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CaseApproved-list review · Tollmere Senior Lending FundJWJames Walker

Subject: Tollmere Credit Advisers LLCOwner: Sarah CollinsOpen

Case evidence · 6

ImageInvestor portal fee noticeScreenshot · Saved 2026-10-23 by Sarah Collins · 1 note
Source linkInvestors in older Tollmere funds ask whether fee fix reaches themThe Credit Desk · 2026-06-18 · Source copy · 1 note
Source linkTollmere completes fee reviewTollmere Capital Group · 2026-03-04 · 1 note
SEC filingForm 4 · Keary DesmondFiled 2026-03-12 · Officer · Vice Chair
PDFOrder instituting proceedings · File No. 3-22418Published 2025-02-11 · 9 pages
ResearchDue Diligence report · Version 1AI-generated report on Tollmere Credit Advisers LLC · 4 cited sources

2 more items

Activity

Working assessment savedSarah Collins

File version savedSarah Collins

Note added to saved versionSarah Collins

Working assessmentCurrent · revision 2 · Sarah Collins · 2026-10-22 11:12 UTC

Current assessment

The manager reports its review complete . Public sources do not show whether borrower fees are now credited against this fund’s management fee .

Unresolved questions

  1. What do the fund’s offering memorandum and governing agreement say about the offset?
  2. Does a recent fee calculation show the credit for borrower fees?
  3. When did remediation take effect for this fund? Is anything excluded?
  4. Who oversees the fee controls and the remediation today?

Next step

Request the offering memorandum, governing agreement and a recent fee calculation from Tollmere before the approved-list committee on 2026-11-12.

Reviews on other revisions · James Walker · Reviewed · Revision 1

Source referenceThe Credit Desk · 2026-06-18

Source link · Source copy · Version 1 · PDF

Sample

The Credit Desk · 2026-06-18

Investors in older Tollmere funds ask whether fee fix reaches them

Tollmere’s letters to investors describe the offset for funds launched after January 2025. Two investors in older funds, including the Senior Lending Fund, said the letters did not say whether borrower fees are now credited against their management fees.

A Tollmere spokesperson said each fund’s offset follows its governing agreement and the consultant’s review covered every fund.

Notes for this source

SCSarah Collins · 2026-10-21 13:52 UTC

The letters describe funds launched after January 2025. Ask for our fund’s fee terms and a recent fee calculation showing the credit.

Source referenceTollmere Capital Group · 2026-03-04

Tollmere completes fee review

Publisher
Tollmere Capital Group
Published
2026-03-04
Saved by
Sarah Collins

Link only. No page body or original copy is stored.

Notes for this source

SCSarah Collins · 2026-10-21 13:40 UTC

The statement comes after the deadline. Ask when the adviser filed its certification.

Add evidenceApproved-list review · Tollmere Senior Lending FundJWJames Walker

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tollmere-slf-fee-calculation-q3-2026.pdf186 KBReady

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Original fileQ3 2026 management fee calculation

PDF · Original · Version 1 · Provided by Tollmere Credit Advisers LLC

Sample

Tollmere Senior Lending Fund

Management fee calculation

Quarter ended September 30, 2026

1Average invested capital$512,000,000
2Management fee rate (annual)1.25%
3Gross management fee (line 1 × line 2 ÷ 4)$1,600,000
4Servicing and monitoring fees paid by fund borrowers to Tollmere Loan Services LLC, Q3 2026$214,300
5Offset under section 4.3 of the governing agreement (100% of line 4)($214,300)
6Net management fee$1,385,700

Prepared by Tollmere Credit Advisers LLC · October 30, 2026Page 1 of 1

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JWJames Walker · Note on saved version · page 1

Line 5 credits this quarter’s borrower fees in full against the management fee. It covers Q3 2026 only, so it doesn’t show how earlier periods were treated.

Working assessmentCurrent · revision 3 · James Walker · 2026-11-05 10:40 UTCJWJames Walker

Assessment revision 3 saved. Earlier revisions and Records are unchanged.

Current assessment

The manager reports its review complete . Its Q3 2026 calculation for this fund credits borrower fees in full against the management fee . Earlier periods are not shown.

Q3 2026 management fee calculationPDF · page 1

5Offset under section 4.3 of the governing agreement (100% of line 4) ($214,300)

JWJames Walker: It covers Q3 2026 only, so it doesn’t show how earlier periods were treated.

Tollmere completes fee reviewTollmere Capital Group · 2026-03-04

SCSarah Collins: The statement comes after the deadline. Ask when the adviser filed its certification.

Unresolved questions

  1. What do the fund’s offering memorandum and governing agreement say about the offset?
  2. How were borrower fees treated before Q3 2026?
  3. Who oversees the fee controls and the remediation today?

Next step

Ask Tollmere for the governing agreement and the earlier calculations before the committee on 2026-11-12.

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SCSarah CollinsReview requested · Assessment revision 3 · 2026-11-05 10:42 UTC

Colleague reviews

SCSarah Collins · Reviewed · Assessment revision 3 · 2026-11-06 09:15 UTC

The Q3 calculation supports a credit for this fund before the reported January 2027 rollout to all funds. Confirm when it began and how earlier borrower fees were treated.

A colleague’s response applies to the named revision; it is not compliance clearance.

Review requestsWaiting on youSCSarah Collins

Approved-list review · Tollmere Senior Lending FundAssessment revision 3

Requested by James Walker · 2026-11-05 10:42 UTC

WaitingAnswer

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ReviewedChanges requested

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Review & create RecordApproved-list review · Tollmere Senior Lending FundJWJames Walker

Save the exact contents below. Creating a Record does not close or approve the Case.

Contents summary & included versions

AssessmentWorking assessment · revision 3James Walker · 2026-11-05 10:40 UTC · Sarah Collins · Reviewed
ResearchDue Diligence report · Version 1Tollmere Credit Advisers LLCDue Diligence report, included by James Walker on Nov 10, 2026
PDFQ3 2026 management fee calculationOriginal · Version 1 · 1 note
ImageInvestor portal fee noticeOriginal · Version 1 · 1 note
Source linkInvestors in older Tollmere funds ask whether fee fix reaches themSource copy · Version 1 · 1 note
Source linkTollmere completes fee reviewLink only · 1 note
SEC filingForm 4 · Keary DesmondFiled 2026-03-12
PDFOrder instituting proceedings · File No. 3-22418Published 2025-02-11
Create RecordCancel
CaseApproved-list review · Tollmere Senior Lending FundJWJames Walker

Subject: Tollmere Credit Advisers LLCOwner: Sarah CollinsOpen

Case evidence · 7

PDFTollmere letter on the offset’s start dateProvided by Tollmere Credit Advisers LLC · Saved 2026-11-16 by James WalkerAdded after Record 1
PDFQ3 2026 management fee calculationProvided by Tollmere Credit Advisers LLC · Saved 2026-11-04 by James Walker · 1 note
ImageInvestor portal fee noticeScreenshot · Saved 2026-10-23 by Sarah Collins · 1 note
Source linkTollmere completes fee reviewTollmere Capital Group · 2026-03-04 · 1 note
Source linkInvestors in older Tollmere funds ask whether fee fix reaches themThe Credit Desk · 2026-06-18 · Source copy · 1 note

3 more items5 more items

Record history

Record 1Latest saved2026-11-10 16:20 UTC · James Walker

Activity

File version savedJames Walker

Record createdJames Walker

Assessment review response savedSarah Collins

Record 1Created 2026-11-10 16:20 UTC by James Walker

Tollmere Credit Advisers LLC

Approved-list review · Tollmere Senior Lending Fund · Organization

Saved assessment · revision 3

James Walker · 2026-11-05 10:40 UTC

The manager reports its review complete [1]. Its Q3 2026 calculation for this fund credits borrower fees in full against the management fee [2]. Earlier periods are not shown.

Unresolved questions

  1. What do the fund’s offering memorandum and governing agreement say about the offset?
  2. How were borrower fees treated before Q3 2026?
  3. Who oversees the fee controls and the remediation today?
SCSarah Collins · Reviewed · Assessment revision 3 · 2026-11-06 09:15 UTC

The Q3 calculation supports a credit for this fund before the reported January 2027 rollout to all funds. Confirm when it began and how earlier borrower fees were treated.

Analyst assessment and colleague review at creation. This is not a screening decision or formal approval. Later revisions are not included.

Referenced evidence in this Record · 7

PDFQ3 2026 management fee calculation

ImageInvestor portal fee notice

Source linkTollmere completes fee review

Source linkInvestors in older Tollmere funds ask whether fee fix reaches them

SEC filingForm 4 · Keary Desmond

PDFOrder instituting proceedings · File No. 3-22418

ResearchDue Diligence report · Version 1

Due Diligence report, included by James Walker on Nov 10, 2026

About this Record

Saved at creation. Later Case changes are not included. Creating this Record did not close or approve the Case.

Record
Record 1
Created
2026-11-10 16:20 UTC
Created by
James Walker
Case status
Open

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Evidence

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CaseApproved-list review · Tollmere Senior Lending Fund
Case evidence · 7

Gathered elsewhere

Found in Altira

PDF · Original · Version 1 · Provided by Tollmere Credit Advisers LLC

Sample

Tollmere Senior Lending Fund

Management fee calculation

Quarter ended September 30, 2026

1Average invested capital$512,000,000
2Management fee rate (annual)1.25%
3Gross management fee (line 1 × line 2 ÷ 4)$1,600,000
4Servicing and monitoring fees paid by fund borrowers to Tollmere Loan Services LLC, Q3 2026$214,300
5Offset under section 4.3 of the governing agreement (100% of line 4)($214,300)
6Net management fee$1,385,700

Prepared by Tollmere Credit Advisers LLC · October 30, 2026Page 1 of 1

Notes for this source

JWJames Walker · Note on saved version · page 1

Line 5 credits this quarter’s borrower fees in full against the management fee. It covers Q3 2026 only, so it doesn’t show how earlier periods were treated.

Image · Original · Version 1 · Screenshot pasted by Sarah Collins

Sample

Investor portal · Notices

Fee offset update · Posted 2026-05-14

Following the completion of our fee review, servicing and monitoring fees received by Tollmere Loan Services are now offset against management fees for funds launched after January 2025.

Tollmere Credit Advisers LLC

Notes for this source

SCSarah Collins · Note on saved version

The portal notice names funds launched after January 2025 only. Our fund has been offered since 2022.

Tollmere completes fee review

Publisher
Tollmere Capital Group
Published
2026-03-04
Saved by
Sarah Collins

Link only. No page body or original copy is stored.

Notes for this source

SCSarah Collins · Analyst note

The statement comes after the deadline. Ask when the adviser filed its certification.

Source link · Source copy · Version 1 · PDF · From Adverse Media

Sample

The Credit Desk · 2026-06-18

Investors in older Tollmere funds ask whether fee fix reaches them

Tollmere’s letters to investors describe the offset for funds launched after January 2025. Two investors in older funds, including the Senior Lending Fund, said the letters did not say whether borrower fees are now credited against their management fees.

A Tollmere spokesperson said each fund’s offset follows its governing agreement and the consultant’s review covered every fund.

Notes for this source

SCSarah Collins · Analyst note

The letters describe funds launched after January 2025. Ask for our fund’s fee terms and a recent fee calculation showing the credit.

Form 4 · Keary Desmond

Filed name
DESMOND KEARY
Form
4
Filing date
2026-03-12
Roles reported in filing
Officer · Vice Chair

Historical role context: roles were reported in this filing and do not establish a current role.

From Corporate Insiders · Tollmere Capital Group, Inc.

Order instituting proceedings · File No. 3-22418

Published 2025-02-11 · 9 pages · From Enforcement Actions

Sample

Page 4

¶14. From 2021 through 2023, Tollmere Loan Services LLC received $11.6 million in servicing and monitoring fees from borrowers of the funds. Contrary to the funds’ offering memoranda and governing agreements, Respondent did not offset these fees against its management fees.

Due Diligence report · Version 1

AI-generated · From Due Diligence · Saved 2026-10-21 by Sarah Collins

Key findings

  1. Adviser to the Tollmere Senior Lending Fund; a subsidiary of Tollmere Capital Group, Inc.
  2. The 2025 order found borrower fees an affiliate collected were not credited as the governing agreements said, and required a consultant and a certification.

4 cited sources · 2 open questions

Colleague review

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Sample data · invented companies, people and documents
Working assessmentApproved-list review · Tollmere Senior Lending Fund

Revision

Each request applies to its named assessment revision.

Current assessment

The manager reports its review complete . Its Q3 2026 calculation for this fund credits borrower fees in full against the management fee . Earlier periods are not shown.

Unresolved questions

  1. What do the fund’s offering memorandum and governing agreement say about the offset?
  2. How were borrower fees treated before Q3 2026?
  3. Who oversees the fee controls and the remediation today?

Next step

Ask Tollmere for the governing agreement and the earlier calculations before the committee on 2026-11-12.

Colleague reviews

SCSarah Collins · Reviewed · Assessment revision 3 · 2026-11-06 09:15 UTC

The Q3 calculation supports a credit for this fund before the reported January 2027 rollout to all funds. Confirm when it began and how earlier borrower fees were treated.

Current assessment

The manager reports its review complete . Public sources do not show whether borrower fees are now credited against this fund’s management fee .

Unresolved questions

  1. What do the fund’s offering memorandum and governing agreement say about the offset?
  2. Does a recent fee calculation show the credit for borrower fees?
  3. When did remediation take effect for this fund? Is anything excluded?
  4. Who oversees the fee controls and the remediation today?

Next step

Request the offering memorandum, governing agreement and a recent fee calculation from Tollmere before the approved-list committee on 2026-11-12.

Colleague reviews

No review shown for this revision.

Current assessment

The manager reports its review complete . Public sources do not show whether borrower fees are now credited against this fund’s management fee .

Unresolved questions

  1. What do the fund’s offering memorandum and governing agreement say about the offset?
  2. Does a recent fee calculation show the credit for borrower fees?
  3. When did remediation take effect for this fund? Is anything excluded?

Next step

Request the offering memorandum, governing agreement and a recent fee calculation from Tollmere before the approved-list committee on 2026-11-12.

Colleague reviews

JWJames Walker · Reviewed · Assessment revision 1 · 2026-10-22 09:30 UTC

Add who oversees the fee controls now. The filings show Keary is still an officer, as Vice Chair; Amberley leads credit.

This is an earlier revision. Its review does not apply to a newer assessment.

Cited evidence

Tollmere completes fee review

Source link · Tollmere Capital Group · 2026-03-04

Link only. No page body or original copy is stored.

SCSarah Collins · Analyst note

The statement comes after the deadline. Ask when the adviser filed its certification.

Cited evidence

Investors in older Tollmere funds ask whether fee fix reaches them

Source link · The Credit Desk · 2026-06-18

“Tollmere’s letters to investors describe the offset for funds launched after January 2025.”

SCSarah Collins · Analyst note

The letters describe funds launched after January 2025. Ask for our fund’s fee terms and a recent fee calculation showing the credit.

Cited evidence

Q3 2026 management fee calculation

PDF · Original · page 1 · Provided by Tollmere Credit Advisers LLC

5Offset under section 4.3 of the governing agreement (100% of line 4) ($214,300)

JWJames Walker · Note on saved version · page 1

Line 5 credits this quarter’s borrower fees in full against the management fee. It covers Q3 2026 only, so it doesn’t show how earlier periods were treated.

Records

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The working Case · Nov 16

CaseApproved-list review · Tollmere Senior Lending FundJWJames Walker

Subject: Tollmere Credit Advisers LLCOwner: Sarah CollinsOpen

Case evidence · 8

PDFTollmere letter on the offset’s start dateProvided by Tollmere Credit Advisers LLC · Saved 2026-11-16 by James WalkerAdded after Record 1
PDFQ3 2026 management fee calculationProvided by Tollmere Credit Advisers LLC · Saved 2026-11-04 by James Walker · 1 note
ImageInvestor portal fee noticeScreenshot · Saved 2026-10-23 by Sarah Collins · 1 note
Source linkTollmere completes fee reviewTollmere Capital Group · 2026-03-04 · 1 note
Source linkInvestors in older Tollmere funds ask whether fee fix reaches themThe Credit Desk · 2026-06-18 · Source copy · 1 note

3 more items5 more items

Record history

Record 1Latest saved2026-11-10 16:20 UTC · James Walker

Activity

File version savedJames Walker

Record createdJames Walker

Assessment review response savedSarah Collins

Record 1 · saved Nov 10

Record 1Created 2026-11-10 16:20 UTC by James Walker

Tollmere Credit Advisers LLC

Approved-list review · Tollmere Senior Lending Fund · Organization

Saved assessment · revision 3

James Walker · 2026-11-05 10:40 UTC

The manager reports its review complete [1]. Its Q3 2026 calculation for this fund credits borrower fees in full against the management fee [2]. Earlier periods are not shown.

Unresolved questions

  1. What do the fund’s offering memorandum and governing agreement say about the offset?
  2. How were borrower fees treated before Q3 2026?
  3. Who oversees the fee controls and the remediation today?
SCSarah Collins · Reviewed · Assessment revision 3 · 2026-11-06 09:15 UTC

The Q3 calculation supports a credit for this fund before the reported January 2027 rollout to all funds. Confirm when it began and how earlier borrower fees were treated.

Analyst assessment and colleague review at creation. This is not a screening decision or formal approval. Later revisions are not included.

Referenced evidence in this Record · 7

PDFQ3 2026 management fee calculation

ImageInvestor portal fee notice

Source linkTollmere completes fee review

Source linkInvestors in older Tollmere funds ask whether fee fix reaches them

SEC filingForm 4 · Keary Desmond

PDFOrder instituting proceedings · File No. 3-22418

ResearchDue Diligence report · Version 1

Due Diligence report, included by James Walker on Nov 10, 2026

About this Record

Saved at creation. Later Case changes are not included. Creating this Record did not close or approve the Case.

Record
Record 1
Created
2026-11-10 16:20 UTC
Created by
James Walker
Case status
Open

Export

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Sample

ALTIRA · CASE RECORD 1

Tollmere Credit Advisers LLC

Approved-list review · Tollmere Senior Lending Fund · Organization

Saved 2026-11-10 16:20 UTC by James Walker
Exported 2026-11-10 16:24 UTC

Saved at creation. Later Case changes are not included. Creating this Record did not close or approve the Case.

Working assessment · revision 3 · James Walker

The manager reports its review complete [1]. Its Q3 2026 calculation for this fund credits borrower fees in full against the management fee [2]. Earlier periods are not shown.

Colleague review · Sarah Collins · Reviewed

The Q3 calculation supports a credit for this fund before the reported January 2027 rollout to all funds. Confirm when it began and how earlier borrower fees were treated.

Evidence index

E001 Q3 2026 management fee calculation · E002 Investor portal fee notice · E003 Tollmere completes fee review · E004 The Credit Desk, 2026-06-18 · E005 Form 4 · Keary Desmond · E006 Order, File No. 3-22418 · E007 Due Diligence report · Version 1

ALTIRARECORD 11 / 9

Altira-Record-1.zipEvidence package

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