Premium Point Investments, LLC

Form ADV, Part 2A: Firm Brochure March 31, 2011 Premium Point Investments, LLC Contact Information: 712 Fifth Avenue, 45 th Floor New York, NY 10019 (p) 212-991-2000 (f) 212-991-4005 Email: info@premiumpt.com Website: www.premiumpt.com CRD Number: 149921 This brochure provides information about the qualifications and business practices of Premium Point Investments LLC. If you have any questions about the contents of this brochure, please contact us at: 212-991-2000 or email us at info@premiumpt.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about our firm, Premium Point, LLC, is available on the SEC s website at www.adviserinfo.sec.gov 1

Item 2 Material Changes The U.S. Securities and Exchange Commission issued a final rule in July 2010 (Final Rule) requiring changes to Part II of SEC Form ADV. The Final Rule specifies that a new document be prepared according to the requirements of the Final Rule. This document, therefore, is materially different in structure and requires certain information not included in our prior Form ADV Part II. This new document is now known as Form ADV Part 2 and includes Part 2A, the Brochure, and Part 2B, the Brochure Supplement. In the past we have offered or delivered information about our qualifications and business practices to clients at least annually. Pursuant to the Final Rule, we will ensure that you receive a summary of any material changes to this document and subsequent brochures within 120 days of the close of our fiscal year end. We may provide other ongoing disclosure information about material changes as necessary. 2

Item 3 Table of Contents Item 1 Cover page... 1 Item 2 Material Changes... 2 Item 3 Table of Contents... 3 Item 4 Advisory Business... 4 Item 5 Fees and Compensation... 4 Item 6 Performance-Based Fees and Side-by-Side Management... 5 Item 7 Types of Clients... 5 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss... 5 Item 9 Disciplinary Information... 6 Item 10 Other Financial Industry Activities and Affiliations... 7 Item 11 Code of Ethics, Participation or Interest in Client Transactions & Personal Trading... 7 Item 12 Brokerage Practices... 7 Item 13 Review of Accounts... 8 Item 14 Client Referrals and Other Compensation... 9 Item 15 Custody... 9 Item 16 Investment Discretion... 9 Item 17 Voting Client Securities... 10 Item 18 Financial Information... 10 Brochure Supplement (Part 2B of Form ADV)... 11 3

Item 4 Advisory Business Premium Point Investments, LLC (PPI), a Delaware limited liability company formed in June 2008 by Anilesh Ahuja, Patrick Downes and Hyung Peak, provides investment advisory services. At the end of 2009, Anilesh Ahuja, Patrick Downes and Hyung Peak contributed their interests in PPI to a newly formed holding company, PPIH, LLC, thereby, making Messrs. Ahuja, Downes and Peak indirect owners of PPI. Anilesh Ahuja and Patrick Downes are the managing members of the Investment Manager. Messrs. Ahuja and Downes worked together on and off again for thirteen (13) years at Deutsche Bank AG and Greenwich Capital (RBS). They are joined by senior trading, research and risk management professionals who worked together for ten (10) years at Deutsche Bank AG, Lehman Brothers and Greenwich Capital (RBS). PPI provides investment advisory services. We do not hold ourselves out as specializing in a particular type of advisory service such as financial planning, quantitative analysis or market timing. PPI manages hedge fund, private equity, and ERISA compliant vehicles. The Funds achieve returns primarily through return of principal attained by investing in residential mortgage securities and loans, as well as through interest income and price appreciation. As of December 31, 2010 PPI managed $535 million on a discretionary basis and $265 million on a nondiscretionary basis. Clients may not impose restrictions on investing in certain securities or types of securities other than as outlined in the governing documents. PPI does not participate in wrap fee programs by providing portfolio management services. Item 5 Fees and Compensation PPI is compensated for advisory services as a percentage of assets under management or committed capital at a rate of approximately 1.5% (management fee). In addition, PPI receives performance based compensation between 10-20% of net appreciation of assets. The fees are deducted from the clients assets. In addition, the client pays their proportionate share of custody, administrative and other expenses of the Fund PPI and its personnel do not receive compensation for the sale of securities or other investment products or service fees such as from the sale of mutual funds also known as 12b-1 fees. There are no commissions or mark ups in addition to our advisory fees. 4

Item 6 Performance-Based Fees and Side By-Side Management See Item 5. Item 7 Types of Clients PPI provides discretionary and non discretionary asset management services to private and institutional clients. PPI s client base includes high net worth individuals, trusts, pensions, endowments, pooled investment vehicles as well as other types of institutional investors. PPI requires a minimum account size of $5 million. PPI offers managed accounts for investments over $100 million. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss PPI focuses on opportunities in the U.S. residential real estate markets. PPI seeks to acquire residential mortgage real estate assets that are undervalued compared to the intrinsic value of the underlying real estate; PPI does not take a speculative view on the recovery of the housing market. PPI s Funds performance is driven by the cash flows generated by pools of mortgages purchased under conservative default and loss assumptions. It is not dependent solely on the appreciation of the underlying real estate or interest income. Any appreciation that may occur as the housing market stabilizes would represent excess return to the funds base case projections. PPI believes it utilizes a differentiated approach to investing in the U.S. residential real estate markets by combining extensive modeling and risk management with a fundamentally-driven investment process that begins with property-level analysis. PPI believes that its approach is essential to investing in this sector successfully, as the probability of defaults remains relatively high (driven both by borrowers inability and their unwillingness to pay), and recovery rates are an important variable in the security selection process. PPI utilizes data and information such as housing auctions, Case- Shiller Home Price Index, the Federal Reserve, FHFA (the US Federal Housing Finance Agency formerly the Office of Federal Housing Enterprise Oversight or OFHEO), NAR, Urban Land Institute, Bloomberg and other sources. 5

PPI uses a top-down strategic approach in its investment process and a bottom-up tactical approach in selecting specific securities. PPI will first make educated assumptions about broad variables based on the historical data related to the housing market, employment, etc. From these assumptions, the Investment Manager identifies sectors of the market that represent the best risk-reward opportunities. Once the strategy is solidified, securities are purchased using a detailed fundamental approach where the most granular consideration will be the underlying characteristics of the individual loans in the securitized pools and the higher level consideration will be the structure of the deal. Typically, the portfolio manager(s) identify a list of 5-10 securities daily that fit the basic investment criteria, as determined by the strategic and tactical approach. The investment team then performs detailed analysis of the real estate collateral at the loan level, and models the cash flows and returns on each of the 5-10 bonds under a base case and stress scenario. Risk statistics are also calculated at this point, and optimal hedges are identified. Once the analysis is completed, the most attractive bond is selected and an investment memorandum is prepared for review by the Investment Committee. At this point, the Chief Risk Officer reviews the liquidity and counterparty exposure and the impact the potential transaction would have on the portfolio. Based on input from the investment and risk personnel, the Investment Committee will determine the suitability of the trade and the highest price the Investment Manager is willing to pay. Once approved by the Committee, the personnel that are responsible for trading will seek to execute the order at the most advantageous price possible. Investing in any security involved the risk of loss. Investors should be prepared to bear this risk before investing. Item 9 Disciplinary Information Since inception of the firm in 2008, there have been no material legal or disciplinary events involving PPI and/or PPI s management. 6

Item 10 Other Financial Industry Activities and Affiliations In March 2011, the management of PPI has been approved for a Broker Dealer license in the name of Brant Point, LLC. PPI s management are among the registered representatives of Brant Point, LLC. Brant Point, LLC shares its offices with Premium Point Investments, LLC. The broker dealer and the investment adviser are affiliated due to their mutual ownership by PPIH, LLC. Conflicts of interest may arise; however, the broker dealer and the investment adviser are dedicated to acting in accordance with the best interests of their clients at all times and under all circumstances. The broker dealer and the investment adviser both have written policies and procedures in place designed to ensure compliance with the rules of each firms specific regulatory authority. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading PPI maintains a Code of Ethics that requires the highest standard of ethical conduct on the part of employees and requires compliance with securities laws. A copy of the firm s Code of Ethics is available upon request. The Principals of PPI have aligned their interests with investors by investing personal capital into the funds. Since, all investments are allocated on a primarily pro rata basis the Principals receive the same gains and losses as the investors. The interests of clients are always put ahead of PPI and/or PPI s Principals. PPI maintains and reviews a record of firm and personal securities transactions. Item 12 Brokerage Practices The criteria that forms the basis for PPI s broker selection is achieving best execution on behalf of clients. Thus, we consider the full range and quality of a broker's service in selecting brokers to meet best execution obligations. Such factors as the responsiveness of the broker, execution, clearance and settlement capabilities of the 7

broker, the nature of the security being purchased, the size of the transaction, the desired timing of the trade, the activity existing and expected in the market for the particular security, confidentiality, the broker's financial stability and the commission rates available at the time of the trade each may influence the selection of the broker for a particular trade. PPI does not receive research or other products or services other than execution from a broker dealer or a third party in connection with client securities transactions ( soft dollar benefits ). PPI does not consider, in selecting a broker dealer, whether PPI or a related person receives client referrals from a broker dealer or third party. PPI does not permit a client to direct brokerage. PPI's order aggregation policy is that where possible for efficiency and to minimize costs, client trades may be aggregated and executed in a "block transaction". If so, shares are apportioned in accordance with Premium Point LLC's "Block Trading Policy" which provides for, among other things, a written allocation statement specifying the intended allocation, pro-rata allocation on partially filled orders and average pricing, except where administratively impracticable if the difference would be immaterial (e.g. if it results in a number of shares being allocated to a particular portfolio that is insignificant in relation to the size of the portfolio). Where fair and equitable, orders may be allocated in a manner different from the allocation statement. Item 13 Review of Accounts The Fund s external Administrator is the accountant of record for the Funds. They are responsible for completion of all middle and back office accounting including daily reconciliations. Review of these reconciliations and oversight of the administrator is completed by internal operations. Any issues are presented to the Head of Operations and corrections are reconciled and corrected timely. The Administrator prepares a month-end accounting package and calculates the Net Asset Value. The monthly package is reviewed internally and not finalized until approved. Quarterly written account statements are sent to each investor by the administrator. PPI also accommodates reasonable additional reporting requests from clients. 8

Item 14 Client Referrals and Other Compensation PPI or related persons do not have any oral or written arrangements to be paid cash by or receive some economic benefit from a non-client in connection with giving advice to clients. PPI may compensate third persons for referrals. Such referral arrangements are generally governed by a written agreement between PPI and the particular third party that (i) complies with the SEC's «cash solicitation» rule (Rule 206 (4)-3); (ii) requires that clients be provided with copies of PPI's Form ADV Part IIA ( also known as the brochure), separate disclosure of the nature of the referral arrangement (including compensation features) applicable to the client being referred, and any other document required to be provided under the applicable state law. In exchange for each referral, PPI pays the solicitor an agreed upon percentage of the management fees received by PPI. Item 15 Custody Since PPI has signing authority over some of the accounts that they serve as Investment Manager, PPI is deemed to have custody over client assets, however, PPI has no physical custody of these assets. Each fund/account has a prime broker (JP Morgan or State Street) who is the actual custodian of the clients assets. In addition, there is a third-party administrator on all Funds and an external independent audit is done annually for the Funds by PricewaterhouseCoopers, LLP. Quarterly statements, which include each investor s capital balance and transaction activity (i.e. contributions and redemptions), are sent to each investor by the administrator. PPI advises clients to carefully review those statements. Item 16 Investment Discretion PPI provides discretionary and non discretionary asset management services. We request from our clients that our discretionary authority be documented in written form. This documentation may take the form of the LP agreement. 9

Item 17 Voting Client Securities PPI invests in debt; therefore, we do not vote client securities. Item 18 Financial Information PPI does not have any financial impairments that will preclude the firm from meeting contractual commitments to clients. 10

Form ADV, Part 2B: Brochure Supplement March 31, 2011 Premium Point Investments, LLC Anilesh Ahuja Patrick Downes Hyung Peak Amin Majidi Elias Katz Contact Information: 712 Fifth Avenue, 45 th Floor New York, NY 10019 (p) 212-991-2000 (f) 212-991-4005 Email: info@premiumpt.com Website: www.premiumpt.com CRD Number: 149921 This brochure supplement provides information about Anilesh Ahuja, Patrick Downes, Hyung Peak, Amin Majidi and Elias Katz that supplements the Premium Point Investments LLC brochure. You should have already received a copy of that brochure. Please contact Patrick Downes if you did not receive our brochure or if you have any questions about the contents of this supplement. 11

Additional information about Anilesh Ahuja and Patrick Downes is available on the SEC s website at www.adviserinfo.sec.gov. Anilesh Ahuja Item 2 Educational Background and Business Experience Anilesh Ahuja (born 1968) serves as Chief Executive Officer and Chief Investment Officer of Premium Point Investments, LLC (Investment Manager). He has served in this role since 2008 (inception). From 2004 to 2008, Mr. Ahuja was the Head of Deutsche Bank s RMBS business. By 2007, under Mr. Ahuja s leadership, Deutsche Bank had risen from #18 in the RMBS issuance league tables to #4. As Head of Deutsche Bank s RMBS business (which included prime and subprime mortgages), a broad range of employees reported to Mr. Ahuja, including loan originators, securities traders, investment bankers and client relations specialists in North America, Europe and Asia. Prior to joining Deutsche Bank, Mr. Ahuja spent eight (8) years with Greenwich Capital as the head of agency and nonagency MBS. Prior to that, Mr. Ahuja directed the mortgage structuring business at Lehman Brothers for over six (6) years. Mr. Ahuja received his B.A. in Economics from the University of Pennsylvania in May 1989. Item 3 Disciplinary Information Anilesh Ahuja has no material legal or disciplinary history to disclose. Item 4 Other Business Activities See Item 10 Other Financial Industry Activities and Affiliations, in Part 2A, for information that pertains to Anilesh Ahuja s other business activities. Item 5 Additional Compensation Anilesh Ahuja does not receive any additional compensation. Item 6 Supervision The Chief Compliance Officer, Patrick Downes, supervises Anilesh Ahuja by monitoring all trading activity. 12

Patrick Downes Item 2 Educational Background and Business Experience Patrick Downes (born 1961) serves as President, Chief Operations Officer and Chief Compliance Officer or Premium Point Investments, LLC. He has served in this role since 2008 (inception). From 2006 to 2008, Mr. Downes served as a Director of Deutsche Bank s RMBS business. Prior to joining Deutsche Bank, Mr. Downes founded and served as the CEO of Vertical Crossing, which was sold to FIMAT a wholly owned subsidiary of Société Générale in 2003. From 1992 to 2000, Mr. Downes served as a senior member of a structured product sales team at Greenwich Capital. Prior to that, Mr. Downes was a Partner at Convergence Asset Management and Vice President with Salomon Brothers. Mr Downes received his B.S. from Cornell University in May 1984 Item 3 Disciplinary Information Patrick Downes has no material legal or disciplinary history to disclose. Item 4 Other Business Activities See Item 10 Other Financial Industry Activities and Affiliations, in Part 2A, for information that pertains to Patrick Downes s other business activities. Item 5 Additional Compensation Patrick Downes does not receive any additional compensation. Item 6 Supervision The Chief Executive Officer, Anilesh Ahuja, overseas the full organization, including Patrick Downes s activity. 13

Hyung Peak Item 2 Educational Background and Business Experience Hyung Peak (born 1970) serves as a Portfolio Manager and Managing Director of Premium Point Investments LLC. He has served in this role since 2008 (inception). From 2005 to 2008, Mr. Peak was a Managing Director and the Head of Private CMO Trading at Deutsche Bank. Prior to joining Deutsche Bank, Mr. Peak served as the Head of Prime Whole Loan Trading at Greenwich Capital. Previously, Mr. Peak was a Senior MBS Trader with Nomura Securities, Salomon Smith Barney, Barclays Bank plc (Singapore) and Mortgage Industry Advisory Corp. Mr. Peak received his B.S. from the Cooper Union School of Engineering in May 1992. Item 3 Disciplinary Information Hyung Peak has no material legal or disciplinary history to disclose. Item 4 Other Business Activities See Item 10 Other Financial Industry Activities and Affiliations, in Part 2A, for information that pertains to Hyung Peak s other business activities. Item 5 Additional Compensation Hyung Peak does not receive any additional compensation. Item 6 Supervision The Chief Compliance Officer, Patrick Downes, supervises Hyung Peak by monitoring all trading activity. The Chief Executive Officer, Anilesh Ahuja, overseas the full organization, including Hyung Peak s activity. 14

Amin Majidi Item 2 Educational Background and Business Experience Amin Majidi (born 1966) serves as the Chief Risk Officer of Premium Point Investments, LLC. He has served in this role since 2008 (inception). In 2007, Mr. Majidi founded and served as CIO of Alpha Beta Capital ABS Opportunities, an RMBS hedge fund. From 2004 to 2007, Mr. Majidi served as the head of Deutsche Bank s U.S. RMBS research business. Prior to joining Deutsche Bank, Mr. Majidi held senior portfolio manager positions at ABP Investments and Bear Stearns Asset Management. Prior to that, Mr. Majidi was a Senior MBS Research Analyst at Lehman Brothers and Salomon Brothers. Mr. Majidi received his B.S. from the School of Engineering at Columbia University in May 1987. Item 3 Disciplinary Information Amin Majidi has no material legal or disciplinary history to disclose. Item 4 Other Business Activities See Item 10 Other Financial Industry Activities and Affiliations, in Part 2A, for information that pertains to Amin Majidi s other business activities. Item 5 Additional Compensation Amin Majidi does not receive any additional compensation. Item 6 Supervision The Chief Compliance Officer, Patrick Downes, supervises Amin Majidi by monitoring all trading activity. The Chief Executive Officer, Anilesh Ahuja, overseas the full organization, including Amin Majidi s activity. 15

Elias Katz Item 2 Educational Background and Business Experience Elias Katz (born 1955) serves as a Portfolio Manager and Managing Director of Premium Point Investments, LLC. He has served in this role since 2010. From 1999 to 2010, Mr. Katz was the Chief Investment Officer at Madison Square Capital and a Portfolio Manager at Highland Financial Holdings Group. Mr. Katz received his B.S. in Civil Engineering from Tufts University in May 1976, his M.S. in Environmental Engineering from the University of North Carolina at Chapel Hill in June 1978 and his M.B.A. from the University of California, Berkeley in June 1982. Item 3 Disciplinary Information Elias Katz has no material legal or disciplinary history to disclose. Item 4 Other Business Activities See Item 10 Other Financial Industry Activities and Affiliations, in Part 2A, for information that pertains to Elias Katz s other business activities. Item 5 Additional Compensation Elias Katz does not receive any additional compensation. Item 6 Supervision The Chief Compliance Officer, Patrick Downes, supervises Elias Katz by monitoring all trading activity. The Chief Executive Officer, Anilesh Ahuja, overseas the full organization, including Elias Katz s activity. 16