DEPOSITOR LLC Subsidiary · New York, New York, United States
      • CITI FUNDING BNG 20-IV LLC Subsidiary · New York, New York, United States
      • CITI FUNDING BR OBSIDIAN LLC Subsidiary · New York, New York, United States
      • CITI FUNDING BREIT DEBT INVESTMENTS LLC Subsidiary · New York, New York, United States
      • CITI FUNDING BRIGADE SCF-BOSTON PATRIOT LLC Subsidiary · New York, New York, United States
      • CITI FUNDING BSP10 RST LLC Subsidiary · New York, New York, United States
      • CITI FUNDING BSP4 RST LLC Subsidiary · New York, New York, United States
      • Citi Funding CIG 16-1 RST LLC Subsidiary · New York, New York, United States
      • and 250 more
    • Citibank (China) Subsidiary
    • Citibank Berhad Subsidiary · Kuala Lumpur, Malaysia
      • 2 more
    • Citibank Canada Subsidiary · Toronto, Ontario, Canada
      • 3 more
    • Citibank Europe Subsidiary · Dublin
      • 1 more
    • Citibank India Subsidiary · Mumbai
    • Citibank Türkiye Subsidiary
    • Citigroup Global Markets Japan Subsidiary · Tokyo
    • Citigroup Japan Holdings Subsidiary · 東京都, Japan
      • 2 more
    • Financial Group Banamex Subsidiary · Mexico City
    • Metalmark Capital Subsidiary · New York City
    • Ping An Insurance Stake · 3.07% · 深圳市, China
      • 6 more
    • CRRC Stake · 1.83% · 海淀区, China
    • 1 Citicorp Banking Corporation Subsidiary · Delaware, United States
    • 1 Citicorp LLC Subsidiary · Delaware, United States
    • 1 Citigroup Global Markets Holdings Inc. Subsidiary · New York, United States
    • 2 Citi GSCP Inc. Subsidiary · Delaware, United States
    • 2 Citigroup Financial Products Inc. Subsidiary · Delaware, United States
    • 2 Citigroup Japan Holdings G.K. Subsidiary · Japan
    • 3 Citibank (China) Co., Ltd. Subsidiary · China
    • 3 Citibank Kazakhstan JSC Subsidiary · Kazakhstan
    • 3 Citigroup Energy Inc. Subsidiary · Delaware, United States
    • and 106 more

Built from parent and subsidiary links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); subsidiaries listed in Exhibit 21 of annual reports filed with the SEC; subsidiaries, stakes and holdings from Wikidata (CC0). Each entity in the chart links to its source.

Investment adviser

Citigroup Alternative Investments LLC is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.

  • Assets it manages$127.4M6 13 accounts, all with discretion
  • Employees15 5 in investment advice or research
  • ClientsPooled investment vehicles (other than investment companies and: 7 ($123.3M); Other: PROPRIETARY ACCOUNTS: 6 ($4.1M)
  • How it is paidA percentage of assets under its management; Performance-based fees
  • What it doesPortfolio management for pooled investment vehicles (other than investment companies)
  • Holds client assetsYes: cash and securities
  • RegistrationSEC 801-60990, CRD 119537 IAPD record

Who owns it

Owners of 5% or more as the firm lists them (Schedule A), and the owners of those owners up the chain (Schedule B).

  • CITIGROUP INVESTMENTS INC.owns 75% or more, since 02/2002
  • CITIGROUP INC. (public company)owns 75% or more of CITIGROUP INVESTMENTS INC., since 10/1997

Disciplinary record

The firm answered yes to 5 of the disciplinary questions on Form ADV (Item 11). A yes can concern the firm itself or an affiliate.

  • The SEC or the CFTC has entered an order against the firm or an advisory affiliate in connection with investment-related activity.
  • The SEC or the CFTC has imposed a civil money penalty on the firm or an advisory affiliate, or ordered the firm or an advisory affiliate to cease and desist from any activity.
  • Any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has found the firm or an advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical.
  • Any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has found the firm or an advisory affiliate to have been involved in a violation of investment-related regulations or statutes.
  • In the past ten years, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has entered an order against the firm or an advisory affiliate in connection with an investment-related activity.

Each event as the firm describes it on its Disclosure Reporting Pages:

UNITED STATES DEPARTMENT OF JUSTICE, SEVERAL STATE ATTORNEYS GENERAL AND THE FDIC · Jul 11, 2014 · fine $4,500,000,000 · final about CITIGROUP INC.

Allegations: THE DOJ AND STATE AGS ALLEGED THAT CITI MISREPRESENTED THE QUALITY AND CHARACTERISTICS OF THE MORTGAGE LOANS IT SECURITIZED AND SOLD TO INVESTORS, INCLUDING THAT THE LOANS WERE ORIGINATED IN ACCORDANCE WITH UNDERWRITING GUIDELINES AND IN COMPLIANCE WITH FEDERAL, STATE AND LOCAL LAWS AND REGULATIONS. THE FDIC HAD ASSERTED, IN SEVERAL LITIGATIONS COMMENCED AGAINST CITIGROUP AS ISSUER AND UNDERWRITER OF RMBS, SIMILAR CLAIMS OF MISREPRESENTATIONS RELATING TO THE QUALITY OF THE LOAN COLLATERAL IN THE RMBS AT ISSUE.

Sanction: Civil and Administrative Penalt(ies) /Fine(s)

How it ended: Settled

Detail: UNDER THE TERMS OF THE SETTLEMENT, CITIGROUP WILL PAY A TOTAL OF $4.5 BILLION IN CASH AND PROVIDE $2.5 BILLION IN CONSUMER RELIEF. THE CASH PORTION OF THE SETTLEMENT CONSISTS OF A $4 BILLION CIVIL MONETARY PENALTY PAYMENT TO THE DOJ PURSUANT TO THE FINANCIAL INSTITUTIONS REFORM, RECOVERY AND ENFORCEMENT ACT OF 1989 ("FIRREA"), $208,250,000 TO THE FDIC AND $291,750,000 TO VARIOUS STATE AGS.

Summary: ON JULY 11, 2014, CITIGROUP ENTERED INTO A SETTLEMENT WITH THE UNITED STATES DEPARTMENT OF JUSTICE (THE "DOJ"), SEVERAL STATE ATTORNEYS GENERAL (THE "STATE AGS") AND THE FEDERAL DEPOSIT INSURANCE CORPORATION (THE "FDIC") RELATING TO RESIDENTIAL MORTGAGE- BACKED SECURITIES ("RMBS") AND COLLATERALIZED DEBT OBLIGATIONS ("CDOS") ISSUED, STRUCTURED OR UNDERWRITTEN BY CITI BETWEEN 2003 AND 2008. UNDER THE TERMS OF THE SETTLEMENT, CITIGROUP WILL PAY A TOTAL OF $4.5 BILLION IN CASH AND PROVIDE $2.5 BILLION IN CONSUMER RELIEF. THE CASH PORTION OF THE SETTLEMENT CONSISTS OF A $4 BILLION CIVIL MONETARY PENALTY PAYMENT TO THE DOJ PURSUANT TO THE FINANCIAL INSTITUTIONS REFORM, RECOVERY AND ENFORCEMENT ACT OF 1989 ("FIRREA"), $208,250,000 TO THE FDIC AND $291,750,000 TO VARIOUS STATE AGS. THE SETTLEMENT RELEASES CIVIL CLAIMS THAT COULD HAVE BEEN ASSERTED UNDER COMMON LAW, FIRREA, THE FALSE CLAIMS ACT, THE PROGRAM FRAUD CIVIL REMEDIES ACT, THE RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT, THE INJUNCTIONS AGAINST FRAUD ACT, AND VARIOUS STATE STATUTES, INCLUDING STATE SECURITIES LAWS.

U.S. BOARD OF GOVENORS OF THE FEDERAL RESERVE SYSTEM · May 20, 2015 · fine $342,000,000 · final about CITIGROUP INC.

Allegations: ON MAY 20, 2015, CITIGROUP INC. ("CITIGROUP") CONSENTED TO THE ISSUANCE OF AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY (THE "ORDER") BY THE U.S. BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FRB"). CITIGROUP AGREED TO PAY A PENALTY OF $342 MILLION AND TO FURTHER ENHANCE THE CONTROL FRAMEWORK GOVERNING CITIGROUP'S FOREIGN EXCHANGE ("FX") TRADING AND RELATED SALES ACTIVITIES AND CERTAIN OTHER COMMODITIES AND INTEREST RATE MARKET ACTIVITIES. THE ORDER ALLEGES THAT CITIGROUP LACKED ADEQUATE FIRM-WIDE GOVERNANCE, RISK MANAGEMENT, COMPLIANCE AND AUDIT POLICIES AND PROCEDURES RELATING TO ITS FX ACTIVITIES. THE ORDER FURTHER ALLEGES THAT CITIGROUP'S DEFICIENT POLICIES AND PROCEDURES PREVENTED IT FROM DETECTING AND ADDRESSING UNSAFE AND UNSOUND CONDUCT BY ITS FX TRADERS, INCLUDING AGREEMENTS WITH EXTERNAL TRADERS TO COORDINATE TRADING IN A MANNER DESIGNED TO INFLUENCE CERTAIN FX BENCHMARK FIXES AND MARKET PRICES AND TRADING STRATEGIES THAT RAISED POTENTIAL CONFLICTS OF INTEREST.

Sanction: Civil and Administrative Penalt(ies) /Fine(s)

How it ended: Consent

Detail: CIVIL MONEY PENALTY OF $342 MILLION LEVIED AGAINST CONTROL AFFILIATE (CITIGROUP INC.). NO LEVY AGAINST APPLICANT. PENALTY PAID BY CONTROL AFFILIATE ON MAY 20, 2015.

Summary: ON MAY 20, 2015, CITIGROUP CONSENTED TO THE ISSUANCE OF AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY BY THE FRB. THE ORDER REQUIRES CITIGROUP TO PAY A CIVIL MONEY PENALTY OF $342 MILLION AND TO TAKE SPECIFIC STEPS TO IMPROVE ITS OVERSIGHT, INTERNAL CONTROLS, COMPLIANCE, RISK MANAGEMENT AND AUDIT PROGRAMS, INCLUDING TO SUBMIT WITHIN 90 DAYS OF THE ORDER, WRITTEN PLANS AND PROGRAMS RELATING TO REMEDIATION.

Resolved: May 20, 2015

UNITED STATES SECURITIES AND EXCHANGE COMMISSION · Aug 17, 2015 · final

Allegations: ALLEGED VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT AGAINST CITIGROUP GLOBAL MARKETS INC. (CGMI) AND CITIGROUP ALTERNATIVE INVESTMENTS LLC (CAI), SECTION 206(2) AGAINST CGMI, AND SECTIONS 206(4) OF THE ADVISERS ACT, RULE 206(4)-7 PROMULGATED THEREUNDER, AND RULE 206(4)-8 PROMULGATED THEREUNDER AGAINST CAI IN THAT THE FIRMS' FINANCIAL ADVISERS AND THE FUND MANAGER MISREPRESENTED TWO ALTERNATIVE INVESTMENT PRODUCTS' RISKS AND PERFORMANCE TO CLIENTS FROM 2002 THROUGH 2008.

Sanction: Censure

How it ended: Order

Detail: CEASE AND DESIST, CENSURE, DISGORGEMENT OF $139,950,239 AND PREJUDGMENT INTEREST OF $39,612,089

Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRMS CONSENTED TO AN ORDER TO CEASE AND DESIST, A CENSURE, DISGORGEMENT OF $139,950,239 AND PREJUDGMENT INTEREST OF $39,612,089.

Resolved: Aug 17, 2015

BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSYEM · Oct 7, 2020 · final about CITIGROUP, INC.

Allegations: THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FED") IDENTIFIED SIGNIFICANT ONGOING DEFICIENCIES IN IMPLEMENTATION AND EXECUTION BY CITIGROUP WITH RESPECT TO VARIOUS AREAS OF RISK MANAGEMENT AND INTERNAL CONTROLS, INCLUDING FOR DATA QUALITY MANAGEMENT AND REGULATORY REPORTING, COMPLIANCE RISK MANAGEMENT, CAPITAL PLANNING, AND LIQUIDITY RISK MANAGEMENT.

Sanction: Cease and Desist

How it ended: Order

Detail: CITIGROUP AGREED TO CEASE AND DESIST AND AGREE TO CERTAIN AFFIRMATIVE ACTIONS/UNDERTAKINGS

Summary: CITIGROUP AGREED TO TAKE CERTAIN AFFIRMATIVE ACTIONS/UNDERTAKINGS RELATED TO SOURCE OF STRENGTH, BOARD OVERSIGHT, RISK MANAGEMENT AND INTERNAL CONTROLS, DATA QUALITY MANAGEMENT, COMPLIANCE RISK MANAGEMENT, PROGRESS REPORTS, APPROVAL AND IMPLEMENTATION AND DESIGNATION OF PRIMARY CONTACT. No Information Filed

Resolved: Oct 7, 2020

In its own words: the client brochure

Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/31/2026.7 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.

Item 4: Advisory business Services

Citigroup Alternative Investments LLC (“CAI LLC”) is a wholly-owned subsidiary of Citigroup Investments Inc., which is a wholly-owned subsidiary of Citigroup Inc. (“Citigroup”). Citigroup is a publicly held company. CAI LLC commenced operation in March of 2002. CAI LLC’s investment advisory business is also carried out by certain affiliated “relying on advisors,” including Citigroup Private Equity LP, Citigroup Private Equity (Offshore) LLC, and Citi Private Equity (CVCI GP) LLC (taken collectively with CAI LLC, “CAI”). CAI provides advisory services to private investment companies such as private equity funds and funds of one or more private equity and real estate funds (referred to herein collectively as “Funds” and each individually as a “Fund”). The Funds CAI advises include private funds and employee securities companies. Following the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection of 2010 and other laws and regulations as a result of the 2008 financial crisis, CAI has substantially modified its business, including through the divestiture of a significant portion of its business units, management contracts and employees. CAI does not intend to organize or offer any new investment products or to acquire any new advisory clients. CAI continues to provide investment advisory services for the types of products listed below. All of the investment products advised by CAI are currently past the active investment stage, in which new investment opportunities are sought and made, although certain funds have the capacity to make follow-on investments in existing assets. CAI has also engaged sub-advisers to assist with the management of several of its advised funds following the divestitures described above. Private Equity Fund Products: CAI has organized and advises limited partnerships, limited liability companies and other investment vehicles that have acquired non-publicly traded securities that they hold for an extended period (“Private Equity Investment Funds”). The securities in which Private Equity Investment Funds invest often have been acquired in management buyouts, or in connection with company growth or restructurings. These securities are in the form of common equity, preferred equity, convertible debt, debt, or other instruments. The capital provided by the investments has been used in the early or intermediate stages of an enterprise or has funded the expansion of an established business. CAI also advises investment partnerships where substantially all of the assets of which are invested in one designated underlying Private Equity Investment Fund and, in one case, an underlying infrastructure fund, in each case sponsored and managed by a third party (each, a “Private Equity Feeder Fund). CAI’s role with respect to Private Equity Feeder Funds is essentially administrative, rather than investment advisory in nature, as CAI is responsible primarily for effecting the Private Equity Feeder Fund’s investment in the designated underlying investment fund, in accordance with the Private Equity Feeder Fund’s governing documents. Real Estate Products:

In the real estate investing area, CAI organized and advises private investment companies (each, a “Fund of Real Estate Funds”) that invested in various underlying real estate limited partnerships, limited liability companies and other investment vehicles that invested, directly or indirectly, in real estate and real estate-related investments, broadly defined (such underlying vehicles, “Real Estate Funds”) that CAI selected but which are sponsored and managed by third parties. Particular Investment Restrictions Individual investors in a Fund are not consulted in the design or implementation of the Fund’s investment program. Each Fund’s governing documentation will describe that Fund’s investment program. Definitions The term “Feeder Fund” means a Private Equity Feeder Fund. The term “Fund of Funds” means a Fund of Real Estate Funds. The term “Underlying Fund” means an investment fund that is sponsored and managed by a third party in which a Feeder Fund or Fund of Funds has invested. Assets Under Management As of December 31, 2025, CAI managed approximately $127,429,182of discretionary assets and $0 of non-discretionary assets.

Item 5: Fees and compensation Fees

Fees Charged: Private Equity Fund Products Each Private Equity Investment Fund and Private Equity Feeder Fund will generally pay CAI a management fee quarterly in arrears, at an annual rate based on the aggregate capital commitments of the Fund’s investors during a defined investment period; thereafter, on invested capital. In addition to the management fee, a Private Equity Investment Fund pays CAI an incentive allocation based on the return of the Fund and/or its investments, often only after exceeding a hurdle rate of return to the Fund’s investors. The amount of the management fee and incentive allocation for a particular Fund will be set forth in the offering materials for that Fund. Investors pay fees directly to the relevant Fund. Certain funds in their late stages no longer charge management fees. Certain funds are charged an annual administration fee instead of a management fee. Fees Charged: Real Estate Products Each Fund of Real Estate Funds pays CAI a management fee quarterly in arrears, at an annual rate generally based on the aggregate capital commitments of the Fund’s investors during a defined investment period; thereafter, on invested capital or the net asset value. In addition to the management fee, a Fund of Real Estate Funds pays CAI an incentive allocation and/or incentive fee based on the return of the Fund and its investments. The amount of the management fee, incentive allocation and/or incentive fee for a particular Fund will be set forth in its offering materials.

Multiple Layers of Fees and Expenses Investors in a Fund of Funds or in a Feeder Fund will in effect pay two sets of fees and expenses. For a Fund of Funds, investors will generally pay management fees to CAI and vehicle expenses at the Fund level and will also indirectly pay management fees to the sponsor of the Underlying Fund and vehicle expenses at the Underlying Fund level. In certain Funds, management fees are paid to sub-advisors and origination channels. As a result, investors pay more in fees by investing in a Fund of Funds than they would by investing directly in the underlying Real Estate Funds. However, because of high minimum investment levels and other reasons, investors in a Fund of Funds generally would not have the opportunity to invest directly in the Underlying Funds. In addition, by investing in a Fund of Funds, investors receive the benefit of diversification through professional management of a portfolio consisting of multiple Underlying Funds. Investors in Feeders also pay multiple sets of fees and expenses: one directly at the Feeder level and one (indirectly) at the Underlying Fund level. As a result of the payment of multiple levels of fees and expenses, investors pay more fees by investing in a Feeder than they would by investing directly in the Underlying Fund. Because of high minimum investment levels and other reasons, however, investors in Feeders generally would not have the opportunity to invest directly in the relevant Underlying Fund. Method of Payment of Fees Funds will pay any management and incentive fees at such times and in such manner specified in their respective offering materials and other governing documentation. Such fees will typically be paid from the Fund and deducted from an investor’s net asset value per share or capital account, as applicable. Additional Compensation Received by Affiliates Affiliates of CAI have typically received placement fees for placing interests in Funds from the Funds and/or from CAI as a Fund’s manager. Where the Funds placed were Feeder Funds, these affiliates and/or CAI also typically received compensation from the manager of the Underlying Fund. CAI also receives fees from certain Funds for the provision of administrative services, the responsibility for all or a portion of which may be subcontracted to affiliates of CAI or to unaffiliated third parties. Affiliates of CAI also may have direct relationships with, and provide certain other services to, a Fund or a Fund’s portfolio companies for which the affiliate receives compensation. Additional Fees and Expenses As described in more detail in the relevant offering documentation, each Fund typically bears its organizational and offering expenses and its operating and other expenses, which may include, but not be limited to, direct investment-related expenses (e.g. custodial fees, interest expense, consulting and other professional fees relating to particular investments), reporting and legal expenses, accounting, audit and tax preparation expenses, remuneration to directors or managing

members, as applicable, insurance, administrator fees, liability insurance premiums, any extraordinary expenses and other similar expenses related to the Fund. Compensation of CAI Personnel CAI’s personnel and supervised persons do not receive commissions tied directly to the sale of any securities or other investment products advised by CAI in the form of asset-based sales charges or services fees. However, historically certain CAI personnel were registered as broker-dealer representatives of Citigroup Global Markets Inc. and as such marketed CAI’s Funds to institutional investors in the past, as further described in Item 10 “Other Financial Industry Activities and Affiliations.” Affiliates of CAI that served as placement agents, referral agents or distributors for CAI products and third-party marketers received compensation for those activities. Payment of Fees in Advance and Arrears Generally, fees payable to CAI are paid in arrears or less than six months in advance.

Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks

As used in this Item 8, “Investment Managers” and “CAI” include CAI and its relying advisors unless the context indicates otherwise. “Underlying Fund Manager” means the third-party investment manager or investment adviser to an Underlying Fund. Unless the context indicates otherwise, all references to “Funds” in this Item 8 should be read to include “Underlying Funds.” Private Equity Fund Products: Investment Process and Method of Analysis: CAI’s Private Equity Investment Funds are all currently past the active investment stage, in which new investment opportunities are sought and made, although certain Funds have the capacity to make follow-on investments in existing portfolio companies. With respect to each Private Equity Investment Fund sponsored by CAI, the investment team generally employed fundamental research, specific industry knowledge, proprietary relationships, and partnerships with management teams to identify attractive investment opportunities, often targeting industries that are undergoing change or are otherwise out-of-favor. The teams applied experience and proprietary relationships in seeking to create a sustainable advantage throughout the investment process. After preliminary screening, relevant investment professionals applied their industry experience to perform in-depth due diligence with management to achieve a comprehensive understanding of a prospective portfolio company’s competitive position, identify the opportunities and risks associated with a prospective investment, and develop an investment thesis. This analytic process included constructing alternative business and financial scenarios that test the capital structure of and potential equity returns from a proposed investment. For its Feeder Funds and Funds of Private Equity Funds to select underlying Private Equity Investment Funds and monitor their performance, CAI generally considered (1) investment strategy and targeted sectors; (2) personnel and the underlying fund’s investment team; (3) track record and transactions done by the investment team; and (4) terms and fit with investor objectives. Within each of these broad areas, CAI used an extensive list of issues, questions and metrics that are designed to assist it in deciding whether to invest in a particular fund. Interviews with other investors and lenders and verification from independent professionals may also be undertaken. Strategy Risks: Nature of Investment. An investment in a Private Equity Investment Fund and Feeder Fund requires a long-term commitment with no certainty of any return and should be undertaken only by investors capable of evaluating and bearing a high level of risk and lack of liquidity. Private equity and infrastructure investments are generally highly illiquid, and there can be no assurance

that a Fund will be able to realize its investments in a timely manner. Dispositions of investments may require a lengthy time period, and an inability to find or consummate a sale may result in distributions in kind of illiquid securities to the investors. Additionally, private equity funds typically invest in securities that cannot be sold except pursuant to a registration statement filed under the Securities Act of 1933 (“Securities Act”) or in a private placement or other transaction exempt from registration under the Securities Act and that complies with any applicable non-U.S. securities laws. The securities in which a Fund invests may be the most junior in what typically will be a complex capital structure, and thus subject to the greatest risk of loss. Certain of a Fund’s investments may be in businesses with little or no operating history. A Fund may also have investments in businesses with high levels of debt or in leveraged buyouts; leveraged buyouts by their nature require companies to undertake a high ratio of fixed charges to available income. Leveraged investments are inherently more sensitive to declines in revenues and to increases in expenses. Since a Fund may make only one investment (where a fund is a Feeder Fund or other single-investment vehicle) or only a limited number of investments, and since a Fund’s investments generally will involve a high degree of risk, poor performance by only one or two investments could severely affect the total returns to the investors. Risks Upon Disposition of Investments. In connection with the disposition of an investment in a portfolio company, a Fund may be required to make representations about the business and financial affairs of the portfolio company typical of those made in connection with the sale of any business or may be responsible for the contents of disclosure documents under applicable securities laws. The Fund may also be required to indemnify the purchasers of such investment or underwriters to the extent that any such representations or disclosure documents turn out to be incorrect, inaccurate, or misleading. These arrangements may result in contingent liabilities, which might ultimately have to be funded by the investors. Fund partnership or other governing agreements contain provisions to the effect that if there is any such claim during or after the term of the applicable partnership in respect of a portfolio company, it will be funded by the applicable partners to the extent that they have received distributions from the Fund, subject to certain limitations. In addition, a Fund’s investments will typically be in privately purchased illiquid securities, which are normally subject to restrictions on resale. In some cases, the Fund may be prohibited from selling such securities for a period of time or otherwise be restricted from disposing of such securities. Furthermore, the types of investments made may require a substantial length of time to liquidate. As a result, there is a significant risk that a Fund may be unable to realize its investment objectives by sale or other disposition at attractive prices or will otherwise be unable to complete any exit strategy, of its investments. Investment in Restructurings; Insolvency of Portfolio Companies. A Fund may have made investments in restructurings that involve portfolio companies that are experiencing or are expected to experience severe financial difficulties, which may never be overcome. Such investments could, in certain circumstances, subject the Fund to certain additional potential liabilities, which may exceed the value of the Fund’s original investments therein. For example, under certain circumstances, a lender who has inappropriately exercised control of the management and policies of a debtor may have its claims subordinated, or disallowed, or may be found liable for damage suffered by parties as a result of such actions. In addition, under circumstances involving a portfolio company’s insolvency, payments to a Fund and distributions

by such Fund to the investors may be reclaimed if any such payment or distribution is later determined to have been a fraudulent conveyance or a preferential payment. Investments in restructurings involving non-U.S. portfolio companies may be subject to various laws enacted in the countries of their issuance for the protection of creditors. These considerations will differ depending on the country in which each portfolio company is located or domiciled. Need for Follow-On Investments. Following the initial investment in a portfolio company, the Fund may be called upon to provide additional funds or have the opportunity to increase its investment in such portfolio company. There is no assurance that the Fund will make follow-on investments or that the Fund will have sufficient funds to make such an investment at that time. The Fund’s decision not to make a follow-on investment or its inability to do so may have a substantial negative impact on the portfolio company and, therefore, the return from such investment. Please also refer to “General Risks” below. Real Estate Funds: Investment Process and Method of Analysis: CAI’s Real Estate Funds are all currently past the active investment stage, in which new investment opportunities are sought and made, although certain Funds have the capacity to make follow-on investments in existing assets. CAI generally selected Underlying Funds for the Fund of Real Estate Funds based on performance track record, organizational ability to execute the investment strategy, and financial capacity to meet obligations, among other factors. CAI used information obtained from various outside research firms, coupled with internal economic and real estate market analysis, to ascertain which geographic markets and what property types offer attractive investment opportunities. Strategy Risks: Investment in Real Estate Funds. Because real estate, like many other types of long-term investments, historically has experienced significant fluctuation and cycles in value, specific market conditions may result in occasional or permanent reductions in the value of the investments made by Underlying Funds that are real estate funds. The marketability and value of real estate investments made by the Underlying Funds will depend on many factors beyond the control of the funds or their investment managers, including, without limitation: changes in general economic or local conditions and/or specific industry segments; declines in rental or occupancy rates; competition from other developments; changes in supply of or demand for competing properties in an area (as a result, for instance, of over-building); geographic or market concentration; the ability of the Underlying Funds or property managers to manage the real properties; changes in interest rates; the promulgation and enforcement of governmental regulations relating to land use and zoning restrictions, environmental protection and occupational safety; unavailability of mortgage funds which may render the sale or refinancing of a property difficult; location of the

properties; the financial condition of borrowers and of tenants, buyers and sellers of property; changes in real estate tax rates and other operating expenses; the imposition of rent controls; energy and supply shortages; various uninsured or uninsurable risks; and natural disasters. These factors may have an adverse impact on the performance of the Underlying Funds in which a Fund of Real Estate Funds invests, and there can be no assurance that such Underlying Funds will effectively manage these risks. Please also refer to “General Risks” below. General Risks Alternative investments entail a high degree of risk. Investors should consider the following risk factors and conflicts of interest detailed in this Item 8 and other product-specific information provided by the product or CAI in evaluating the merits and suitability of any Fund products. The following does not purport to be a comprehensive summary of all the risks and conflicts of interest associated with the Funds. Investing in Funds involves a risk of total loss that clients must be prepared to bear. Investment in General Any investor must be able to bear the risks involved and must meet the suitability requirements of the relevant Fund. Some or all alternative investment strategies employed by the Funds may not be suitable for certain investors. No assurance can be given that any Fund’s investment objectives will be achieved. Investments in private equity funds, real estate funds and other types of private investment funds are typically speculative and involve a substantial degree of risk. Past results of the Funds or any other private investment funds managed by an investment manager are not necessarily indicative of future performance of any Fund and the performance of any Fund may fluctuate. Investment results may vary substantially on a quarterly or annual basis. The establishment and use of a Fund do not constitute a complete investment program. Each investor must realize that it could lose all or a substantial amount of its investment in a Fund. CAI expects that certain Funds may underperform or experience financial difficulties, which difficulties may never be overcome. CAI’s Funds are generally highly illiquid and do not permit redemptions. Investment Managers or Underlying Fund Managers may have implemented highly speculative investment techniques, including high leverage, highly concentrated portfolios, workouts and startups, control positions and illiquid investments. Neither CAI nor any investor will have the ability to direct or influence the management of an Underlying Fund Manager’s investments. As a result, the returns of any Fund that allocates to an Underlying Fund will depend primarily on the performance of such Underlying Fund Manager and could suffer substantial adverse effects by the unfavorable performance of such Underlying Fund Manager. No assurance can be given that a Fund will achieve its goals or investment objectives. If a Fund receives distributions in kind from an Underlying Fund, it may incur additional costs and risks to dispose of such assets.

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Item 7: Types of clients

CAI provides investment advice only to Funds. However, the ultimate investors in Funds advised by CAI are institutional investors, funds of funds, and high net worth individuals Private Equity Fund Products: Ultimate investors in each Private Equity Investment Fund and Private Equity Feeder Fund generally were required to make a minimum capital commitment ranging from $25,000 to $3,000,000. The minimum for any specific Fund was set forth in the offering materials for that Fund.

Real Estate Products: Ultimate investors in each Fund generally were required to make a minimum capital commitment ranging from $250,000 to $5 million, depending on the terms of the specific Fund. In its discretion, CAI retained the right to accept a lower capital commitment from an investor.

Item 6: Performance-based fees and side-by-side management Conflicts of interest

CAI and its affiliates receive performance-based fees from certain of our Funds. Most funds are also charged fixed fees, such as management fees, which may include asset-based fees in certain cases. The performance-based fees may have created an incentive for CAI to cause the relevant Fund to make investments that are riskier or more speculative than would have been the case if CAI did not receive a performance-based fee, or to have directed investments in favor of a Fund that pays a performance-based fee. None of the Funds advised by CAI is making investments in new portfolio companies or Underlying Funds, as applicable. For certain Funds, some, or all these performance-based and/or fixed fees are payable to third-party sub-advisers or other service providers to the Funds. Please refer to Item 11 “Code of Ethics, Participation in Client Transactions and Personal Trading” and Item 12 “Brokerage Practices” for a discussion of CAI’s conflict management procedures, incentive compensation arrangements, managerial review and oversight and allocation policy, all of which are intended to mitigate conflicts.

Item 10: Other financial industry activities and affiliations Conflicts of interest

CAI shares resources, other employees, and management, as well as investment ideas and opportunities, with any or all affiliates engaged in similar activities. Certain employees of CAI are registered as broker-dealer representatives of Citigroup Global Markets Inc. Citigroup Global Markets Inc., Citibank, N.A. and other affiliates have acted as placement agents for securities issued by vehicles managed or sponsored by CAI. Citigroup affiliates have also provided administrative services to Funds. Material Relationships or Arrangements with Certain Related Persons. Broker-Dealer Citigroup Global Markets Inc., a registered broker-dealer (“CGMI”), served as the distributor of Private Equity Products and Real Estate Products. Other Citigroup affiliated entities have also served as distributors or referral agents for these CAI-advised funds. Such affiliated distributors charged placement or other fees to clients as provided in the relevant account documentation. In addition, they may share in the fees paid to CAI. See Item 5 “Fees and Compensation”. CAI may, in certain limited circumstances, select CGMI as a broker-dealer in respect of the Funds. See Item 12 “Brokerage Practices”. Banking Institutions As described above, certain Citigroup affiliates have served as distributors or referral agents for CAI-advised funds and accounts.

Certain Funds retain Citibank, N.A. to provide certain cash account or other custodial services. Citigroup affiliates provide administrative services to Funds.

Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest

Trading

Code of Ethics, Participation or Interest in Client Transactions and Personal

Code of Ethics CAI has adopted a Code of Ethics that memorializes CAI’s fundamental duties as a fiduciary. The Code of Ethics includes standards of business conduct and incorporates a personal investments policy. Each employee receives a copy of the Code of Ethics upon hiring and annually thereafter and must sign an attestation that such employee has read and understood such Code of Ethics. CAI’s Code of Ethics requires each employee to prioritize the interests of the client, to avoid conflicts of interest, to never abuse such employee’s position of trust and responsibility and to comply with all federal securities laws. Employees are required to safeguard material non-public information in such employee’s possession and are prohibited from using such information to such employee’s personal benefit. Each employee must treat information belonging to clients as confidential and take care to protect such information from unauthorized access by third parties. To avoid any potential conflict of interest involving personal transactions, CAI requires each employee to notify the Compliance department upon opening a personal account, to pre-clear personal transactions and disclose all potential conflicts of interest with regard to such a personal transaction before engaging in the transaction. Employees are also subject to a restricted list and blackout periods. In addition, access persons (defined as employees with access to non-public information regarding CAI’s purchase or sale of securities and directors, officers and partners) will (i) upon starting employment, provide a complete record of his or her securities holdings to the Compliance Officer, or delegated Compliance Department, and (ii) provide quarterly reports of personal securities transactions within 30 days following the end of the quarter, unless such information has been provided through other means. All employees are required to inform the Compliance Officer of any violation of the Code of Ethics that comes to his or her notice. A copy of CAI’s Code of Ethics has been provided to any client or prospective client upon request. Trading Practices Participation and Interest in Client Transactions. CAI has implemented policies and procedures that address affiliated transactions. Therefore, from time to time, CAI or its affiliates may affect a securities transaction between one or more Funds. In such case, one Fund will purchase securities held by another Fund. CAI effects these transactions only (i) when it deems the transaction to be in the best interests of both client accounts and (ii) at a price that CAI has determined by reference to independent market indicators, which CAI believes to constitute “best execution” for both accounts. Neither CAI nor its affiliates will receive any compensation, directly or indirectly, for arranging such a transaction. To the extent that CAI or its affiliates engage in principal agency, agency cross transactions or cross trades, such transactions will be consummated in accordance with Section 206(3) of the Advisers Act and, as applicable, Rule 206(3)-2 promulgated thereunder.

Interest in Client Transactions CAI may recommend securities in which it and/or its affiliates directly or indirectly have a financial interest. CAI affiliates also may buy and sell securities that CAI recommends to advisory clients for purchase and sale. CAI may give advice and act in the performance of its duties to clients which differs from the advice given, or the timing and nature of action taken, with respect to the accounts of its affiliates and/or the accounts of other clients. In certain instances, affiliates of CAI have acquired investments in an issuer on a side-by-side basis with an investment vehicle managed by CAI. Such investments may provide the vehicle with access to investments that it could not otherwise have obtained. However, this practice gives rise to potential conflicts of interest. Temporary investments in which an account’s assets may be invested include instruments issued, or funds managed by, an affiliate of CAI, in which case such affiliate will receive fees or other compensation in connection with such investment. Such fees will be in addition to the advisory fees and other compensation paid to CAI. Inside Information CAI has adopted procedures to guard against insider trading. In the event that CAI obtains material, non-public information about an issuer, it may be prohibited from trading the issuer’s securities until the information becomes public or is no longer material. CAI’s investment flexibility may be constrained as a consequence of CAI’s inability to use such information for investment purposes. Other Conflicts of Interest As an indirect subsidiary of Citigroup, CAI is a member of a large corporate conglomerate consisting of many affiliated entities. In addition, Citigroup has existing and potential relationships with a significant number of institutions and individuals. Affiliates of CAI engage in a broad spectrum of activities, including financial advisory activities, merchant banking, lending, arranging securitizations and other financings, sponsoring, and managing private investment funds, engaging in broker-dealer activities, and other activities, and they have extensive investment activities that are independent from, and may from time-to-time present potential conflicts of interest with, CAI’s clients. Many of these potential conflicts of interest arise in connection with the investment banking activities and other investment management activities of CAI affiliates. For example, Citigroup affiliates often represent potential purchasers and sellers in portfolio company divestitures or may pursue investments on a proprietary basis on their own behalf. In these cases, these relationships or proprietary investment activities may result in a Fund not being permitted to pursue certain investment opportunities. Accordingly, no assurances can be given that all potentially suitable investment opportunities will be offered to any given Fund. In addition, Citigroup could provide investment banking services to competitors of portfolio investments of Funds, in which case Citigroup and its affiliates will take appropriate steps to safeguard the confidential information of each client. CAI has taken certain steps to ameliorate these potential conflicts of interest. CAI is organizationally and legally separate from and reports through different channels from the investment banking businesses of Citigroup. CAI’s compensation, including that of its employees,

is independent of the activities of its affiliates, although CAI has an inherent interest in the value of the Citigroup conglomerate. Information barriers have been erected that are designed to prevent the flow of non-public information between Citigroup’s investment management activities, which include CAI, on the one hand, and its investment banking and direct investment activities, which include Citigroup Global Markets Inc., on the other hand. CAI affiliates may engage in transactions with, and provide services to, portfolio companies of CAI clients. A Fund may pay investment banking fees to a CAI affiliate for providing services in connection with: (i) the acquisition, disposition, or sale of companies in which the Fund invests; (ii) equity or debt financings; or (iii) other investment banking services. An affiliate may be engaged to act as financial adviser to a company in connection with the sale of such company, or subsidiaries or divisions thereof. The compensation provided to a CAI affiliate for such activities typically will be based upon realized consideration and will likely be contingent, in substantial part, upon closing. CAI affiliates may be precluded from offering such company to any affiliated Fund or other CAI client if the seller has required the CAI affiliate to act exclusively on its behalf. Additionally, there may be seller assignments in which the seller permits the Fund or other CAI client to act as a buyer. If an affiliated Fund or other CAI client were to be that buyer, certain conflicts of interest would be inherent in the situation, including those involved in negotiation of a purchase price. CAI affiliates may be engaged to act as financial adviser to financially troubled companies in connection with the restructuring of their capital structures or in connection with their bankruptcy. The compensation provided to a CAI affiliate for such activities generally is based upon the successful completion of a restructuring, which may include raising funds for the purchase of existing securities or for an equity infusion. If an affiliated Fund or other CAI client is an investor in such a company, certain conflicts of interest would be inherent in the situation, including those involved in negotiation of a purchase price. CAI affiliates, such as Citigroup Global Markets Inc., may provide advisory and other services to parties entering into transactions with entities advised by CAI. In such instances, steps will be taken to ensure that the investment decision-making process on behalf of the CAI-advised entity is insulated from any investment banking considerations. CAI may engage in transactions on behalf of its Funds (or their subsidiaries) with, or seek services for such Funds from, affiliates or other related parties or former related parties. For example, certain affiliates of CAI or other related parties may, subject to Bank Holding Company Act and other regulatory restrictions, provide services to its funds or their subsidiaries, including debt and equity financing services, raising of equity capital for a Fund’s portfolio companies, development or redevelopment services, development oversight or construction management services, interest rate hedging, foreign exchange services or hedging, brokerage services or investment banking services (including in connection with asset sales). In most instances, the Fund’s governing documents will provide that CAI or its affiliates may be retained to provide (and be compensated for providing) services to a fund, such as those described in the preceding sentences or that are ancillary to the fund’s investment or financing activities or are customarily provided by a service provider in connection with the acquisition, disposition, leasing, financing or management of

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Item 12: Brokerage practices Conflicts of interest

Brokerage Practices Brokerage Discretion CAI generally is not limited in its authority to select broker-dealers for trade execution, to the extent applicable. CAI generally considers it appropriate (unless there are relevant factors such as customer direction or legal requirements or policy decisions to the contrary) to use the execution services of affiliated broker-dealers for the purchase and sale of such securities for investment advisory clients. CAI’s affiliates will receive compensation in connection therewith. As discussed below in connection with unaffiliated broker-dealers, in light of all of the factors bearing upon the execution services provided by CAI’s affiliated broker-dealers, the commissions charged may exceed those that other broker-dealers may charge. Any such transactions will be executed by CAI’s affiliated broker-dealers only to the extent permitted by, and in compliance with, applicable law and regulations, including Section 11(a) of the Securities Exchange Act of 1934. Clients may direct CAI not to execute securities transactions through its affiliated broker-dealers. CAI also may accept instructions from a client to direct specific amounts of brokerage to particular broker-dealers in connection with services rendered by those broker-dealers directly to the client. In either case, the client may pay higher commissions than if CAI selected the broker-dealer and negotiated the commission rates. In selecting an unaffiliated broker-dealer for trade execution, CAI uses its best judgment to select a broker-dealer that provides prompt and reliable execution at favorable securities prices and reasonable commission rates. Ordinarily, the best net price, giving effect to brokerage commissions and other costs, is the determining factor, but a number of other factors also may enter into the decision. These factors may include: the nature of the security being traded; the size and complexity of the transaction; the desired timing of the transaction; the existing and expected activity in the market for particular securities; confidentiality; and the execution, clearance, and settlement capabilities and financial condition and other relevant and appropriate services of the broker-dealer. Research and Other Soft Dollar Arrangements

CAI does not utilize client’s agency commission dollars to purchase research and other services (i.e., soft dollars).

Item 14: Client referrals and other compensation Conflicts of interest

Client Referrals and Other Compensation CAI does not receive any economic benefits from non-clients for providing investment advice or other advisory services to clients. CAI historically entered into agreements with its employees, and/or third parties to solicit clients for CAI’s investment advisory services. Under such agreements, persons could refer or solicit clients and receive compensation for such services. The structure of any such agreement with a third party, including the compensation payable to the solicitor, has been disclosed fully to the client as required by applicable law. Different solicitors, including affiliates, received varying amounts of compensation for their services. CAI also may have entered into agreements to refer clients to its affiliates. Under such arrangements, CAI would have received compensation for such referrals.

Item 9: Disciplinary information

Below are summaries of certain legal and disciplinary events that maybe material to clients and prospective clients. Additional information about legal and disciplinary events involving us and our management persons is available in Item 11 of Part 1A on Form ADV at www.adviserinfo.sec.gov. Citigroup, CAI LLC, and related parties were named as defendants in a putative class action lawsuit filed in October 2012 on behalf of investors in CSO Ltd., CSO US Ltd., and Corporate Special Opportunities Ltd., whose investments were managed by a subsidiary of CAI LLC. Plaintiffs asserted a variety of state common law claims, alleging that they and other investors were misled into investing in the funds and later, not redeeming their investments. The complaint

sought to recover more than $400 million on behalf of a putative class of investors. On August 10, 2015, the parties entered into an agreement providing for a class action settlement of the litigation in the amount of $13.5 million. The court held a final settlement hearing on December 17, 2015, and entered an order approving settlement on January 28, 2016. Additional information concerning this action is publicly available in court filings under the docket number 12-cv-7717 (S.D.N.Y.) (Castel, J.). On August 17, 2015, Citigroup Alternative Investment LLC (“CAI LLC”) and an affiliate entered into a settlement with the SEC that resolves all claims relating to the investigation by the Securities and Exchange Commission (“SEC”) into the marketing and management of the Falcon and ASTA/MAT funds, alternative investment products that were managed and sold by CAI LLC and certain of its affiliates between 2002 and 2007. The SEC alleged violations of Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933 and Sections 206(2) and (4) of the Investment Advisers Act of 1940, and Rules 206(4)-7 and 206(4)-8 promulgated thereunder, in that the firms allegedly misrepresented to clients the risks and performance of these two alternative investments products from 2002 through 2008. Without admitting or denying the findings, the firms consented to an order to cease and desist, a censure, disgorgement of $139,950,239 and prejudgment interest of $39,612,089.

Item 13: Review of accounts

Review of Accounts Review of Accounts Private Equity Products: Private Equity Investment Funds typically hold annual meetings with investors to review and discuss the funds’ investment activities and portfolio. Valuation committee meetings are held quarterly to review the valuation of underlying investments. Real Estate Products: Management of CAI’s real estate business has been transferred to a thirdparty. However, the anticipated occurrence of certain significant matters triggers a review by CAI before such matter is consummated. Client Reports Private Equity Fund Products: CAI provides each Fund’s general partner or managing member with periodic reports concerning the Fund’s investments. While the Funds’ underlying investors are not advisory clients of CAI and will not receive periodic reports from CAI as advisory clients, such investors will be provided by the Funds with annual audited financial statements of the applicable fund and periodic investor reports. In connection with certain Funds, CAI has engaged a third party to serve as sub-advisor to CAI. The sub-advisor generally works with CAI and certain CAI affiliates to prepare and deliver quarterly investor reports. Real Estate Funds: As part of the transfer of the management of CAI’s former real estate business, CAI has engaged a third-party to serve as a sub-advisor to CAI. The sub-advisor works with certain CAI affiliates to prepare and deliver quarterly investor reports.

Item 15: Custody

Custody CAI does not provide custodial services to its clients. Client assets are held with banks, registered broker-dealers, or other qualified custodians.

CAI will cause its Funds and any related special purposes vehicles to maintain their funds and securities with a qualified custodian, which includes a U.S. bank, an SEC-registered broker-dealer, a CFTC-registered futures commission merchant, and a foreign financial institution that segregates client assets. Certain affiliates of CAI serve as a qualified custodian for client assets. In addition, each Fund or special purpose vehicle is required to be audited at least annually and to provide audited financial statements to its investors within 120 days after the end of its fiscal year, or 180 days in the case of funds of funds. (Otherwise, the relevant fund custodian will send each such fund investor a quarterly account statement showing such fund’s quarter-end positions and NAV, and the fund’s aggregate account transactions during the quarter. In addition, a surprise examination of the relevant fund will be conducted by a qualified independent accountant.)

Item 16: Investment discretion

Investment Discretion CAI has the authority to determine, without obtaining specific client consent, the investments, and temporary investments a Fund will acquire, subject in each case to the limitations and restrictions described in the Funds’ offering materials and governing documents and their investment advisory agreements. A Fund may receive distributions from an Underlying Fund or portfolio company in kind in the form of securities of portfolio companies, some of which may be illiquid or restricted securities. With respect to such distributions, CAI may have the discretion to sell such securities and distribute the cash proceeds, distribute such securities in kind or offer the relevant Fund’s investors the option, subject to CAI’s consent, either to receive the securities in kind or have the Fund sell them and distribute the cash proceeds. While CAI will use reasonable efforts in such instances to sell or to distribute marketable securities promptly, investors will bear any associated costs or market risks during the disposition process.

Item 17: Voting client securities

Voting Client Securities CAI has been delegated the authority to vote investment proxies on behalf of certain of its clients and has adopted written policies that are reasonably designed to ensure proxies are voted in the best interest of its clients and to resolve conflicts of interest (the “Policies”). The general policy is to vote proxy proposals, amendments, consents, or resolutions relating to client securities, including interests in private investment funds, if any, in a manner that serves the best interests of client accounts, as determined by CAI in its discretion. Clients may request a copy of the Policies and the proxy voting record relating to their account by contacting CAI.

Item 18: Financial information

Financial Information All client fees owed to CAI are either paid in arrears or paid less than six months in advance. Under relevant SEC rules, this means that CAI is not required to disclose information about its financial position or balance sheets. Nonetheless, we confirm that we believe that CAI has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has never been the subject of a bankruptcy proceeding.

Robert Albert Grogan 388 Greenwich Street New York, NY 10013 (212) 816-2409 March 31, 2026 Educational Background and Business Experience Robert A. Grogan, 1948 • California State University Long Beach, B.S. in Accounting • Whittier School of Law, J.D Citigroup (1989-Present) • Human Resources, Managing Director (2011-Present) o Managing Director, Citigroup Private Equity (CVCI GP) LLC o Group Head, Citigroup Employee Private Equity Management o Group Head and Senior Financial Planner, Executive Financial Services •

Citi Global Pension Investments (2008-2010) o Business Head and Chief Investment Officer

•

Salomon Brothers (1989-2007)

Disciplinary Information Mr. Grogan does not have any legal or disciplinary events required to disclosed in this Appendix Other Business Activities Mr. Grogan has no other business activities outside of his employment with CAI, LLC and other Citigroup affiliates that are required to be disclosed in this Appendix. Mr. Grogan will not offer products and services other than investment advisory services. The amount of compensation Mr. Grogan earns for advisory services may be more or less than compensation received for non-advisory services. This may pose a potential conflict of interest to recommend products based on the compensation received rather than your needs. When Citigroup Alternative Investments, LLC or one of its affiliates identifies an actual conflict of interest we will strive to mitigate that conflict or disclose it to our clients. For additional information about Citigroup Alternative Investments, LLC compensation please refer to “Item 5. Compensation of CAI Personnel.” •

Additional Compensation

Citigroup Alternative Investments, LLC has adopted policies that prohibit the acceptance of gifts and entertainment that may influence the investment advice provided to clients. Consistent with these policies, Mr. Grogan is permitted to receive gifts of up to $100 and receive ordinary and customary business entertainment, subject to a limit of $250 per person per event to a maximum of $1,000 of meals and entertainment expenses per person per vendor. •

Supervision

Citigroup Alternative Investments, LLC supervises Mr. Grogan in accordance with Citigroup Alternative Investments, LLC’s internal policies and procedures. The name and contact information for the person responsible for supervising Mr. Grogan’s activities is Mr. Stuart Woodward at (44207)-508-6876. .

Subsidiaries and ownership

Ultimate parent

Subsidiaries (GLEIF)

Ownership links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); each one cites its LEI record.

Timeline

  1. Oct 2, 2017Parent Directly consolidated by CITIGROUP INVESTMENTS INC.2
  2. Feb 12, 2002Founded Citigroup Alternative Investments LLC is founded2

SEC filer profile

How Citigroup Alternative Investments LLC is registered with the Securities and Exchange Commission, from its EDGAR record and the cover page of its latest annual report.

  • Name on EDGARCitigroup Alternative Investments LLC1
  • CIK0001441823
  • Incorporated inDelaware1
  • Fiscal year endsDecember 311
  • Business address731 Lexington Avenue, 28Th Floor, New York, NY 100221
  • Phone212-559-85801
  • On EDGAR sinceAug 1, 20081
  • Filings3 in all: 3 (3)1