Small Enterprise Assistance Funds

Allegations: 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. Status: Final Sanction Detail: N/A Summary: 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).