Introduction

Monark's omnibus platform (Evergreen Funds Omnibus, or EFO for short) is purpose-built to bring institutional scale and efficiency to alternative asset transactions. It brings a streamlined, API forward approach to transacting in Registered Evergreen Funds not eligible for settlement via Fund/Serv - more specifically, tender offer funds, non-traded REITs, non-traded BDCs, and similar continuously offered vehicles. The omnibus platform leverages our connectivity with Transfer Agents ("TAs") and the DTCC's Alternative Investment Products ("AIP") system to service the entire lifecycle of an evergreen fund transaction, from initial (and subsequent) purchase(s), ongoing reconciliation, dividend processing, position reconciliation and order netting.

Monark's Omnibus platform sits between Custodians and the funds' Transfer Agents as the sub-accounting system of record, consolidating millions of individual investor orders, positions, and activity into omnibus accounts held with each TA. The Transfer Agent establishes each omnibus account either in the name of the Custodian or, for Custodians in the MMM Securities master omnibus, in the name of MMM Securities LLC, Monark's broker-dealer subsidiary. Either way, Monark maintains the full individual investor sub-accounting beneath it, down to the tax lot. This is the core value proposition of the platform: API Clients (Custodians) get scalable, programmatic access to alternative assets without the operational burden of direct to Transfer Agent integrations, and funds receive clean, aggregated flow without interacting with millions of investors, documents, NIGO trades, etc.

Monark has also removed subscription and redemption documents from the flow entirely. Orders are submitted programmatically via API, with suitability and disclosure requirements satisfied at order submission, unlocking scalable order processing without the paper subscription packages that have slowed down the industry since inception. The implementation platform collects accreditation and suitability from the advisor in its own UI and reports them to Monark, which makes them available to the Custodian.

Custodian Onboarding

To participate as an API client on the EFO platform, your firm must be, or integrated with, a FINRA Member Broker-Dealer and Custodian. Transacting in a fund supported by EFO requires a separate omnibus account at the Transfer Agent for each combination of fund, share class, and dividend election method. Individual investor positions roll up into each omnibus account. Monark sets one of two custody models for each Custodian, fund, and share class:

• Custodian omnibus: the omnibus accounts are held in the name of the Custodian, for its investors only. The Custodian licenses Monark's netting engine to net orders within its own omnibus account, and Monark holds no account and is not a record-holder. Cash moves directly between the Custodian and the Transfer Agent, and Monark does not touch it.
• MMM Securities master omnibus: for Custodians that opt in, the master omnibus accounts at the Transfer Agent are held in the name of MMM Securities LLC, Monark's broker-dealer subsidiary, which is the sole record-holder. Each participating Custodian holds its own omnibus account at MMM Securities, which records the Custodian's balance on its own books. Orders net in two tiers: first within each participating Custodian's omnibus account, then across participating Custodians at the master omnibus level. Cash moves between the Custodian and the Transfer Agent through MMM Securities, using a clearing account the Custodian opens with MMM Securities. MMM Securities sees only Custodian-level data, such as balances, orders and wires: individual investor records and personal information stay in Monark's sub-ledger.

See Custody Models for a side-by-side comparison.

For example, to begin transacting in Fund 123 under the custodian omnibus model, Custodian ABC would need one omnibus account for:

• Fund 123 / Share Class I / CASH Dividends,
  
  and a separate omnibus account for:
• Fund 123 / Share Class I / DRIP Dividends
  
  and yet another omnibus account for:
• Fund 123 / Share Class C / DRIP Dividends

This structure ensures that dividends and other corporate actions are captured and processed accurately and enables BUY and SELL Orders to be netted against each other. Custodial Omnibus Accounts are set up on a one-time basis during onboarding, in coordination with Monark's operations team and the Transfer Agent.

In the MMM Securities master omnibus, the Custodian's investor positions roll up into its omnibus account at MMM Securities, and from there into MMM Securities' master omnibus accounts for the same combinations, which Monark opens with the Transfer Agent if they do not already exist.

Fund Onboarding

To participate as a Fund client on the EFO platform, your fund company must meet the following eligibility criteria:

Eligibility Criteria:

• Not currently supported on Fund/SERV
• Evergreen/continuously raising vehicle
• 1099s for tax reporting. K-1 funds are not supported on EFO
• AIP functionality enabled for Positions, Valuations, and Activity Distributions (dividends)
• EFO has existing connectivity with your Transfer Agent (Currently integrated with SS&C ALTSERVE CONNECT and UMB).

For questions on eligibility, or to begin the onboarding process as a Custodian or Fund, contact [email protected].