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AXIA Energia (AXIAY) director juggles buys and sales in August 21 trade

(High)
(Neutral)
Form Type
4

Rhea-AI Filing Summary

AXIA Energia S.A. (AXIAY) reported insider activity involving director Pedro Batista de Lima Filho through investment vehicles managed by Radar Gestora de Recursos Ltda. On 2026-08-21, entities associated with him purchased 67,800 Class "C" preferred shares, which automatically convert into Common Shares at a 1:1 ratio, in stages from 2026 to 2031. The same day, those managed accounts sold 67,100 Common Shares. Prices for the sales and purchases are reported as weighted average prices of BRL 52.12 per Common Share sold and about BRL 51.68–51.69 per preferred share purchased, each converted to U.S. dollars using a BRL/USD rate of 5.1740. Following these transactions, Filho is reported as directly holding 51,115 Common Shares, while he and the related entities each disclaim beneficial ownership of the managed-account positions except to the extent of their pecuniary interest.

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Insider Batista de Lima Filho Pedro
Role Director
Bought 67,800 shs ($677K)
Sold 67,100 shs ($676K)
Type Security Shares Price Value
Purchase Class "C" Preferred Shares F8, F9, F2 29,400 $9.99 $294K
Purchase Class "C" Preferred Shares F8, F9, F3 15,900 $9.99 $159K
Purchase Class "C" Preferred Shares F8, F10, F4 1,200 $9.99 $12K
Purchase Class "C" Preferred Shares F8, F9, F5 1,700 $9.99 $17K
Purchase Class "C" Preferred Shares F8, F9, F6 10,300 $9.99 $103K
Purchase Class "C" Preferred Shares F8, F9, F7 9,300 $9.99 $93K
Sale Common Shares F1, F2 29,000 $10.07 $292K
Sale Common Shares F1, F3 15,700 $10.07 $158K
Sale Common Shares F1, F4 3,000 $10.07 $30K
Sale Common Shares F1, F5 1,700 $10.07 $17K
Sale Common Shares F1, F6 8,500 $10.07 $86K
Sale Common Shares F1, F7 9,200 $10.07 $93K
holding Common Shares -- -- --
Holdings After Transaction: Class "C" Preferred Shares — 9,994,629 shares (Indirect, By managed account); Common Shares — 4,860,084 shares (Indirect, By managed account); Common Shares — 51,115 shares (Direct)
Footnotes (10)
  1. F1. The price reported in column 4 is a weighted average price. The reporting person undertakes to provide to AXIA Energia S.A. (the "Company"), any security holder of the Company, or the staff of the Securities and Exchange Commission (the "SEC"), upon request, full information regarding the number of shares sold at each separate price. The weighted average price, $52.12 Brazilian reals ("BRL") per share, has been converted to U.S. dollars ("USD") using the U.S. Department of the Treasury Bureau of the Fiscal Service Treasury Reporting Rates of Exchange as of June 30, 2026 (the most recently published quarterly rate at the time of filing), at a rate of 5.1740 BRL per USD (fiscaldata.treasury.gov). Brokerage commissions and other costs of execution, if any, are excluded from the reported price.
  2. F2. Pedro Batista de Lima Filho ("Mr. Filho") is a partner at Radar Gestora de Recursos Ltda. ("Radar Gestora"), which is responsible for the portfolio management of MALIKO INVESTMENTS LLC - BANCO BTG PACTUAL S/A ("Maliko") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Maliko. For the purposes of this filing, each of Maliko and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Maliko or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Securities Exchange Act of 1934, as amended (the "Exchange Act"), or otherwise.
  3. F3. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of MANUKA INVESTMENTS LLC - BANCO BTG PACTUAL S/A ("Manuka") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Manuka. For the purposes of this filing, each of Manuka and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Manuka or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Exchange Act, or otherwise.
  4. F4. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of TUCURUI MASTER FUNDO DE INVESTIMENTO FINANCEIRO EM ACOES ("Tucurui") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Tucurui. For the purposes of this filing, each of Tucurui and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Tucurui or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Exchange Act, or otherwise.
  5. F5. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of XINGO MASTER FUNDO DE INVESTIMENTO FINANCEIRO DE ACOES ("Xingo") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Xingo. For the purposes of this filing, each of Xingo and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Xingo or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Exchange Act, or otherwise.
  6. F6. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of RADAR MASTER FUNDO DE INVESTIMENTO FINANCEIRO EM ACOES ("Radar") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Radar. For the purposes of this filing, each of Radar and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Radar or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Exchange Act, or otherwise.
  7. F7. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of INFRAD MASTER FUNDO DE INVESTIMENTO FINANCEIRO EM ACOES ("Infrad") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Infrad. For the purposes of this filing, each of Infrad and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Infrad or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Exchange Act, or otherwise.
  8. F8. Pursuant to Article 11 of the Bylaws of the Company, the class "C" preferred shares ("PNC Shares") shall be automatically converted into Common Shares, assuming such PNC Shares are not earlier mandatorily redeemed by the Company in accordance with its Bylaws, at a ratio of 1:1, as follows: 4% of the total volume of originally-issued PNC Shares, allocated proportionally among all holders, in each of the fiscal years 2026, 2027, 2028, 2029 and 2030; and all PNC Shares remaining, in fiscal year 2031.
  9. F9. The price reported in column 4 is a weighted average price. The reporting person undertakes to provide to the Company, any security holder of the Company, or the staff of the SEC, upon request, full information regarding the number of shares purchased at each separate price. The weighted average price, $51.68 BRL per share, has been converted to USD using the U.S. Department of the Treasury Bureau of the Fiscal Service Treasury Reporting Rates of Exchange as of June 30, 2026 (the most recently published quarterly rate at the time of filing), at a rate of 5.1740 BRL per USD (fiscaldata.treasury.gov). Brokerage commissions and other costs of execution, if any, are excluded from the reported price.
  10. F10. The price reported in column 4 is a weighted average price. The reporting person undertakes to provide to the Company, any security holder of the Company, or the staff of the SEC, upon request, full information regarding the number of shares purchased at each separate price. The weighted average price, $51.69 BRL per share, has been converted to USD using the U.S. Department of the Treasury Bureau of the Fiscal Service Treasury Reporting Rates of Exchange as of June 30, 2026 (the most recently published quarterly rate at the time of filing), at a rate of 5.1740 BRL per USD (fiscaldata.treasury.gov). Brokerage commissions and other costs of execution, if any, are excluded from the reported price.
Shares purchased (Class "C" preferred) 67,800 shares Total derivative-type purchases on 2026-08-21, each corresponding to 1 Common Share
Shares sold (Common Shares) 67,100 shares Total non-derivative sales on 2026-08-21 through managed accounts
Net share change 700 shares Net difference between purchased Class "C" preferred shares and Common Shares sold
Weighted average sale price BRL 52.12 per share Weighted average price for Common Shares sold, converted using 5.1740 BRL per USD
Weighted average purchase prices BRL 51.68–51.69 per share Weighted average prices for Class "C" preferred shares purchased, using 5.1740 BRL per USD
FX rate used 5.1740 BRL per USD Treasury Reporting Rates of Exchange as of June 30, 2026, used for conversions
Direct Common Shares held 51,115 shares Direct holdings of Common Shares reported after the transactions
Automatic conversion schedule 4% per year 2026–2030; remaining in 2031 Schedule for automatic conversion of Class "C" preferred into Common Shares
weighted average price financial
"The price reported in column 4 is a weighted average price."
Weighted average price is the average price of a security where each trade or component is counted according to its size, so bigger trades pull the average more than smaller ones. Think of it like calculating the average cost of a grocery haul where items you bought more of have greater influence on the final per-item cost. Investors use it to understand the true average price paid or received, judge execution quality, and compare trading performance against market movement.
pecuniary interest financial
"disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest"
beneficial ownership regulatory
"disclaims beneficial ownership of the reported securities except to the extent"
Beneficial ownership means the person or entity that actually enjoys the benefits of owning shares or other assets — such as receiving dividends, voting rights, or price gains — even if the legal title is held in another name. For investors it matters because knowing who truly controls and profits from a company reveals who can influence decisions, exposes potential conflicts of interest or hidden concentration of power, and affects transparency and risk in the stock.
Treasury Reporting Rates of Exchange financial
"using the U.S. Department of the Treasury Bureau of the Fiscal Service Treasury Reporting Rates of Exchange"
class "C" preferred shares financial
"the class "C" preferred shares ("PNC Shares") shall be automatically converted"
automatically converted financial
"PNC Shares shall be automatically converted into Common Shares, assuming such PNC Shares"

FAQ

What insider trading activity was reported for AXIAY on August 21, 2026?

On 2026-08-21, investment vehicles associated with director Pedro Batista de Lima Filho purchased 67,800 Class "C" preferred shares of AXIA Energia S.A. and sold 67,100 Common Shares, resulting in a small net increase in exposure equivalent to 700 shares.

At what prices were AXIA Energia (AXIAY) shares bought and sold in this Form 4?

The Common Shares sold had a weighted average price of BRL 52.12 per share. The Class "C" preferred shares purchased had weighted average prices of about BRL 51.68–51.69 per share. All figures were converted to U.S. dollars using a 5.1740 BRL/USD rate.

How many AXIA Energia (AXIAY) shares does Pedro Batista de Lima Filho hold directly after these transactions?

After the reported trades, Pedro Batista de Lima Filho is shown as directly holding 51,115 Common Shares of AXIA Energia S.A. Indirect holdings through managed accounts are reported separately, with beneficial ownership disclaimed except for any pecuniary interest.

What happened with AXIA Energia (AXIAY) Class "C" preferred shares in this filing?

Entities associated with the director bought 67,800 Class "C" preferred shares, each corresponding to 1 Common Share on conversion. Under the bylaws, 4% of originally issued preferred shares convert each year from 2026–2030, with remaining shares converting in 2031.

Are the AXIA Energia (AXIAY) transactions made under a Rule 10b5-1 trading plan?

No. The filing indicates the Rule 10b5-1 checkbox is not affirmed, and the footnotes do not state that the transactions were made pursuant to a Rule 10b5-1 or other pre-arranged trading plan.

Who actually owns the AXIA Energia (AXIAY) shares reported in the managed accounts?

The shares are held in accounts or funds such as Maliko, Manuka, Tucurui, Xingo, Radar, and Infrad, managed by Radar Gestora. The filing states that each entity and Mr. Filho disclaim beneficial ownership except to the extent of their pecuniary interest.

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SEC Form 4
FORM 4UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940
OMB APPROVAL
OMB Number:3235-0287
Estimated average burden
hours per response:0.5
Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).
Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.
1. Name and Address of Reporting Person*
Batista de Lima Filho Pedro

(Last)(First)(Middle)
AVENIDA GRACA ARANHA, NO. 26
CENTRO

(Street)
RIO DE JANEIRO20030-000

(City)(State)(Zip)

BRAZIL

(Country)
2. Issuer Name and Ticker or Trading Symbol
AXIA Energia S.A. [ AXIA3 ]
5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)
XDirector10% Owner
Officer (give title below)Other (specify below)
2a. Foreign Trading Symbol
[AXIA7]
3. Date of Earliest Transaction (Month/Day/Year)
08/21/2026
6. Individual or Joint/Group Filing (Check Applicable Line)
XForm filed by One Reporting Person
Form filed by More than One Reporting Person
4. If Amendment, Date of Original Filed (Month/Day/Year)

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3) 2. Transaction Date (Month/Day/Year)2A. Deemed Execution Date, if any (Month/Day/Year)3. Transaction Code (Instr. 8) 4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5) 5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4) 6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4) 7. Nature of Indirect Beneficial Ownership (Instr. 4)
CodeVAmount(A) or (D)Price
Common Shares08/21/2026S29,000D$10.07(1)13,785,919IBy managed account(2)
Common Shares08/21/2026S15,700D$10.07(1)6,898,017IBy managed account(3)
Common Shares08/21/2026S3,000D$10.07(1)347,885IBy managed account(4)
Common Shares08/21/2026S1,700D$10.07(1)472,409IBy managed account(5)
Common Shares08/21/2026S8,500D$10.07(1)4,474,319IBy managed account(6)
Common Shares08/21/2026S9,200D$10.07(1)4,860,084IBy managed account(7)
Common Shares51,115D
Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned
(e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3) 2. Conversion or Exercise Price of Derivative Security 3. Transaction Date (Month/Day/Year)3A. Deemed Execution Date, if any (Month/Day/Year)4. Transaction Code (Instr. 8) 5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5) 6. Date Exercisable and Expiration Date (Month/Day/Year)7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4) 8. Price of Derivative Security (Instr. 5) 9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4) 10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4) 11. Nature of Indirect Beneficial Ownership (Instr. 4)
CodeV(A)(D)Date ExercisableExpiration DateTitleAmount or Number of Shares
Class "C" Preferred Shares(8)08/21/2026P29,400 (8) (8)Common Shares29,400$9.99(9)4,982,851IBy managed account(2)
Class "C" Preferred Shares(8)08/21/2026P15,900 (8) (8)Common Shares15,900$9.99(9)1,775,038IBy managed account(3)
Class "C" Preferred Shares(8)08/21/2026P1,200 (8) (8)Common Shares1,200$9.99(10)78,740IBy managed account(4)
Class "C" Preferred Shares(8)08/21/2026P1,700 (8) (8)Common Shares1,700$9.99(9)91,209IBy managed account(5)
Class "C" Preferred Shares(8)08/21/2026P10,300 (8) (8)Common Shares10,300$9.99(9)1,611,453IBy managed account(6)
Class "C" Preferred Shares(8)08/21/2026P9,300 (8) (8)Common Shares9,300$9.99(9)1,455,338IBy managed account(7)
Explanation of Responses:
1. The price reported in column 4 is a weighted average price. The reporting person undertakes to provide to AXIA Energia S.A. (the "Company"), any security holder of the Company, or the staff of the Securities and Exchange Commission (the "SEC"), upon request, full information regarding the number of shares sold at each separate price. The weighted average price, $52.12 Brazilian reals ("BRL") per share, has been converted to U.S. dollars ("USD") using the U.S. Department of the Treasury Bureau of the Fiscal Service Treasury Reporting Rates of Exchange as of June 30, 2026 (the most recently published quarterly rate at the time of filing), at a rate of 5.1740 BRL per USD (fiscaldata.treasury.gov). Brokerage commissions and other costs of execution, if any, are excluded from the reported price.
2. Pedro Batista de Lima Filho ("Mr. Filho") is a partner at Radar Gestora de Recursos Ltda. ("Radar Gestora"), which is responsible for the portfolio management of MALIKO INVESTMENTS LLC - BANCO BTG PACTUAL S/A ("Maliko") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Maliko. For the purposes of this filing, each of Maliko and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Maliko or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Securities Exchange Act of 1934, as amended (the "Exchange Act"), or otherwise.
3. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of MANUKA INVESTMENTS LLC - BANCO BTG PACTUAL S/A ("Manuka") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Manuka. For the purposes of this filing, each of Manuka and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Manuka or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Exchange Act, or otherwise.
4. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of TUCURUI MASTER FUNDO DE INVESTIMENTO FINANCEIRO EM ACOES ("Tucurui") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Tucurui. For the purposes of this filing, each of Tucurui and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Tucurui or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Exchange Act, or otherwise.
5. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of XINGO MASTER FUNDO DE INVESTIMENTO FINANCEIRO DE ACOES ("Xingo") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Xingo. For the purposes of this filing, each of Xingo and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Xingo or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Exchange Act, or otherwise.
6. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of RADAR MASTER FUNDO DE INVESTIMENTO FINANCEIRO EM ACOES ("Radar") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Radar. For the purposes of this filing, each of Radar and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Radar or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Exchange Act, or otherwise.
7. Mr. Filho is a partner at Radar Gestora, which is responsible for the portfolio management of INFRAD MASTER FUNDO DE INVESTIMENTO FINANCEIRO EM ACOES ("Infrad") and receives a performance-based compensation in his capacity as a partner of Radar Gestora. Mr. Filho may be deemed to indirectly beneficially own these shares by virtue of its relationship with Infrad. For the purposes of this filing, each of Infrad and Mr. Filho disclaims beneficial ownership of the reported securities except to the extent of his or its pecuniary interest therein. This filing shall not be deemed an admission that Infrad or Mr. Filho is the beneficial owner of any of the reported securities for purposes of Section 16 of the Exchange Act, or otherwise.
8. Pursuant to Article 11 of the Bylaws of the Company, the class "C" preferred shares ("PNC Shares") shall be automatically converted into Common Shares, assuming such PNC Shares are not earlier mandatorily redeemed by the Company in accordance with its Bylaws, at a ratio of 1:1, as follows: 4% of the total volume of originally-issued PNC Shares, allocated proportionally among all holders, in each of the fiscal years 2026, 2027, 2028, 2029 and 2030; and all PNC Shares remaining, in fiscal year 2031.
9. The price reported in column 4 is a weighted average price. The reporting person undertakes to provide to the Company, any security holder of the Company, or the staff of the SEC, upon request, full information regarding the number of shares purchased at each separate price. The weighted average price, $51.68 BRL per share, has been converted to USD using the U.S. Department of the Treasury Bureau of the Fiscal Service Treasury Reporting Rates of Exchange as of June 30, 2026 (the most recently published quarterly rate at the time of filing), at a rate of 5.1740 BRL per USD (fiscaldata.treasury.gov). Brokerage commissions and other costs of execution, if any, are excluded from the reported price.
10. The price reported in column 4 is a weighted average price. The reporting person undertakes to provide to the Company, any security holder of the Company, or the staff of the SEC, upon request, full information regarding the number of shares purchased at each separate price. The weighted average price, $51.69 BRL per share, has been converted to USD using the U.S. Department of the Treasury Bureau of the Fiscal Service Treasury Reporting Rates of Exchange as of June 30, 2026 (the most recently published quarterly rate at the time of filing), at a rate of 5.1740 BRL per USD (fiscaldata.treasury.gov). Brokerage commissions and other costs of execution, if any, are excluded from the reported price.
Remarks:
/s/ Pedro Batista de Lima Filho08/24/2026
** Signature of Reporting PersonDate
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 4 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.
* Form 4: SEC 1474 (03-26)