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Private Equity Portfolio Performance Report As of March 31, 2012

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California State Teachers' Retirement System Private Equity Portfolio Performance March 31, 2012 CalSTRS Since Vintage Capital Inception Description Year Capital Committed Capital Contributed Distributed IRR* Total 38,521,723,753.95 30,725,783,132.26 21,039,189,215.64 12.35 ACON Equity Partners III LP 2011 70,000,000.00 0.00 0.00 N/A Acon-Bastion Partners II, L.P. 2006 40,000,000.00 33,974,793.00 6,541,242.00 16.61 Advent Central & Eastern Europe IV, LP 2008 103,646,859.39 57,103,952.02 0.00 (25.73) Advent International GPE VI, L.P. 2008 275,286,707.18 203,374,918.98 11,381,986.00 12.43 Affinity Asia Pacific Fund III, L.P. 2006 150,000,000.00 105,850,809.34 35,674,677.77 11.04 Alchemy Plan (Estrellita) L.P. 2002 258,985,732.44 258,154,612.44 156,127,959.47 (0.05) Alchemy Special Opps. Feeder Fund, L.P. 2006 80,329,252.19 59,646,405.83 26,038,419.63 4.75 Alta Communications IX, L.P. 2002 40,000,000.00 37,600,000.00 11,287,507.00 (4.80) Alta Communications VIII, L.P. 2000 45,000,000.00 44,100,000.00 27,911,226.00 (5.90) Alta V Limited Partnership 1992 20,000,000.00 20,000,000.00 45,540,989.12 24.54 AG Capital Recovery Partners IV, L.P. 2003 33,958,976.00 33,958,976.00 74,683,616.00 28.15 AG Capital Recovery Partners V, L.P. 2005 50,000,000.00 46,750,000.00 36,975,000.00 1.97 AG Capital Recovery Partners VI, L.P. 2008 100,000,000.00 100,000,000.00 12,056,466.00 6.78 AG Capital Recovery Partners VII, L.P. 2009 164,208,774.00 164,208,772.00 0.00 1.32 Apax Europe V 2001 115,649,883.55 115,649,883.54 230,369,390.33 36.34 Apax Europe VI - A, L.P. 2004 314,547,653.21 314,547,653.14 239,913,776.28 10.54 Apax Europe VII 2007 526,237,612.85 488,284,169.07 77,003,568.13 6.12 Apax Excelsior VI, L.P. 2000 100,000,000.00 98,422,784.00 131,749,983.00 11.79 Apollo Investment Fund VI, L.P. 2005 250,000,000.00 223,631,433.01 32,503,787.00 7.85 Apollo Investment Fund VII, L.P. 2008 350,000,000.00 221,516,694.61 53,058,761.39 21.38 ARCH Venture Fund VI, L.P. 2003 30,000,000.00 28,800,000.01 1,215,258.00 9.27 Atria Private Equity Fund III FC PR 2006 41,958,201.12 26,512,627.69 0.00 (9.50) Austin Ventures V, L.P. 1997 15,000,000.00 15,000,000.00 28,918,231.57 31.18 Austin Ventures VI, L.P. 1998 22,000,000.00 22,000,000.00 11,335,024.14 (6.37) Avenue Special Situations Fund V, LP 2007 250,000,000.00 250,000,000.00 308,350,668.00 11.25 Bain Capital Coinvest Fund X, L.P. 2007 50,000,000.00 12,250,000.00 169,578.00 (10.15) Bain Capital Fund IX, L.P. 2006 100,000,000.00 97,250,000.00 19,409,680.00 3.68 Bain Capital Fund X, L.P. 2007 400,000,000.00 302,000,000.00 35,663,837.00 (0.61) Bain Capital IX Coinvest Fund, LP 2006 50,000,000.00 48,500,000.00 18,223,733.00 8.94 Bain Capital Asia Fund, L.P. 2007 25,000,000.00 23,187,500.00 5,716,134.00 4.53 BC European Capital IX 2011 282,296,827.37 31,092,970.76 243,710.86 (12.98) BC European Capital VIII, L.P. 2005 611,613,851.63 570,264,573.41 219,864,742.10 6.85 BC Partners VII, L.P. 2000 323,203,188.55 323,203,188.54 803,514,181.28 23.98 BCI Growth IV, L.P. 1996 25,000,000.00 25,000,021.49 15,212,872.61 (5.44) Blackstone Capital Partners II, L.P. 1993 81,834,000.00 76,029,993.19 170,626,035.57 33.89 Blackstone Capital Partners III, L.P. 1997 323,945,000.00 305,141,241.39 611,744,743.63 14.54 Blackstone Capital Partners IV, L.P. 2001 215,000,000.00 179,118,342.70 319,305,253.21 37.79 Blackstone Capital Partners V, L.P. 2005 1,738,000,000.00 1,539,002,896.41 182,132,273.73 2.02 Blackstone Capital Partners VI, L.P. 2008 322,100,000.00 38,542,496.19 0.00 (23.48) Blackstone Capital Partners, II L.P.-2nd 1999 9,294,000.00 8,691,131.67 18,685,371.43 44.38 Blackstone Communications Partners I, LP 2000 275,000,000.00 249,899,684.90 234,340,639.64 6.15 Blackstone - GSO Capital Solutions LP 2009 250,000,000.00 157,031,016.00 19,083,896.00 13.88 Blue Run Ventures IV, L.P. 2008 23,595,506.00 14,865,168.19 3,943,323.19 28.49 Blue Run Ventures, L.P. 2005 31,415,730.00 28,902,471.84 10,052,556.83 2.08 Boston Ventures V, L.P. 1996 90,000,000.00 86,872,281.01 93,621,709.58 2.85 CalSTRS/B of A Capital Access Fund III 2006 200,000,000.00 118,739,282.26 4,085,989.28 (0.11) CalSTRS/B of A Capital Access Partners 2003 75,000,000.00 57,822,678.19 12,447,986.97 (2.21) CalSTRS/BOA/ML Cap Access LLC Fund IV 2010 200,000,000.00 12,210,656.21 0.00 (41.69) CalSTRS New&Next Gen. Manager Fund II 2008 216,947,782.00 75,517,990.21 0.00 3.64 * The limited partnership record keeping, including the internal rate of return or IRR, is maintained internally by CalSTRS for each limited partnership. The CalSTRS’ IRR calculation method may differ from calculation methods used by the General Partner or other Limited Partners. Differences in IRR calculations can be affected by cash flow timing, the account treatment of carried interest, partnership management fees, advisory fees, organization fees, other partnership expenses, sale of distributed stock and valuations. Importantly, there is no industry-standardized method for valuation or reporting, which makes comparisons of these numbers difficult. Additionally, the purchase of secondary interests makes for unique comparison problems due to the specific pricing and timing characteristics of the transaction when contrasted with the Limited Partnership Investment. Until a partnership is liquidated, typically over 10 to 12 years, the IRR is only an interim estimated return. The IRR calculated for partnerships in the first three years of a partnership life are particularly not meaningful. The actual IRR performance of any limited partnership is not known until the final liquidation. Finally, please note, none of the information contained herein has been reviewed or approved by the General Partners of the Funds. California State Teachers' Retirement System Private Equity Portfolio Performance March 31, 2012 CalSTRS Since Vintage Capital Inception Description Year Capital Committed Capital Contributed Distributed IRR* CalSTRS New&Next Generation Manager Fund 2005 105,645,634.00 70,959,172.79 4,654,972.00 6.11 Carlyle Europe Partners III, L.P. 2007 525,610,330.82 406,268,953.57 18,203,360.27 (0.43) Carlyle Partners IV, L.P. 2005 100,000,000.00 96,229,729.00 68,087,994.00 12.96 Carlyle Partners V, L.P. 2007 500,000,000.00 322,857,685.00 69,545,350.00 9.14 Carlyle/Riverstone Renew Energy Infrast 2006 50,000,000.00 49,681,484.98 4,535,974.00 (21.72) CVI Global Value Fund, LP 2007 196,000,000.00 186,200,000.00 49,681,889.69 3.61 Centerbridge Capital Partners II, L.P. 2011 225,000,000.00 59,255,483.00 0.00 (7.73) Centerbridge Capital Partners, L.P. 2006 150,000,000.00 132,122,464.13 88,668,720.00 20.97 Centerbridge Special Credit Partners 2009 250,000,000.00 237,500,000.00 0.00 16.19 Centerbridge Special Credit Partners II 2012 250,000,000.00 25,000,000.00 0.00 (0.01) Cerberus Institutional (INTL) Series 1 2008 151,410,000.00 82,817,051.61 0.00 (0.68) Cerberus Institutional (Series Four) LP 2007 500,000,000.00 461,721,438.42 79,927,472.09 6.84 Cerberus Institutional (Series Three) 2003 100,000,000.00 81,000,000.00 86,306,175.46 12.84 CGW Southeast Partners IV 1999 40,000,000.00 34,831,657.85 52,536,992.79 8.44 Charterhouse Capital VIII, L.P. 2006 136,918,845.85 117,984,548.19 3,223,328.35 (2.25) Chisholm Partners IV, L.P. 1999 29,500,000.00 28,981,412.23 28,991,848.90 0.61 Clayton, Dubilier & Rice Fund VII, L.P. 2004 100,000,000.00 91,260,942.00 30,727,698.00 8.75 Clearstone Venture Partners III-A, L.P.
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  • SUBMITTED VIA COURIER August 20, 2012 David A. Stawick Secretary

    SUBMITTED VIA COURIER August 20, 2012 David A. Stawick Secretary

    SUBMITTED VIA COURIER August 20, 2012 David A. Stawick Secretary of the Commission Commodity Futures Trading Commission Three Lafayette Centre 1155 21st Street, N.W. Washington, D.C. 20581 Re: CFTC, Notice of Proposed Rulemaking on Aggregation, Position Limits for Futures and Swaps (RIN 3038-AD82) Dear Mr. Stawick: This letter is submitted by the Private Equity Growth Capital Council (“PEGCC”, “we” or “us”, as applicable) to supplement our comment letter, dated as of June 29, 2012 (“Initial Letter”), that was made in response to the above-referenced Notice of Proposed Rulemaking on Aggregation, Position Limits for Futures and Swaps (the “Proposing Release”) issued by the Commodity Futures Trading Commission (“CFTC” or “Commission”). The PEGCC is an advocacy, communications and research organization established to develop, analyze and distribute information about the private equity and growth capital investment industry and its contributions to the national and global economy.1 We appreciate the opportunity to supplement our Initial Letter. All capitalized terms used but not defined herein should be read as having the meanings assigned to them in our Initial Letter. As discussed in our Initial Letter, we believe that the Non-Majority Investment Exemption should be expanded to permit, in appropriate circumstances, disaggregation notwithstanding an investment that exceeds 50 percent. Because the proposed exemption would be limited to non-majority investments, the exemption would not be available with respect to 1 Established in 2007, and formerly known as the Private Equity Council, the PEGCC is based in Washington, D.C. The PEGCC’s members are 36 of the world’s leading private equity and growth capital firms united by their commitment to growing and strengthening the businesses in which they invest.