Seaf

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GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
ACCESS SEAF SAFI
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SUPERINTENDENCIA DEL MERCADO DE VALORES, PERU IN REGARDS TO ACCESS SEAF SAFI, A RELYING ADVISER OF SEAF
2.
Principal Sanction:
Revocation
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/04/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
090-2015-SMV/02
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Investment Contract(s)
Other Product Types: 
DEBT AND EQUITY INVESTMENTS IN PRIVATELY HELD COMPANIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ACCESS SEAF SAFI WAS NOT IN COMPLIANCE WITH REPORTING REQUIREMENTS TO THE SUPERINTENDENCIA DEL MERCADO DE VALORES. THERE WAS
A SITE VISIT BY THE SUPERINTENDENCIA DEL MERCADO DE VALORES ON SEPTEMBER 1, 2015, BUT ACCESS SEAF SAFI'S OFFICE WAS CLOSED AND
THERE WAS NO WAY TO ACCESS A REPRESENTATIVE OF ACCESS SEAF SAFI. ACCESS SEAF SAFI DID NOT SUBMIT AN ANNUAL AUDIT REPORT FOR 2014.
ACCESS SEAF SAFI DID NOT SUBMIT / HAS NOT RESPONDED REGARDING THE REQUIREMENT TO COMPLETE ANTI-MONEY LAUNDERING AND ANTI-
TERRORISM REPORTS. ACCESS SEAF SAFI DOES NOT HAVE ADEQUATE PHYSICAL INFRASTRUCTURE OR TECHNOLOGY TO PERFORM ITS DUTIES. ACCESS
SEAF SAFI HAS NOT REMEDIED ITS FINANCIAL DEFICIT IN ACCORDANCE WITH ARTICLE 130 OF THE REGULATIONS FOR INVESTMENT FUNDS AND THEIR
MANAGEMENT COMPANIES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/04/2015
 Exact
 Explanation
If not exact, provide explanation:
IN ACCORDANCE WITH THE NOTICE FROM THE SUPERINTENDENCIA DEL MERCADO DE VALORES, ACCESS SEAF SAFI WILL BE CHANGING ITS
CORPORATE PURPOSE AT A SHAREHOLDERS MEETING ON SEPTEMBER 23, 2015.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion

of penalty was waived: 
N/A
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN RESPONDING TO ITEM 11.D.5, IT SHOULD BE NOTED THAT IN EARLY 2012 THE SHAREHOLDERS OF FONDO LATAM PERU ("THE FUND") DENIED
ACCESS SEAF SAFI, A RELYING ADVISOR OF SEAF, ITS RIGHT TO RETAIN CERTAIN EXIT PROCEEDS THEREBY LEAVING THE FUND WITH INSUFFICIENT
LIQUIDITY TO PAY ITS LIABILITIES. THE FUND'S SIGNIFICANT LIABILITY IS AN ACCOUNT PAYABLE OF OVER USD 1.1 MILLION DUE TO ACCESS SEAF
SAFI, THAT REMAINS UNPAID. IN Q1, 2015 AFTER SIGNIFICANT FINANCIAL SUPPORT FROM SEAF TO ACCESS SEAF SAFI, THE FUNDS' SHAREHOLDERS
PUT THE FUND INTO LIQUIDATION AND APPOINTED A THIRD PARTY LIQUIDATOR. AS A RESULT, ACCESS SEAF SAFI NO LONGER NEEDED TO RETAIN ITS
REGISTRATION AND ITS REGISTRATION WAS SUBSEQUENTLY CANCELLED BY THE PERUVIAN FINANCIAL REGULATOR (THE SMV).