Subject: Administrative Proceeding File No. 3-16757
From:Marty L. Krueger

October 11, 2017

Regarding the proposed plan of distribution for the monies paid by Citigroup Alternative Investment LLC and Citigroup Global Markets Inc., the “Total Payments to Investors” include settlements that individual investors were able to negotiate with the “Respondents”, and such settlements are aggregated for all investors within “Potentially Eligible Fund”. Using that formula, there are some investors who benefitted more than others by virtue of receiving a settlement or higher settlements than other investors in the same fund. It would be more equitable to treat all investors individually within a fund. It would appear this information is available as the “Respondents” prepared an individual form K-1 for each investor.

Marty L. Krueger