Illegal Activity
suspicious
Blackmail
none
Date
Unknown
Document Type
memorandum
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:41
Summary
This memorandum amends the summary of principal terms for the Access Fund to include details about a servicing fee paid to Deutsche Bank for introducing clients. The fee is calculated based on the subscription amount of the introduced client and varies depending on the stage of the underlying fund's investment period.
Metadata
- Subject
- Changes to Summary of Principal Terms of the Access Fund
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0096108
- Date
- —
Illegal Activity
- Severity
- suspicious
- Description
- The document describes a servicing fee arrangement with Deutsche Bank for introducing clients to the Access Fund. While not inherently illegal, the tiered fee structure based on subscription amounts could raise concerns about potential conflicts of interest or undue influence, warranting further scrutiny.
- Content Type
- none
Relationships 3
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| General Partner | placement agreement | Deutsche Bank Securities Inc. | The General Partner, the Investment Manager and the Access Funds have entered into a placement agreement with Deutsche Bank Securities Inc. |
| Investment Manager | payment for servicing functions | Deutsche Bank | The Investment Manager will, in exchange for Deutsche Bank performing certain servicing functions, pay to Deutsche Bank in respect of each DB Introduced Person that is not in default of its obligations as described in the Partnership Agreement |
| Access Fund | investor | DB Introduced Person | DB Introduced Person subscribes to the Access Fund |
Financial Information
Amounts:$3 million$5 million0.65% per annum0.45% per annum0.05% per annum0.4875% per annum0.36% per annum0.05% per annum0.20%
Assets:
- Subscription to the Access Fund
- Invested Capital
Transactions:
- Servicing Fee payable quarterly in advance
- Payment from Investment Manager to Deutsche Bank for servicing functions
Raw Analysis JSON
click to expand
Themes
Financial transactions/money flowBusiness dealings
Organizations 8
Mid Lake CapitalAccess FundGeneral PartnerInvestment ManagerDeutsche Bank Securities Inc.DBSIDeutsche BankUnderlying Fund
Financial Entities 2
Deutsche BankDeutsche Bank Securities Inc.
Text Analysis
- Tone
- Professional
- Purpose
- To amend the Summary of Principal Terms of the Access Fund by adding information about the Servicing Fee paid to Deutsche Bank for introducing clients to the Access Fund.
- Significance
- This document outlines the financial arrangement between the Access Fund, its Investment Manager, and Deutsche Bank regarding client referrals and servicing fees.
File Info
- File Name
- EFTA01391278.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:41:38.941844
- DOJ Source
- View on DOJ