EXHIBIT INDEX
Exhibit A: Attachment to item 77o:
Transactions effected pursuant to Rule 10f-3
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Exhibit A:
Item 77O
Transactions Executed Pursuant to Rule 10f-3
For the six month period ended June 30, 2000 the Partnership
engaged in several transactions which involved the purchase
of securities during the existence of an underwriting or
selling syndicate in which CIBC World Markets Corp., an
affiliate of the Partnership, participated as an
underwriter. The Partnership did not purchase securities
directly from CIBC World Markets Corp and purchased the
securities at the offering price.
The Individual General Partners of the Partnership,
including a majority of the Individual General Partners of
the Partnership who are not interested persons, have adopted
Rule 10f-3 procedures, pursuant to which such transactions
may be affected by the Partnership. On April 19, 2000 and
July 26, 2000, the Individual General Partners of the
Partnership determined that the transactions met the
requirements of Rule 10f-3. Details of the transactions
have been attached as an exhibit.
SCHEDULE B
RULE 10f-3 REPORT
A. INFORMATION REGARDING THE OFFERING AND TRANSACTION
Date of Purchase: 04/04/00
Name of Issuer/Issue: Metlife, Inc. / Common Stock
Principal Amount of Offering: 202MM SHS
Price/Spread: $14.25 / 0.64
Amount Purchased by the Fund: 500,000
B. COMPLIANCE CHECKLIST
Indicate whether the following conditions were met in connection
with the purchase of the security described in Section A above:
1. X Securities are (i) part of an issue
registered under the Securities Act of 1933 that is
being offered to the public, (ii) Eligible Municipal
Securities, (iii) sold in an Eligible Foreign
Offering, or (iv) sold in an Eligible Rule 144A
Offering.
2. X The purchase for the Fund was made prior to
the end of the first full business day on which any
sales are made, and, if the securities are offered for
subscription upon exercise of rights, on or before the
fourth day preceding the day on which the rights
offering terminates.
3. X The underwriting was a firm commitment
underwriting.
4. X The commission, spread or profit received or to be
received by the principal underwriters was fair and
reasonable as compared to the commission, spread or
profit received by other principal underwriters in
connection with underwritings of similar securities
during a comparable period of time.
5. X Except for Eligible Municipal Securities, the
issuer has been in continuous operation for not less
than 3 years, including the operations of any
predecessors.
6. X The amount of securities of any class purchased by
the Fund, alone or together within one or more
investment companies to which the Adviser serves as
investment adviser, (i) for all offerings other than
Eligible Rule 144A Offerings, does not exceed 25% of
the principal amount of the offering of such class, and
(ii) for Eligible Rule 144A Offerings, does not exceed
25% of the total principal amount of the offering of
such class sold to qualified institutional buyers, plus
the principal amount of the offering in any concurrent
public offering.
7. X The securities were not purchased directly or
indirectly from: (a) an officer, director, Manager,
investment adviser or employee of the Fund or (b) a
person of which any of the persons noted in (a) is an
affiliated person.
8. X If securities were purchased from a syndicate
manager, the purchase was not part of a group sale or
otherwise allocated to the account of any of the
persons specified in 7 above.
04/04/00
Name: Thomas Kyle Date
Title: Partner
SCHEDULE B
RULE 10f-3 REPORT
A. INFORMATION REGARDING THE OFFERING AND TRANSACTION
Date of Purchase: 04/26/00
Name of Issuer/Issue: AT&T Wireless Group / Common Stock
Principal Amount of Offering: 360MM SHS
Price/Spread: $29.50 / 0.86
Amount Purchased by the Fund: 106,000
B. COMPLIANCE CHECKLIST
Indicate whether the following conditions were met in connection
with the purchase of the security described in Section A above:
1. X Securities are (i) part of an issue registered
under the Securities Act of 1933 that is being offered
to the public, (ii) Eligible Municipal Securities,
(iii) sold in an Eligible Foreign Offering, or (iv)
sold in an Eligible Rule 144A Offering.
2. X The purchase for the Fund was made prior to
the end of the first full business day on which any
sales are made, and, if the securities are offered for
subscription upon exercise of rights, on or before the
fourth day preceding the day on which the rights
offering terminates.
3. X The underwriting was a firm commitment
underwriting.
4. X The commission, spread or profit received or to be
received by the principal underwriters was fair and
reasonable as compared to the commission, spread or
profit received by other principal underwriters in
connection with underwritings of similar securities
during a comparable period of time.
5. X Except for Eligible Municipal Securities, the
issuer has been in continuous operation for not less
than 3 years, including the operations of any
predecessors.
6. X The amount of securities of any class purchased by
the Fund, alone or together within one or more
investment companies to which the Adviser serves as
investment adviser, (i) for all offerings other than
Eligible Rule 144A Offerings, does not exceed 25% of
the principal amount of the offering of such class, and
(ii) for Eligible Rule 144A Offerings, does not exceed
25% of the total principal amount of the offering of
such class sold to qualified institutional buyers, plus
the principal amount of the offering in any concurrent
public offering.
7. X The securities were not purchased directly or
indirectly from: (a) an officer, director, Manager,
investment adviser or employee of the Fund or (b) a
person of which any of the persons noted in (a) is an
affiliated person.
8. X If securities were purchased from a syndicate
manager, the purchase was not part of a group sale or
otherwise allocated to the account of any of the
persons specified in 7 above.
04/26/00
Name: Thomas Kyle Date
Title: Partner
SCHEDULE B
RULE 10f-3 REPORT
A. INFORMATION REGARDING THE OFFERING AND TRANSACTION
Date of Purchase: 06/26/00
Name of Issuer/Issue: Stratos Lightwave / Common Stock
Principal Amount of Offering: 8.75MM SHS
Price/Spread: $21 / 1.47
Amount Purchased by the Fund: 10,500
B. COMPLIANCE CHECKLIST
Indicate whether the following conditions were met in connection
with the purchase of the security described in Section A above:
1. X Securities are (i) part of an issue registered
under the Securities Act of 1933 that is being offered
to the public, (ii) Eligible Municipal Securities,
(iii) sold in an Eligible Foreign Offering, or (iv)
sold in an Eligible Rule 144A Offering.
2. X The purchase for the Fund was made prior to
the end of the first full business day on which any
sales are made, and, if the securities are offered for
subscription upon exercise of rights, on or before the
fourth day preceding the day on which the rights
offering terminates.
3. X The underwriting was a firm commitment
underwriting.
4. X The commission, spread or profit received or to be
received by the principal underwriters was fair and
reasonable as compared to the commission, spread or
profit received by other principal underwriters in
connection with underwritings of similar securities
during a comparable period of time.
5. X Except for Eligible Municipal Securities, the
issuer has been in continuous operation for not less
than 3 years, including the operations of any
predecessors.
6. X The amount of securities of any class purchased by
the Fund, alone or together within one or more
investment companies to which the Adviser serves as
investment adviser, (i) for all offerings other than
Eligible Rule 144A Offerings, does not exceed 25% of
the principal amount of the offering of such class, and
(ii) for Eligible Rule 144A Offerings, does not exceed
25% of the total principal amount of the offering of
such class sold to qualified institutional buyers, plus
the principal amount of the offering in any concurrent
public offering.
7. X The securities were not purchased directly or
indirectly from: (a) an officer, director, Manager,
investment adviser or employee of the Fund or (b) a
person of which any of the persons noted in (a) is an
affiliated person.
8. X If securities were purchased from a syndicate
manager, the purchase was not part of a group sale or
otherwise allocated to the account of any of the
persons specified in 7 above.
06/26/00
Name: Thomas Kyle Date
Title: Partner
SCHEDULE B
RULE 10f-3 REPORT
A. INFORMATION REGARDING THE OFFERING AND TRANSACTION
Date of Purchase: 06/28/00
Name of Issuer/Issue: Capstone Turbine Corp. / Common Stock
Principal Amount of Offering: 9,090,909 SHS
Price/Spread: $16 / 1.12
Amount Purchased by the Fund: 15,000
B. COMPLIANCE CHECKLIST
Indicate whether the following conditions were met in connection
with the purchase of the security described in Section A above:
1. X Securities are (i) part of an issue registered
under the Securities Act of 1933 that is being offered
to the public, (ii) Eligible Municipal Securities,
(iii) sold in an Eligible Foreign Offering, or (iv)
sold in an Eligible Rule 144A Offering.
2. X The purchase for the Fund was made prior to
the end of the first full business day on which any
sales are made, and, if the securities are offered for
subscription upon exercise of rights, on or before the
fourth day preceding the day on which the rights
offering terminates.
3. X The underwriting was a firm commitment
underwriting.
4. X The commission, spread or profit received or to be
received by the principal underwriters was fair and
reasonable as compared to the commission, spread or
profit received by other principal underwriters in
connection with underwritings of similar securities
during a comparable period of time.
5. X Except for Eligible Municipal Securities, the
issuer has been in continuous operation for not less
than 3 years, including the operations of any
predecessors.
6. X The amount of securities of any class purchased by
the Fund, alone or together within one or more
investment companies to which the Adviser serves as
investment adviser, (i) for all offerings other than
Eligible Rule 144A Offerings, does not exceed 25% of
the principal amount of the offering of such class, and
(ii) for Eligible Rule 144A Offerings, does not exceed
25% of the total principal amount of the offering of
such class sold to qualified institutional buyers, plus
the principal amount of the offering in any concurrent
public offering.
7. X The securities were not purchased directly or
indirectly from: (a) an officer, director, Manager,
investment adviser or employee of the Fund or (b) a
person of which any of the persons noted in (a) is an
affiliated person.
8. X If securities were purchased from a syndicate
manager, the purchase was not part of a group sale or
otherwise allocated to the account of any of the
persons specified in 7 above.
06/28/00
Name: Thomas Kyle Date
Title: Partner
SCHEDULE B
RULE 10f-3 REPORT
A. INFORMATION REGARDING THE OFFERING AND TRANSACTION
Date of Purchase: 06/26/00
Name of Issuer/Issue: Marvell Technology Group / Common Stock
Principal Amount of Offering: 6MM SHS
Price/Spread: $15 / 1.05
Amount Purchased by the Fund: 10,000 SHS
B. COMPLIANCE CHECKLIST
Indicate whether the following conditions were met in connection
with the purchase of the security described in Section A above:
1. X Securities are (i) part of an issue registered
under the Securities Act of 1933 that is being offered
to the public, (ii) Eligible Municipal Securities,
(iii) sold in an Eligible Foreign Offering, or (iv)
sold in an Eligible Rule 144A Offering.
2. X The purchase for the Fund was made prior to
the end of the first full business day on which any
sales are made, and, if the securities are offered for
subscription upon exercise of rights, on or before the
fourth day preceding the day on which the rights
offering terminates.
3. X The underwriting was a firm commitment
underwriting.
4. X The commission, spread or profit received or to be
received by the principal underwriters was fair and
reasonable as compared to the commission, spread or
profit received by other principal underwriters in
connection with underwritings of similar securities
during a comparable period of time.
5. X Except for Eligible Municipal Securities, the
issuer has been in continuous operation for not less
than 3 years, including the operations of any
predecessors.
6. X The amount of securities of any class purchased by
the Fund, alone or together within one or more
investment companies to which the Adviser serves as
investment adviser, (i) for all offerings other than
Eligible Rule 144A Offerings, does not exceed 25% of
the principal amount of the offering of such class, and
(ii) for Eligible Rule 144A Offerings, does not exceed
25% of the total principal amount of the offering of
such class sold to qualified institutional buyers, plus
the principal amount of the offering in any concurrent
public offering.
7. X The securities were not purchased directly or
indirectly from: (a) an officer, director, Manager,
investment adviser or employee of the Fund or (b) a
person of which any of the persons noted in (a) is an
affiliated person.
8. X If securities were purchased from a syndicate
manager, the purchase was not part of a group sale or
otherwise allocated to the account of any of the
persons specified in 7 above.
06/26/00
Name: Thomas Kyle Date
Title: Partner
SCHEDULE B
RULE 10f-3 REPORT
A. INFORMATION REGARDING THE OFFERING AND TRANSACTION
Date of Purchase: 02/10/00
Name of Issuer/Issue: Fargo Electronics / Common Stocks
Principal Amount of Offering: 5,000,000 SHS
Price/Spread: $15 / 1.05
Amount Purchased by the Fund: 7,000 SHS
B. COMPLIANCE CHECKLIST
Indicate whether the following conditions were met in connection
with the purchase of the security described in Section A above:
1. X Securities are (i) part of an issue registered
under the Securities Act of 1933 that is being offered
to the public, (ii) Eligible Municipal Securities,
(iii) sold in an Eligible Foreign Offering, or (iv)
sold in an Eligible Rule 144A Offering.
2. X The purchase for the Fund was made prior to
the end of the first full business day on which any
sales are made, and, if the securities are offered for
subscription upon exercise of rights, on or before the
fourth day preceding the day on which the rights
offering terminates.
3. X The underwriting was a firm commitment
underwriting.
4. X The commission, spread or profit received or to be
received by the principal underwriters was fair and
reasonable as compared to the commission, spread or
profit received by other principal underwriters in
connection with underwritings of similar securities
during a comparable period of time.
5. X Except for Eligible Municipal Securities, the
issuer has been in continuous operation for not less
than 3 years, including the operations of any
predecessors.
6. X The amount of securities of any class purchased by
the Fund, alone or together within one or more
investment companies to which the Adviser serves as
investment adviser, (i) for all offerings other than
Eligible Rule 144A Offerings, does not exceed 25% of
the principal amount of the offering of such class, and
(ii) for Eligible Rule 144A Offerings, does not exceed
25% of the total principal amount of the offering of
such class sold to qualified institutional buyers, plus
the principal amount of the offering in any concurrent
public offering.
7. X The securities were not purchased directly or
indirectly from: (a) an officer, director, Manager,
investment adviser or employee of the Fund or (b) a
person of which any of the persons noted in (a) is an
affiliated person.
8. X If securities were purchased from a syndicate
manager, the purchase was not part of a group sale or
otherwise allocated to the account of any of the
persons specified in 7 above.
02/10/00
Name: Thomas Kyle Date
Title: Partner
SCHEDULE B
RULE 10f-3 REPORT
A. INFORMATION REGARDING THE OFFERING AND TRANSACTION
Date of Purchase: 03/07/00
Name of Issuer/Issue: Firstworld Communications Corp. / Common
Stock
Principal Amount of Offering: 10MM SHS
Price/Spread: $17 / 1.19
Amount Purchased by the Fund: 40,000 SHS
B. COMPLIANCE CHECKLIST
Indicate whether the following conditions were met in connection
with the purchase of the security described in Section A above:
1. X Securities are (i) part of an issue registered
under the Securities Act of 1933 that is being offered
to the public, (ii) Eligible Municipal Securities,
(iii) sold in an Eligible Foreign Offering, or (iv)
sold in an Eligible Rule 144A Offering.
2. X The purchase for the Fund was made prior to
the end of the first full business day on which any
sales are made, and, if the securities are offered for
subscription upon exercise of rights, on or before the
fourth day preceding the day on which the rights
offering terminates.
3. X The underwriting was a firm commitment
underwriting.
4. X The commission, spread or profit received or to be
received by the principal underwriters was fair and
reasonable as compared to the commission, spread or
profit received by other principal underwriters in
connection with underwritings of similar securities
during a comparable period of time.
5. X Except for Eligible Municipal Securities, the
issuer has been in continuous operation for not less
than 3 years, including the operations of any
predecessors.
6. X The amount of securities of any class purchased by
the Fund, alone or together within one or more
investment companies to which the Adviser serves as
investment adviser, (i) for all offerings other than
Eligible Rule 144A Offerings, does not exceed 25% of
the principal amount of the offering of such class, and
(ii) for Eligible Rule 144A Offerings, does not exceed
25% of the total principal amount of the offering of
such class sold to qualified institutional buyers, plus
the principal amount of the offering in any concurrent
public offering.
7. X The securities were not purchased directly or
indirectly from: (a) an officer, director, Manager,
investment adviser or employee of the Fund or (b) a
person of which any of the persons noted in (a) is an
affiliated person.
8. X If securities were purchased from a syndicate
manager, the purchase was not part of a group sale or
otherwise allocated to the account of any of the
persons specified in 7 above.
03/07/00
Name: Thomas Kyle Date
Title: Partner
SCHEDULE B
RULE 10f-3 REPORT
A. INFORMATION REGARDING THE OFFERING AND TRANSACTION
Date of Purchase: 02/17/00
Name of Issuer/Issue: Eloquent, Inc. / Common Stock
Principal Amount of Offering: 4,500,000 SHS
Price/Spread: $16 / 1.12
Amount Purchased by the Fund: 12,500
B. COMPLIANCE CHECKLIST
Indicate whether the following conditions were met in connection
with the purchase of the security described in Section A above:
1. X Securities are (i) part of an issue registered
under the Securities Act of 1933 that is being offered
to the public, (ii) Eligible Municipal Securities,
(iii) sold in an Eligible Foreign Offering, or (iv)
sold in an Eligible Rule 144A Offering.
2. X The purchase for the Fund was made prior to
the end of the first full business day on which any
sales are made, and, if the securities are offered for
subscription upon exercise of rights, on or before the
fourth day preceding the day on which the rights
offering terminates.
3. X The underwriting was a firm commitment
underwriting.
4. X The commission, spread or profit received or to be
received by the principal underwriters was fair and
reasonable as compared to the commission, spread or
profit received by other principal underwriters in
connection with underwritings of similar securities
during a comparable period of time.
5. X Except for Eligible Municipal Securities, the
issuer has been in continuous operation for not less
than 3 years, including the operations of any
predecessors.
6. X The amount of securities of any class purchased by
the Fund, alone or together within one or more
investment companies to which the Adviser serves as
investment adviser, (i) for all offerings other than
Eligible Rule 144A Offerings, does not exceed 25% of
the principal amount of the offering of such class, and
(ii) for Eligible Rule 144A Offerings, does not exceed
25% of the total principal amount of the offering of
such class sold to qualified institutional buyers, plus
the principal amount of the offering in any concurrent
public offering.
7. X The securities were not purchased directly or
indirectly from: (a) an officer, director, Manager,
investment adviser or employee of the Fund or (b) a
person of which any of the persons noted in (a) is an
affiliated person.
8. X If securities were purchased from a syndicate
manager, the purchase was not part of a group sale or
otherwise allocated to the account of any of the
persons specified in 7 above.
02/17/00
Name: Thomas Kyle Date
Title: Partner
Eligible Municipal Securities means "municipal securities," as
defined in Section 3(a)(29) of the Exchange Act, that have received
an investment grade rating from at least one NRSRO; provided, that if
the issuer of the municipal securities, or the entity supplying the
revenues or other payments from which the issue is to be paid, has
been in continuous operation for less than three years, including the
operation of any predecessors, the securities shall have received one
of the three highest ratings from an NRSRO.
