The document is an investment memorandum for Aspen Grove Capital, LLC, discussing U.S. federal income tax rules and considerations for prospective Limited Partners in the Access Fund. It highlights the lack of IRS rulings, potential changes in tax consequences, and advises consulting tax advisors. It also covers regulatory matters, including the unregistered offer and sale of Interests under the Securities Act of 1933, reliance on exemptions, and restrictions on transferability. Additionally, it discloses past regulatory issues with Raymond James related to auction rate securities.
doj/DataSet10/EFTA01393324.pdf
{"key_people":["Raymond James"],"document_type":"correspondence","key_locations":["United States","Puerto Rico","Virgin Islands","District of Columbia"],"document_subtype":"investment memorandum","key_organizations":["Aspen Grove Capital, LLC","Raymond James Financial Services, Inc.","Securities and Exchange Commission"],"reference_numbers":["DB-SDNY-0098841","SDNY_GM_00245025","EFTA01393324"]}