Please contact Gavion toll-free(800) 969-6891 during business hours for technical assistance or to request a paper copy of the documents below.  For a free download of Adobe Acrobat, please access the link below:

https://get.adobe.com/reader/

IMPORTANT DISCLOSURES

GAVION does not provide legal or tax advice to clients. All clients with tax considerations, including the effect of UBTI resulting from alternative investment strategies, are strongly urged to consult their tax advisers regarding such issues. A copy of GAVION’s current ADV Brochures may be obtained by contacting the firm’s compliance department at compliance@gavionllc.com or at www.adviserinfo.sec.gov. SEC registration does not denote a certain level of skill or training.

Risks of Investing in Alternative Investments including Hedge Funds

PLEASE READ THE FOLLOWING STATEMENT CAREFULLY

When considering alternative investments, such as hedge funds and hedge funds of funds (collectively referenced in this document as “Hedge Funds”), you should consider various risks including the fact that some alternative investments use leverage and other speculative investment practices that may increase the risk of investment loss, can be illiquid, are not required to provide periodic pricing or valuation information to investors, may involve complex tax structures and delays in distributing important tax information, are not subject to the same regulatory requirements as mutual funds, often charge high fees, and in many cases the underlying investments are not transparent and are known only to the investment manager.

With respect to alternative investments, such as Hedge Funds, in general, you should be aware that:

• Returns from some alternative investments, such as Hedge Funds, can be volatile
• You may lose all or a portion of your investment
• With respect to single manager products, the manager has total trading authority.  The use of a single manager could mean a lack of diversification and higher risk.
• Many alternative investments that include Hedge Funds are subject to substantial expenses that must be offset by trading profits and other income. 
• Trading may take place on foreign exchanges that may not offer the same regulatory protection as United States exchanges.
• The ability to perform adequate due diligence may be significantly limited due to limited transparency.  Client account statements may not be readily available, may not contain sufficient detail, may not represent standard security pricing conventions and may not be produced regularly.
• Alternative investments comprising direct private investments may pose greater levels of risk compared to those identified in this disclosure document.
• Certain Alternative investments are not registered therefore lacking governmental oversight.

With respect to an investment in a Hedge Fund, you should be aware that:

• There is often a lack of transparency as to the underlying investments of Hedge Funds.
• With respect to a hedge fund of funds, the fund’s manager has complete discretion to invest in various sub-funds without disclosure thereof to you or to us.  Because of this lack of transparency, there is no way for you to monitor the specific investments made by the underlying hedge funds or to know whether the sub-fund investments are consistent with the hedge fund’s historic investment philosophy or risk levels.
• A hedge fund of funds invests in other funds and fees are charged at both the fund and sub-fund level.  Thus, the overall fees you will pay will be higher than you would pay by investing directly in the sub-funds.  In addition, each sub-fund charges an incentive fee on new profits regardless of whether the overall operations of the fund are profitable.
• There is no public secondary market for Hedge Funds interests.  Transfers of interests are subject to limitations.  The funds’ manager may deny a request to transfer if it determines that the transfer may result in adverse legal or tax consequences for the fund.

A Hedge Funds’ Offering Memorandum or a registered money manager’s disclosure document (Form ADV Part 2A) describes the various risks and conflicts of interest relating to an investment and to its operations.  You should read those documents carefully to determine whether an investment is suitable for you in light of, among other things, your financial situation, need for liquidity, tax situation, and other investments.

Keep in mind that past performance of any investment is not necessarily indicative of future results.  You should only commit risk capital to any investment product.  Alternative investment products, including Hedge Funds, are not for everyone and entail risks that are different from more traditional investments.  You should obtain legal and tax advice from your appropriate advisors before deciding to invest.

GAVION, LLC Business Continuity Planning
Gavion, LLC (“GAVION”) has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity
plan.

Contacting Us – If after a significant business disruption you cannot contact us as you usually do at 901-761-8080, you should use our alternative number, 901-568-9937, 901-355-5456 or 901-517-7642.

Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees,and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; and regulatory reporting.

Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 24 hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site(s) outside of the affected area, and recover and resume business within 3 business days. In either situation, we plan to continue in business, and notify you through a message on our regular number.

For more information – If you have questions about our business continuity planning, you can contact us at 901-761-8080 or compliance@gavionllc.com.