Regulatory Information

Regulatory status, fund structure, and governance disclosures.

Last updated: January 2026

Regulatory Status

Aukeo Living operates as an operator-led adaptive reuse real estate investment and development platform. Aukeo intends to register as an investment adviser with the U.S. Securities and Exchange Commission ("SEC") pursuant to the Investment Advisers Act of 1940, as amended (the "Advisers Act"), upon reaching applicable regulatory assets under management thresholds, and will comply with applicable state and federal securities laws. Registration with the SEC does not imply a particular level of skill or training.

Private Fund Structure

Aukeo fund vehicles are organized as Delaware Limited Partnerships. Interests in Aukeo funds are offered in reliance on exemptions from registration under the Securities Act of 1933, as amended, including Regulation D thereunder, and on exemptions from investment company registration under the Investment Company Act of 1940, as amended, including Section 3(c)(7) thereof. Interests are available only to accredited investors, qualified purchasers, and institutional investors as defined under applicable rules.

Fund Administrator, Auditor, and Legal Counsel

Aukeo engages independent third parties to support fund governance and administration:

• Independent Auditor: PricewaterhouseCoopers LLP prepares annual audited financial statements for each Aukeo fund vehicle.
• Legal Counsel: LePore Law Group serves as external counsel to the Aukeo platform.
• Fund Administrator: An independent fund administrator maintains investor records, capital account statements, K-1 tax documentation, and quarterly capital account reporting.

Investment Committee and LP Advisory Committees

Alexandra Pohl chairs the Investment Committee for each Aukeo fund vehicle and maintains ultimate accountability for investment decisions. Each Aukeo fund includes an LP Advisory Committee composed of representatives of significant limited partners, which reviews potential conflicts of interest, related-party transactions, and other matters designated under the fund limited partnership agreement.

Fee and Expense Transparency

All Aukeo fund fees, carried interest, and fund expense allocations are disclosed in the definitive offering documents delivered to prospective limited partners. Aukeo commits to full fee transparency and does not receive undisclosed related-party fees. Aukeo funds operate under a European-style distribution waterfall with clawback provisions and carried interest held in escrow consistent with institutional governance standards.

Conflicts of Interest

Aukeo maintains a Conflicts of Interest policy covering allocation of investment opportunities across fund vehicles, co-investment allocation, related-party transactions, and personnel outside business activities. All material conflicts are disclosed to the LP Advisory Committee and, where applicable, subject to LP Advisory Committee approval. Full conflict disclosure is provided in the definitive offering documents for each fund vehicle.

Anti-Money Laundering and Know Your Customer

Aukeo complies with all applicable U.S. anti-money-laundering ("AML") and know-your-customer ("KYC") requirements. Prospective investors are subject to identity verification, source-of-funds screening, and sanctions screening against Office of Foreign Assets Control ("OFAC") lists prior to admission to any Aukeo fund. Aukeo maintains a written AML program including designated compliance personnel and periodic independent testing.

Cybersecurity and Data Protection

Aukeo maintains a cybersecurity program including encrypted transmission of investor data through the LP Portal, restricted role-based access controls, multi-factor authentication, periodic security testing, and incident response procedures. Aukeo complies with applicable privacy regulations including the California Consumer Privacy Act ("CCPA") and reports any material data incidents in accordance with applicable law.

Business Continuity

Aukeo maintains a business continuity plan designed to allow the firm to continue serving LP investors, portfolio investments, and municipal partners during significant business disruptions. The plan addresses alternative office locations, remote work capability, fund administrator continuity, and communication protocols with LP investors, auditors, and regulators.

Complaints and Regulatory Inquiries

Written complaints or regulatory inquiries should be directed to [email protected] or by mail at Aukeo Living, Attn: Compliance, 1910 Pacific Avenue, Suite 2000, Dallas, TX 75201. Aukeo maintains a written complaint log and responds to all substantive complaints within a reasonable period.

SEC Filings and Form ADV

Upon registration as an investment adviser, Aukeo will file Form ADV Parts 1, 2A, 2B, and 3 (Form CRS) as applicable, which will be publicly available through the SEC's Investment Adviser Public Disclosure system at adviserinfo.sec.gov. Copies of the filings will be available upon request by contacting [email protected].

Historic Tax Credit and LIHTC Program Compliance

Aukeo funds that use Federal Historic Tax Credits, state historic tax credits, or Low-Income Housing Tax Credits comply with applicable National Park Service, state historic preservation office, and state housing agency requirements. Recapture risk, monitoring compliance, and reporting obligations related to these tax credit programs are managed by Aukeo's development management team in coordination with tax counsel.

Contact

For regulatory, compliance, or governance questions, contact Aukeo at [email protected] or by mail at Aukeo Living, Attn: Compliance, 1910 Pacific Avenue, Suite 2000, Dallas, TX 75201.