EFTA01442223.txt Text dataset_10 View on DOJ

This document is a supplement to a private placement memorandum for Glendower Access Secondary Opportunities IV (U.S.), L.P., focusing on the role of Deutsche Bank Securities Inc. as a placement agent. It details the fees and compensation structure for Deutsche Bank, discloses potential conflicts of interest, and mentions past regulatory settlements involving Deutsche Bank Securities Inc.

Subject

Supplement to the Confidential Private Placement Memorandum relating to Glendower Access Secondary Opportunities IV (U.S.), L.P.

Sender

—

Recipients

—

Document ID

—

Date

April 2018

Severity

suspicious

Description

The document mentions past settlements by Deutsche Bank Securities Inc. (DBSI) with regulatory bodies like the SEC, the National Association of Securities Dealers, the New York Stock Exchange, the New York Attorney General, and the New Jersey Department of Securities. These settlements relate to investigations into research analyst independence and the sale of auction rate preferred securities and auction rate securities (ARS). While these are past events, the disclosure raises concerns about DBSI's past conduct and potential regulatory risks.

Content Type

first_hand

The DB Placement Fee is a one-time sales charge in addition to and apart from the Subscription, calculated and payable upon closing at a rate determined with respect to the relevant DB Introduced Person's Subscription to the Access Fund (e.g., a DB Introduced Person with an aggregate Subscription of $1 million will pay to Deutsche Bank a DB Placement Fee equal to $20,000).

Prospective investors should take such fees, and the related potential conflicts of interest, into account when considering and evaluating any recommendations related to a direct or indirect investment in the Underlying Fund.

• The varying fee structures and potential for Deutsche Bank to receive different fees for different funds, creating a conflict of interest.
• The fact that direct investors in the Underlying Fund do not bear the additional layer of fees and expenses to which DB Introduced Persons are subject.

Context

The document is a supplement to a private placement memorandum, which is not typically public. However, the past regulatory settlements involving Deutsche Bank Securities Inc. (DBSI) may be public knowledge.

• Potential conflicts of interest due to Deutsche Bank's dual role as placement agent for both the Access Fund and the Underlying Fund, and the varying fee structures.
• Disclosure of past regulatory settlements involving DBSI with the SEC, the New Jersey Department of Securities and New York Attorney General.

Financial transactions/money flowLegal matters/litigationBusiness dealingsCommunications/correspondence

Cliff Illig

Glendower Access Secondary Opportunities IV (U.S.), L.P.Glendower Capital Secondary Opportunities Fund IV, LPDeutsche Bank Securities Inc.Deutsche BankGlendower Access Secondary Opportunities IV (International), L.P.U.S. Internal Revenue ServiceGlendower GPGlendower Capital, LLCSECNational Association of Securities DealersNew York Stock ExchangeNew York Attorney GeneralNew Jersey Department of Securities

U.S.New YorkNew Jersey

Deutsche Bank Securities Inc.Deutsche Bank

Tone

Professional

Purpose

To modify and update the Confidential Private Placement Memorandum of Glendower Access Secondary Opportunities IV (U.S.), L.P. with respect to Investors referred or introduced to the Access Fund by Deutsche Bank Securities Inc.

Significance

This document outlines the fees and compensation structure for Deutsche Bank's role as a placement agent for the Glendower Access Secondary Opportunities IV (U.S.), L.P. fund, and discloses potential conflicts of interest.

File Name

EFTA01442223.txt

Dataset

dataset_10

Type

Text

Model

gemini-2.0-flash-001

Processed

2026-02-07T18:42:33.510905

DOJ Source

View on DOJ