Oakleaf Endowment Trust for the Blake School

“Paragraph 6.1(04)a of the trust document for the oakleaf endowment trust for the blake school dated january 3, 2000, as amended 12/10/2010, previously read as follows: "the annual draw payable during a calendar year ("payment year") shall be determined by the trustees at the end of the preceding calendar year ("determination year") and shall be the designated percentage of the lesser of: i. The amount determined by the trustees using the same formula that the blake used to determine the draw from its endowment for its fiscal year ending within or with the determination year; and ii. The sum of (a) seventy percent (70%) of the amount determined under this subparagraph ii as of the end of the year immediately preceding the determination year ("predetermination year") increased by the rate of inflation for the determination year (the amount determined under this clause (a) shall be zero for purposes of determining the annual draw payable during the calendar year following the calendar year during which the trust is initially funded), and (b) one and one-half percent (1-1/2%) of the net fair market value of the assets of the trust as of the end of the determination year; provided, however, in no event shall such annual draw be less than one percent (1%) of the net fair market value of the assets of the trust as of the end of the determination year, and in no event shall such annual draw be greater than that specified in the preceding portion of this provison unless the outside auditors regularly retained by blake have, during the determination year, in language clearly understandable to the average member of the board of directors of blake reported to such board in detail the degree to which the endowments of blake (as defined by blake's board of directors in consultation with its outside auditors) are in the aggregate in financial equilibrium." paragraph 6.1(04)a has been amended in its entirety pursuant to amendment no. 2, dated may 23, 2014, to the oakleaf endowment trust for the blake school dated january 3, 2000, as amended 12/10/2010, to read as follows: "the annual draw payable during a calendar year ("payment year") shall be determined by the trustees at the end of the preceding calendar year ("determination year") and shall be the designated percentage of the lesser of: i. The amount determined by the trustees using the same formula that the blake used to determine the draw from its endowment for its fiscal year ending within or with the determination year; and ii. The sum of (a) seventy percent (70%) of the amount determined under this subparagraph ii as of the end of the year immediately preceding the determination year ("predetermination year") increased by the rate of inflation for the determination year (the amount determined under this clause (a) shall be zero for purposes of determining the annual draw payable during the calendar year following the calendar year during which the trust is initially funded), and (b) one and one-half percent (1-1/2%) of the net fair market value of the assets of the trust as of the end of the determination year; provided, however, in no event shall such annual draw be less than one percent (1%) of the net fair market value of the assets of the trust as of the end of the determination year, and in no event shall such annual draw be greater than that specified in the preceding portion of this proviso unless the finance committee of the board of directors of blake has, during the determination year, in language clearly understandable to the average member of the board of directors of blake reported in detail the methodology by which it determined the recommended appropriation for expenditure from blake's endowments for its last fiscal year and the degree to which the endowments of the blake (as defmed by blake's board of directors after consultation with its outside auditors) are in the aggregate in financial equilibrium (as that term is defined in the first sentence of paragraph 6.1(04)”

“Paragraph 6.1(04)e of the trust document for the oakleaf endowment trust for the blake school dated january 3, 2000, as amended 12/10/2010, previously read as follows: "for purposes hereof, financial equilibrium is defined as maintaining the real value of a pool of assets over time by both investing such a pool and drawing funds out of such a pool in such a way so that over the long-term such pool will grow at least at the rate of inflation, not counting additions to such pool. The outside auditor regularly retained by blake shall provide annually to the trustees its opinion regarding whether the endowments of blake (as defined by blake's board of directors after consultation with its outside auditors) in the aggregate are in financial equilibrium and the facts supporting such opinion. The trustees may rely on such opinion and shall be held harmless for doing so. The grantors suggest that the following calculation methodology be utilized by blake's outside auditors until the board of directors of blake in consultation with its outside auditors determines that a different calculation methodology is better suited to accomplishing the grantors' intent as expressed in the first sentence of this paragraph and so instructs the trustees: i. The endowments of blake shall be in financial equilibrium at the end of a fiscal year of blake if the actual value of blake's endowment funds (as defined by blake's board of directors after consultation with its outside auditors but disregarding this trust and referred to herein as the "endowment funds") in the aggregate as of the end of such fiscal year is greater than or equal to the equilibrium value of the endowment funds as of the end of such fiscal year. Ii. The actual value of the endowment funds shall be the fair market value of the endowment funds as of the end of such fiscal year as recorded in the audited fmancial statements of blake. Iii. The equilibrium value of the endowment funds shall be computed as of the end of each fiscal year of blake. The equilibrium value at the end of a fiscal year shall be the sum of: a. Such equilibrium value as of the beginning of such fiscal year increased by the rate of inflation for such fiscal year; and b. For each addition to the endowment funds during such fiscal year, the fair market value of such addition as of the date of contribution increased by the rate of inflation for such fiscal year prorated on a daily basis to reflect the number of days during such fiscal year the addition was held in the endowment funds. The board of directors of blake shall determine whether to begin the computation of the equilibrium value of the endowment funds as of the beginning of its 1997, 1998 or 1999 fiscal year. The equilibrium value of the endowment funds as of the beginning of the first fiscal year of blake for which the computation of the equilibrium value of the endowment funds is made shall be the actual value of the endowment funds at such time. For each fiscal year thereafter, the equilibrium value of the endowment funds at the beginning of a fiscal year shall be the equilibrium value of the endowment funds at the end of the preceding fiscal year." paragraph 6.1(04)e has been amended in its entirety pursuant to amendment no. 2, dated may 23, 2014, to the oakleaf endowment trust for the blake school dated january 3, 2000, as amended 12/10/2010, to read as follows: "for purposes hereof, financial equilibrium is defmed as maintaining the real value of a pool of assets over time by both investing such a pool and drawing funds out of such a pool in such a way so that over the long-term such pool will grow at least at the rate of inflation, not counting additions to such pool. For all purposes of the trust, the endowments of blake (as defined by blake's board of directors after consultation with its outside auditors) shall be conclusively considered to be in financial equilibrium if the board of directors of blake (i) certifies to the trustees of the trust tha”

“Per the endowment's trust agreement, the nominating group for the endowment's board of directors is comprised of the chairperson of blake school's board of directors, the chairperson of the blake school's governance committee, and the chairperson of the blake school's committee that is responsible for its investments.”

“No review was or will be conducted.”

“The oakleaf endowment trust for the blake school makes its governing documents and other financial statements available for public inspection by request to have documents received via e-mail, regular mail, or in person at the okabena company, 180o ids center, minneapolis, mn, 55402. A fee may apply for copying and mailing costs associated with the request.”

“BOOK AX DIFFERENCE 1.”

“The full legal name of the organization is the oakleaf endowment trust for the blake school.”

“The trustees, having been selected by the blake school board of directors, are subject to the policies and procedures of the blake school, the supported organization. The endowment trust does not compensate any trustees, officers, or key employees.”

“Controlled foreign corporation reporting (form 5471) the taxpayer may be required to file form 5471 for the foreign corporation listed below, but is not doing so under the multiple filers exception pursuant to treas. Reg. Section 1.6038-2(j). The taxpayer's filing requirement will be satisfied by: okabena diversified equity fund, llc 1800 ids center, minneapolis, mn 55402 ein: 41-1563584 the return will be filed in ogden, ut. Name of foreign corporation(s): frontier market opportunities fund, ltd. Iva global fund (cayman)(us investors) ltd. Sit offshore custom alpha spc(a)”