Anchorage Capital Advisors, L.P.

If you manage client assets, disclose the amount of client assets you manage on a discretionary basis and the amount of client assets you manage on a nondiscretionary basis. Disclose the date “as of” which you calculated the amounts. As of December 31, 2025, the Advisors managed approximately $27.8 billion of regulatory assets under management on a discretionary basis. The Advisors do not currently manage any client assets on a non-discretionary basis.

ITEM 5 – FEES AND COMPENSATION Item 5.A

Describe how you are compensated for your advisory services. Provide your fee schedule. Disclose whether the fees are negotiable. The Advisors typically charge fees that are based upon a set percentage of assets under management and performance. Set forth below are summaries of the fees payable by Investors in the Funds. It should be noted that detailed disclosure about the fees and other expenses applicable to an investment in the Funds is provided in the relevant Fund’s confidential private placement memorandum, including any supplements, which are provided to prospective investors. Those governing documents should be carefully reviewed prior to making an investment in the Funds. Fee and related information for the Customized Funds are disclosed in their respective governing documents. Asset-based fees are generally charged monthly/quarterly in advance based on the value of the relevant assets as of the first day of the month/quarter. The range of annual asset-based fees in Funds other than the Structured Credit Vehicles and AMAC Funds is typically from 1.0% to 2.0% of each Investor’s assets with the applicable Fund. Annual asset-based fees in the AMAC Funds range between 0.40% to 0.60% of each Investor’s assets. In addition, consistent with the Investment Advisers Act of 1940, as amended ("Advisers Act") and Rule 205-3 thereunder to the extent applicable, the Advisors or their affiliates receive incentive allocations or performance fees from certain Advisory Clients generally based upon net profits allocable to each Investor. The performance allocation or performance fee payable to the Advisors or their affiliates generally ranges from 15% to 25% of the net profits allocable to a particular Investor. For certain Funds, the performance allocation is subject to a hurdle or preferred return rate. Fee arrangements for the Customized Funds are individually negotiated and set forth in their respective governing documents. With respect to the Structured Credit Vehicles, collateral management fees generally range from 0.45% to 0.55% per annum of the aggregate amount of collateral principal, defaulted obligations and accrued interest as described in the vehicle’s governing documents. The Advisors have effectively waived or reduced collateral management fees with respect to investments made by the Funds in instruments/notes issued by the Structured Credit Vehicles. The Advisors may also be entitled to receive an incentive collateral management fee which is payable only after an incentive management fee threshold has been met. Please see each vehicle’s governing documents for a description of the applicable incentive collateral management fee and incentive management fee threshold. The fees and performance allocations detailed above are negotiable in that the Advisors reserve the right to reduce, waive or calculate differently such fees and performance allocations for certain Investors. Partners, employees and certain affiliates of the Advisors currently invested in the Funds are not charged such fees or performance allocations.

Please also refer to Item 14 regarding Other Compensation. It is critical that Investors refer to their respective Fund’s governing documents for a complete understanding of how the Advisors are compensated for their advisory services. The information contained herein is a summary only and is qualified in its entirety by the relevant Fund governing documents. Item 5.B

Describe whether you deduct fees from clients’ assets or bill clients for fees incurred. If clients may select either method, disclose this fact. Explain how often you bill clients or deduct your fees. Other than for certain Customized Funds whose investors are billed directly, the Advisors (or an affiliate thereof) deduct fees from Investors’ assets invested in the Funds. Such Investors do not have the ability to choose to be billed directly for fees incurred. It is critical that Investors refer to their respective Fund’s governing documents for a complete understanding of how fees are deducted from their assets. The information contained herein is a summary only and is qualified in its entirety by the relevant Fund governing documents.

Item 5.C

Describe any other types of fees or expenses clients may pay in connection with your advisory services, such as custodian fees or mutual fund expenses. Disclose that clients will incur brokerage and other transaction costs, and direct clients to the section(s) of your brochure that discuss brokerage. In addition to management/performance fees payable to the Advisors, Advisory Clients (and, therefore, Investors therein) are also subject to other costs and expenses related to their respective activities. The following sets forth various examples of the types of costs and expenses that will generally be borne by Advisory Clients, subject to the terms of such Advisory Client's governing documents: The Drawdown Funds and the AMAC Funds generally pay, as applicable: • organizational expenses; • offering expenses, including legal and accounting expenses, placement fees, printing costs, travel and out-of-pocket expenses; • pro rata share of master fund expenses including all costs and expenses directly related to investments or prospective investments (whether or not consummated) such as external research fees and transaction costs (including travel and travel-related meals, legal and other advisory fees and expenses), interest and commitment fees on debit balances or borrowings, borrowing charges on investments sold short, custody fees, bank fees; bank service fees; amounts for taxes (except as otherwise determined by the Fund general partner, (the "General Partner") and any insurance policies associated with taxes; • costs of industry memberships;

costs and expenses of storage and delivery of physical commodities and insurance policies for such assets; costs of fulfilling the bonding requirement under ERISA, if applicable; all deal and access fees, whether paid to third-party managers or brokers, for transactions in which the Fund participates; expenses in connection with transactions directed to broker-dealers in part in recognition of investment research and information furnished or expenses for services rendered by broker-dealers in the execution of such orders and the use of such research and other services provided by such broker-dealers; investment expenses such as commissions and clearing fees; any amounts for taxes that are attributable to all or any of its Investors and are paid by, withheld by, or withheld from payments to, the Fund; any costs and expenses incurred in connection with compliance with applicable laws (including MiFID II (as defined in Item 8.B)), including governmental, regulatory, licensing, filing or registration fees, expenses or taxes incurred by the Fund (as determined by the General Partner), the General Partner or the Advisors in compliance with the rules of any selfregulatory organization or any U.S. federal, state or local or non-U.S. laws; to the extent permitted by applicable law, and subject to the indemnification/exculpation provisions in the applicable Fund Agreement or the Investment Management Agreement, any legal fees and costs (including settlement costs) arising in connection with any litigation or regulatory investigation instituted against the Fund, the General Partner or the Advisors, each in its capacity as such (whether incurred by the Fund or the General Partner or the Advisors on the Fund’s behalf); all (or such pro rata portion, as determined by the Advisors, of) fees and expenses related to any investment vehicle or wholly owned subsidiaries utilized to facilitate Fund investments (including legal, administrative, custodial, audit, registered office and other fees, rent, overhead and salary, to the extent that the assets of the Fund are not treated as “plan assets” for purposes of ERISA); including as it relates to the Fund’s nonU.S. investment vehicles (which may include the portion of salaries of employees of Anchorage or any affiliate thereof responsible for providing tax, accounting, legal, operational or settlement services relating to such investment vehicle(s) as may be reasonably determined and allocated by the Advisors), other expenses and/or a profit margin to such investment vehicle(s); fees and expenses (if any) associated with the Conflicts Advisory Board or any Limited Partner Advisory Committee; the cost of the audit of the Fund’s financial statements and the preparation of its tax returns; the fees and expenses for financial and tax accounting and reporting services; administrative services and other administrative expenses, including any administrator's fees, on behalf of the Fund to the extent performed by persons other than the General Partner or the Advisors;

the fees and expenses of counsel with respect to the Fund, including in connection with advice directly relating to the Funds’ legal affairs (such as lenders’ counsel for any credit facility); expenses incurred in connection with the admission of Investors or the acceptance of additional capital contributions or commitments (including expenses incurred in connection with side letters for prospective and existing Investors); all costs and expenses associated with reporting and providing information to existing and prospective Investors; the costs of any outside appraisers, accountants, attorneys, compliance consultants, due diligence experts, or other experts or advisers (for example, directors of an entity in which the Fund holds a direct or indirect interest, operating partners, consultants or similar roles, as well as public relations professionals retained to assist in maintaining the confidentiality of the Fund) engaged by the General Partner or the Advisors; costs and expenses in connection with operational risk management (including third party risk assessment, due diligence and ongoing monitoring); costs and expenses of treasury finance modules and trade management modules; the costs and expenses of holding any meetings of Investors; fees and expenses of the "partnership representative"; to the extent consistent with Section 410(b) of ERISA, if applicable, the costs of any liability insurance obtained on behalf of the Fund, the General Partner, the Advisors, the Anchorage principal(s), the senior portfolio managers, the affiliates of any of them and any other indemnified person; other expenses associated with the operation of the Fund as well as other expenses directly related to the Fund’s investment program, including any extraordinary expenses (such as litigation and indemnification); expenses incurred in obtaining and maintaining systems (including software, software-as-a-service, licenses, support and consulting), research and other information utilized for portfolio management purposes (including risk management) that facilitate portfolio management decisions, trading, compliance, treasury, operations, valuations, and accounting, including the costs of statistics and pricing services, independent securities valuation services, service contracts for quotation equipment and related hardware and software; and For the avoidance of doubt and without limitation, “research” as used in this section includes: communication with advisors, counsel, experts and consultants; research services; reports; publications; data; analysis; advice; conferences; and management and shareholder meetings, in each case relating to, without limitation, general or specific research topics relating to macroeconomic factors, trends, markets, geographic sectors, industries and particular companies, transactions and investments, regardless whether such transaction or investment is ultimately closed, acquired or completed. In general, the Funds bear their pro rata share of

expenses for research determined by the Advisors to be of a general nature or beneficial to the Advisors’ research in general. Structured Credit Vehicles: The Structured Credit Vehicles generally pay or reimburse the Advisors for expenses similar to the other Funds as described above, which include: (i) all expenses incurred in connection with the operation of the issuer, including, without limitation; (ii) organizational and offering expenses; (iii) costs and expenses incurred in connection with the acquisition or disposition of assets; (iv) costs and expenses incurred in carrying or management of assets; (v) any and all costs and expense incurred in connection with the vehicle’s notes, including, without limitation, fees and expenses of the rating agencies; (vi) any and all attorneys’, accountants’ and other experts’ fees and disbursements relating to the vehicle; and (vii) other expenses identified in the applicable collateral management agreement. Customized Funds: Customized Funds of the Advisors will pay or reimburse the Advisors for expenses that may vary from but are generally similar to the expenses paid by the other Funds as described above. The fees and expenses that will be borne by each Investor or Advisor Client with respect to the Customized Funds of the Advisors are described in the relevant governing documents for such Funds. It is critical that Investors refer to the relevant governing documents for a complete understanding of fees and expenses they may pay. The information contained herein is a summary only and is qualified in its entirety by such documents. Item 5.D

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If you charge advisory fees in addition to commissions or markups, disclose whether you reduce your advisory fees to offset the commissions or markups. Not applicable to the Advisors.

If you recommend primarily a particular type of security, explain the material risks involved. If the type of security involves significant or unusual risks, discuss these risks in detail. Please see the responses provided in Item 8.B. above.

ITEM 9 – DISCIPLINARY INFORMATION If there are legal or disciplinary events that are material to a client’s or prospective client’s evaluation of your advisory business or the integrity of your management, disclose all material facts regarding those events. Items 9.A, 9.B, and 9.C list specific legal and disciplinary events presumed to be material for this Item. If your advisory firm or a management person has been involved in one of these events, you must disclose it under this Item for ten years following the date of the event, unless: (1) the event was resolved in your or the management person’s favor, or was reversed, suspended or vacated; or (2) you have rebutted the presumption of materiality to determine that the event is not material. For purposes of calculating this tenyear period, the “date” of an event is the date that the final order, judgment, or decree was entered, or the date that any rights of appeal from preliminary orders, judgments or decrees lapsed. Items 9.A, 9.B, and 9.C do not contain an exclusive list of material disciplinary events. If your advisory firm or a management person has been involved in a legal or disciplinary event that is not listed in Items 9.A, 9.B, or 9.C, but nonetheless is material to a client's or prospective client's evaluation of your advisory business or the integrity of its management, you must disclose the event. Similarly, even if more than ten years have passed since the date of the event, you must disclose the event if it is so serious that it remains material to a client’s or prospective client’s evaluation. Item 9.A

A criminal or civil action in a domestic, foreign or military court of competent jurisdiction in which your firm or a management person 1.

was convicted of, or pled guilty or nolo contendere (“no contest”) to (a) any felony; (b) a misdemeanor that involved investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses;

2.

is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses;

3.

was found to have been involved in a violation of an investmentrelated statute or regulation; or

4.

was the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting, your firm or a management person from engaging in any investment-related activity, or from violating any investment-related statute, rule, or order

Not applicable to the Advisors.

Item 9.B

An administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which your firm or a management person 1.

was found to have caused an investment-related business to lose its authorization to do business; or

2.

was found to have been involved in a violation of an investmentrelated statute or regulation and was the subject of an order by the agency or authority (a)

denying, suspending, or revoking the authorization of your firm or a management person to act in an investment-related business;

(b)

barring or suspending your firm’s or a management person's association with an investment-related business;

(c)

otherwise significantly limiting your firm’s or a management person's investment-related activities; or

(d)

imposing a civil money penalty of more than $2,500 on your firm or a management person.

Not applicable to the Advisors.

Describe the types of clients to whom you generally provide investment advice, such as individuals, trusts, investment companies, or pension plans. If you have any requirements for opening or maintaining an account, such as a minimum account size, disclose the requirements. The Advisors provide discretionary investment advisory services including, but not limited to, managing and directing the investment and reinvestment of assets for the Funds and serving as investment manager or collateral manager to certain structured credit vehicles. Investors in the Funds, include, without limitation, pension funds, sovereign wealth funds, insurance companies, financial institutions, foundations, endowments, fund of funds, family offices, and high net worth individuals. Minimum initial investments for Funds generally range from $1,000,000 to $20,000,000, subject to the discretion of the general partner of the Fund. Customized Funds may be set up for certain Investors at the sole discretion of the Advisors and will be subject to individually negotiated terms. It is critical that Investors refer to their respective Fund’s governing documents for a complete understanding of each Fund’s requirements. The information contained herein is a summary only and is qualified in its entirety by the relevant Fund governing documents.

ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Item 8.A

Describe the methods of analysis and investment strategies you use in formulating investment advice or managing assets. Explain that investing in securities involves risk of loss that clients should be prepared to bear. METHODS OF ANALYSIS The Advisors utilize a variety of resources or services to form an investment idea or strategy. In general, the Advisors assess investment opportunities by employing a rigorous research process that may include, among others, fundamental credit analysis, detailed analysis of historical financial statements and development of financial projections, meetings with company management, industry research, including use of outside experts and alternative data, consultation with customers, suppliers and competitors, and analysis of documents (including credit agreements, bond indentures, intercreditor agreements, court filings), and use of outside legal counsel to determine validity and ranking of various claims. INVESTMENT STRATEGIES Drawdown Funds: The ACO Funds primarily invest on a long-only basis principally in the illiquid credit and asset markets of North America and Europe, in addition to other markets, provided, however, that such Funds’ investments may be concentrated in one or more of these regions with little or no allocation to the other regions. Such Funds may also make investments in debt (including dislocated debt), equity (including post-restructured equity) illiquid claims, structured credit, and other assets that appear to present a favorable risk-adjusted return profile based on fundamental credit research, structural review and analysis, differentiated asset sourcing, and assessment of managers/servicers. The ACO Funds may also invest in other cash and derivative instruments that are structured products predominantly linked to corporate and asset-backed credit risk. These Funds may also employ hedged investment and other strategies. The SCF Funds primarily invest in the primary issuance of subordinated notes (“equity”) and secured notes (“liabilities”) of collateralized debt obligation transactions and collateralized loan obligation transactions and warehouse facilities, that are managed by the Advisors. The SCF Funds may also opportunistically invest in other structured credit investments and may (but are under no obligation to) employ hedged investment strategies. Customized Funds: The Customized Funds may utilize different trading and/or investment strategies than the other Funds. Structured Credit Vehicles: The Structured Credit Vehicles consist primarily of a portfolio of senior secured bank loans, with an allowance for second lien loans, bonds, senior unsecured

loans, floating rate notes, and other obligations listed in the concentration limitations. AMAC Funds: The AMAC Funds invest primarily on a long-only basis in high yield fixed income instruments, as well as other U.S. and non-U.S. investments, including, but not limited to, structured credit, loans, and investment grade fixed income instruments. “High yield” refers to instruments that are rated below investment grade or, if unrated, determined by Anchorage to be below investment grade. “Fixed income instruments” include bonds, debt securities and other similar instruments issued by U.S. and non-U.S. public or private-sector entities. Investing in securities involves significant risks, including the risk of loss of some or all of an investment. Prospective investors should speak with their legal, tax, and financial advisors prior to making an investment with Anchorage.

Item 8.B

For each significant investment strategy or method of analysis you use, explain the material risks involved. If the method of analysis or strategy involves significant or unusual risks, discuss these risks in detail. If your primary strategy involves frequent trading of securities, explain how frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. It is critical that Investors refer to the relevant governing documents for a complete understanding of the methods of analysis and investment strategies of the Advisors. The information contained herein is a summary only and is qualified in its entirety by such documents. Use of Leverage The Advisors may utilize leverage for certain of the Funds. This may result in a Fund controlling substantially more assets than such Fund has equity. Leverage increases returns if a Fund earns a greater return on investments purchased with borrowed funds than the cost of borrowing such funds. However, the use of leverage exposes the Funds to additional levels of risk, including: (i) greater losses from investment than would otherwise have been the case had the Funds not borrowed to make the investments; (ii) margin calls or interim margin requirements which may force premature liquidations of investment positions; and (iii) losses on investments where the investment fails to earn a return that equals or exceeds the Funds’ cost of borrowing such funds. In the event of a sudden, precipitous drop in the value of the Funds’ assets, the Funds might not be able to liquidate assets quickly enough to repay its borrowings, further magnifying losses. Analysis and Risk The investment strategy to be utilized by the Advisors may require accurate and detailed analysis of issuers, counterparties, suppliers, service providers and commodity end-users. There can be no assurance that the analysis of the Advisors will be accurate or complete. The Funds may be subject to substantial losses in

the event of credit deterioration or bankruptcy of one or more issuers, counterparties, suppliers, service providers and commodity end-users. While the Funds may hedge credit risk, there can be no assurance that such hedges will be established or, if established, that the hedges will offset losses. Alternative Data Collection and Use The Advisors may rely on “alternative data” from non-traditional sources. Such alternative data may include, for example, social media data, consumer financial transaction data, web traffic, supply chain analysis, search trends, digital footprint data, satellite imagery or weather data. The Advisors may collect and process certain alternative data itself and/or may rely on various third-party data providers. The risks associated with traditional market data generally apply to alternative data, and the use of alternative data exacerbates certain of those risks (including those related to quality control and data integrity). In addition, the applicability of existing laws and regulations to the collection and use of alternative data is uncertain, and new regulations may be adopted in the future. These risks and uncertainties may have an adverse effect on the ability of the Advisors to implement their strategies successfully. Cybersecurity, Information Security and Systems Risk The Advisors rely on information and communications systems, internal controls and third-party service providers to conduct portfolio management, trading, valuation, accounting, cash management, reporting, investor communications and other operations. The Advisors, the Funds and their counterparties, administrators, custodians, prime brokers, lenders, pricing services, issuers and other service providers are subject to risks arising from cybersecurity incidents, data breaches and other technology failures. Such events may result from unauthorized access, malware, ransomware, phishing, denial-of-service attacks, insider misconduct, operational errors or other events and may lead to the loss, misuse, corruption or unauthorized disclosure of confidential, proprietary or personal information, or to disruptions in trading, valuation, settlement, reporting or other business activities. The Funds may also be adversely affected by such events at issuers, portfolio companies and other market participants. Any such event may cause substantial losses, remediation costs, regulatory scrutiny, litigation, reputational harm and other liabilities. Although the Advisors maintain business continuity and information security policies and procedures, there can be no assurance that such measures will be effective or that the Funds will not be adversely affected by cybersecurity incidents or other systems failures affecting the Advisors, the Funds or third parties. Trend Following Certain trading decisions made by the Advisors may be based on trend following. Any factor that would lessen the prospect of major trends occurring in the future (such as increased governmental control of, or participation in, the financial markets) may reduce the prospect that a particular trading method or strategy will be profitable in the future. In the past, there have been periods without discernible trends and, presumably, such periods will continue to occur in the future. Moreover, any factor that would make it more difficult to execute trades at desired prices in accordance with the signals of the trading method or strategy (such as a significant lessening of liquidity in a particular market) would also be detrimental

to profitability. Further, many managers’ trading methods utilize similar analyses in making trading decisions. Therefore, bunching of buy and sell orders can occur, which makes it more difficult for a position to be taken or liquidated. Government Intervention in the Credit Markets The central banks and, in particular, the U.S. Federal Reserve (the “Fed”), have taken unprecedented steps in recent years, including in response to the COVID19 crisis, to intervene and decrease volatility in the credit markets. Because certain investment strategies of the Advisors seek to capitalize on opportunities in volatile credit markets, the success of the Funds may rely, at least in part, on such volatility. In light of recent market events, it has become increasingly more difficult to predict if, how, and to what extent the United States and other governments may further intervene in the credit markets. Such intervention is prompted by politically sensitive issues involving family homes, student loans, small businesses, real estate speculation, credit card receivables, etc., and may, as a result, be contrary to what the Advisors would predict from an “economically rational” perspective. On the contrary, recent governmental intervention may mean that the willingness of governmental bodies to take additional extraordinary action may be diminished. In the event of a major market disruption in the near future, limited additional government intervention may result in correspondingly greater market dislocation and materially greater market risk and/or volatility. Given the uncertainty of how governments will respond to various market events, especially in the near term with the Fed raising of interest rates to combat high inflation, market participants, including the Advisors, may be unable to predict market volatility during the next economic cycle or in the event of a future market disruption. Concerns Regarding a Downgrade of the U.S. Credit Rating For various reasons, financial services companies have in the past and may in the future lower their long term sovereign credit rating on the United States. Any such downgrade could have material adverse impacts on financial markets and economic conditions in the U.S. and throughout the world and, in turn, the market’s anticipation of these impacts could have a material adverse effect on a Fund’s financial condition and liquidity. The ultimate impacts on global markets and a Fund’s business, financial condition, and liquidity are unpredictable and may not be immediately apparent. Force Majeure Risk Investments may be affected by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fire, flood, earthquakes, outbreaks of an infectious disease, pandemic or any other serious public health concern, war, terrorism, and labor strikes). Some force majeure events may adversely affect the ability of a party (including an investment or a counterparty to the Funds or an investment) to perform its obligations until it is able to remedy the force majeure event. Certain force majeure events (such as war or an outbreak of an infectious disease) could have a broader negative impact on the world economy and international

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If you or any of your supervised persons accepts performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle) – disclose this fact. If you or any of your supervised persons manage both accounts that are charged a performance-based fee and accounts that are charged another type of fee, such as an hourly or flat fee or an asset-based fee, disclose this fact. Explain the conflicts of interest that you or your supervised persons face by managing these accounts at the same time, including that you or your supervised persons have an incentive to favor accounts for which you or your supervised persons receive a performance-based fee, and describe generally how you address these conflicts. As described in Item 5.A above, the Advisors (or affiliates thereof) receive performance-based allocations or fees from certain Advisory Clients. Where each Fund managed by the Advisors pays performance-based compensation, it should be noted that the Advisors reserve the right to reduce, waive or calculate differently such fees for certain Investors. Such reductions, waivers and calculations could result in the Funds paying performance-based fees at varying overall rates and create an incentive for the Advisors to disproportionately allocate the best opportunities to Funds that pay the highest rates of performance based fees. The Advisors are committed to allocating investment opportunities on a fair and equitable basis and have established policies and procedures to address the conflicts of interest described above. In addition, the Advisors (or affiliates thereof) ability to receive performance-based allocations or fees creates a potential conflict of interest in that it may create an incentive to make investments that are riskier or more speculative than in the absence of such a performance-based allocation or fee. Investors are provided with clear disclosure as to how a performance-based allocation or fee is charged with respect to a particular Fund and the risks associated with such performance-based allocation or fee prior to making an investment. In addition, in situations where the assets of Funds are used to purchase the equity, and other securities issued by Structured Credit Vehicles that the Advisors (or their affiliates) manage in return for fees for acting as collateral manager, the Advisors generally reduce or waive, rebate, pay or otherwise transfer to the particular investing Fund any fees to which it would otherwise be entitled as collateral manager with respect to the portion of the Structured Credit Vehicle’s equity purchased by such Fund, but will be reimbursed for any of its out-of-pocket expenses incurred in the establishment of the Structured Credit Vehicle and in its on-going operations, and is indemnified for certain losses in connection with its role as collateral manager. Nevertheless, such investments involve conflicts of interest inasmuch as such investments by the Fund may enable the Advisors to act as collateral manager of a Structured Credit Vehicle and earn fees from investments in such vehicle to the extent third parties are invested in the equity of such vehicle during or after the time the Funds are invested in such vehicle. Such fees may be greater than those paid by the Funds with respect to such Structured Credit Vehicles. Thus, there are conflicts with respect to the decision of whether or when to cause the Funds to sell equity they hold in any Advisor-managed Structured Credit Vehicles to a third party because the Advisors would then earn collateral management fees with respect to the equity sold. There are conflicts with respect to the decision of whether to cause the Funds to purchase equity in any Advisor-managed Structured Credit Vehicles since the Advisors would not earn collateral management fees with respect to such equity. Please also see Item 11 for a discussion of such conflicts.

Each Advisor recognizes that it is a fiduciary and as such must act in the best interests of the Funds and Investors. Further, each Advisor recognizes that it must treat all clients fairly and must refrain from favoring one client’s interests over another’s.

If you recommend or select other investment advisers for your clients and you receive compensation directly or indirectly from those advisers that creates a material conflict of interest, or if you have other business relationships with those advisers that create a material conflict of interest, describe these practices and discuss the material conflicts of interest these practices create and how you address them. Not applicable to the Advisors.

ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Item 11.A

If you are an SEC-registered adviser, briefly describe your code of ethics adopted pursuant to SEC rule 204A-1 or similar state rules. Explain that you will provide a copy of your code of ethics to any client or prospective client upon request. The Code of Ethics of the Advisors (the “Code”) is designed to meet the requirements of Rule 204A-1 of the Advisers Act. The Code applies to “Access Persons” of the Advisors (which term includes all employees that perform duties for the Advisors) and sets forth a standard of business conduct that takes into account the status of each Advisor as a fiduciary and requires Access Persons to place the interests of Advisory Clients and Investors above their own interests. The Code requires Access Persons to comply with applicable federal securities laws. Further, Access Persons are required to promptly bring violations of the Code to the attention of the Chief Compliance Officer. All Access Persons are provided with a copy of the Code and are required to acknowledge receipt of the Code on at least an annual basis. The Code also sets forth certain reporting and pre-clearance requirements with respect to personal trading by Access Persons. Advisors’ Access Persons must provide the Chief Compliance Officer with a list of their personal accounts and an initial holdings report within 10 days of becoming an Access Person. In addition, Advisors’ Access Persons must provide annual holdings reports and quarterly transaction reports in accordance with Rule 204A-1. In addition, the Code ensures the protection of nonpublic information about the activities of the Funds. Investors or prospective investors may obtain a copy of the Code by contacting the Chief Compliance Officer, Joel Koerner, at (212) 4324600 or by email at Joel.Koerner@anchoragecapital.com.

Item 11.B

If you or a related person recommends to clients, or buys or sells for client accounts, securities in which you or a related person has a material financial interest, describe your practice and discuss the conflicts of interest it presents. Describe generally how you address conflicts that arise. As explained in Item 10 above, the Advisors serve as the investment managers to the Funds and as such offers interests in the Funds to prospective investors. The Advisors (or their affiliates) have a material financial interest with respect to fees and incentive allocations directly or indirectly paid by Investors. Management fees are payable without regard to the overall success or income earned by the Advisory Clients and therefore may create an incentive on the part of the Advisors to raise or otherwise increase assets under management to a higher level than would be the case if the Advisors were receiving a lower or no management fee. Performance-based fees or allocations may create an incentive for the Advisors to make investments that are riskier or more speculative than in the absence of such performance-based fees or allocations. Advisory Clients and Investors are

provided with clear disclosure as to how performance-based fees or allocations are charged and the risks associated with such performance-based fees and allocations prior to making an investment. The Advisors, their employees or their related persons may also invest directly or indirectly in any one, some, or all of the Funds. Investments in the Funds made by such parties may not be subject to the asset or performance-based fees described above. The fact that partners and employees of the Advisors have financial ownership interests in the Funds also creates a potential conflict in that it could cause the Advisors to make different investment decisions than if such parties did not have such financial ownership interests. Certain of the Advisors act as collateral manager to the Structured Credit Vehicles. Certain partners, officers and employees of the Advisors have, and will in the future, purchase the equity or subordinated debt of certain Structured Credit Vehicles. Certain Funds have purchased and as of the date of this Brochure, hold an interest in the majority of the equity or subordinated debt of certain Structured Credit Vehicles. With respect to certain such investments by the Funds, the Advisors have reduced or effectively waived the collateral management fees due to the Advisors; however, the Advisors do charge such fees to subordinated debt investors which are not Funds or affiliates. Nevertheless, such investments involve conflicts of interest inasmuch as such investments by a Fund may enable the Advisors to launch and act as collateral manager of a Structured Credit Vehicle and earn fees from investments in such vehicle to the extent third parties are invested in the equity of such vehicle during or after the time the Fund is invested in such vehicle. Such fees may be greater than those paid by Funds with respect to such CLOs/CDOs. Thus, there are conflicts with respect to the decision of whether or when to cause a Fund to sell equity it holds in any Advisor-managed CLO/CDO to a third party because the Advisors would then earn collateral management fees with respect to the equity sold. There are conflicts with respect to the decision of whether to cause a Fund to purchase equity in any Advisormanaged CLO/CDO since the Advisors would not earn collateral management fees with respect to such equity. The Advisors and/or their affiliates have invested in Structured Credit Vehicles in the past and may continue to invest in existing and new Advisor-managed CLOs/CDOs for risk retention requirements or other reasons. The Advisors have certain responsibilities when acting as the collateral manager for, and managing the assets of, such Structured Credit Vehicles that may potentially conflict with the investment objectives of the Funds. For example, the investment guidelines of a CLO/CDO will generally restrict a collateral manager’s discretion in selecting and managing the CLO/CDO’s investment portfolio and limit its reinvestment period. Certain Funds may invest in warehouse (or similar) transactions for primary issuance Advisor-managed CLOs and/or CDOs for which other Advisor-managed funds or accounts ("Other Accounts") or third party investors may acquire an interest, provided that such interest is acquired at a price determined by the Advisors to represent the fair market value.

Conversely, certain of the Funds have, or will in the future, invest in CLO/CDOs that are warehoused by one or more of the Other Accounts or third party investors, provided that such interest is acquired at a price that is determined by the general partner or the Advisors to represent the fair market value. Furthermore, upon the redemption, liquidation, winding up or termination of an Advisor-managed CLO and/or CDO (including any warehouse or similar transaction relating thereto), the Funds may purchase the assets, or invest in a warehouse or similar vehicle that would purchase the assets, held by such Advisor-managed CLOs and/or CDOs (including any warehouse or similar transaction relating thereto) for use in a subsequent primary issuance Advisor-managed CLO and/or CDO (or warehouse or similar transaction relating thereto). Additionally, from time to time, the Advisors may cause an Advisory Client to purchase securities from or sell securities to other Advisory Clients when the Advisors believe such transactions are appropriate and in the best interests of such Advisory Clients and complies with U.S. securities laws. For example, this may occur in connection with the redemption, liquidation, winding up or termination of an Advisor-managed CLO and/or CDO (including any warehouse or similar transaction relating thereto). The Advisors have competing fiduciary duties to such Advisory Clients when considering cross trades. Although the Advisors would only engage in a cross trade in the event it believes such trade is the best interests of each Advisory Client, it is possible that if the securities were purchased or sold with a third party, a better price could be obtained. In the event the Advisors wish to reduce the investment of one or more of such Advisory Client in a security and increase the investment of other Advisory Clients in such security, it may effect such transactions by directing the transfer of the securities between Advisory Clients. Any incremental costs and expenses associated with any such investment will be borne by all such Advisory Clients on a pro rata basis. If an Advisor effects a cross trade between Advisory Clients, it will not receive any fee in connection with the completion of the transaction. Additionally, the Advisor's compliance policies require that all cross-trades be pre-cleared by the Chief Compliance Officer. The Advisors may recommend that an Advisory Client purchase or sell an investment that is being sold or purchased, respectively, at the same time by the Advisors, an affiliate thereof or another Advisory Client. The Advisors and their affiliates may also give advice and recommend the purchase or sale of securities and other financial instruments, or buy or sell such securities, and instruments for their own account or that of other clients, which advice or instruments may differ from advice given to, or instruments recommended or bought or sold for, the Funds, even though their investment objectives may be the same or similar. These activities may adversely affect the prices and availability of other securities or instruments held by or potentially considered for one or more Advisory Clients. Potential conflicts may also arise due to the fact that the Advisors and its personnel may have investments in some Funds but not in others or may have different levels of investments in the various Funds. Potential conflicts of interest may arise in connection with the personal trading activities of employees of the Advisors. The principals, officers and employees of the Advisors and their affiliates may buy and sell, for their own account or for

the account of other clients, securities and other financial instruments, in each case of the same or a similar type to those bought or sold on behalf of the Funds subject to the restrictions set forth in the Advisors' Code of Ethics described below. As stated in Item 11 herein, in order to address these potential conflicts and in recognition of the fiduciary obligations of the Advisors to their Advisory Clients and the desire of the Advisors to maintain high ethical standards, the Advisors have adopted a Code of Ethics containing provisions designed to: (i) prevent improper personal trading by “Access Persons” of the Advisors; (ii) prevent improper use of material, non-public information about securities recommendations made by the Advisors or securities holdings of the Funds; (iii) identify conflicts of interest; and (iv) provide a means to resolve any actual or potential conflict in favor of the Funds.

Item 11.C

If you or a related person invests in the same securities (or related securities, e.g., warrants, options or futures) that you or a related person recommends to clients, describe your practice and discuss the conflicts of interest this presents and generally how you address the conflicts that arise in connection with personal trading. The Advisors believe that high ethical standards are essential for the success of the Advisors and to maintain the confidence of its Advisory Clients. The Code is designed to ensure that the personal securities transactions of the Advisors and their affiliates, officers and employees (and members of their household) do not conflict with transactions effected on behalf of the Advisory Clients. Employees of the Advisors must: (i) place the interests of Advisory Clients and, in the case of the Funds, Investors, first; (ii) avoid taking inappropriate advantage of their positions within the firm; and (iii) conduct their personal securities transactions in full compliance with the Code. As required by Rule 204A-1 of the Advisers Act, the Advisors require their Access Persons to report their securities transactions on a quarterly basis and disclose their securities holdings upon employment and on an annual basis thereafter. The Advisors also restrict the personal trading of their Access Persons. In particular, the Advisors maintain a Restricted List containing the names of securities which Access Persons are generally prohibited from trading and requires each of their Access Persons to pre-clear transactions in all reportable securities unless otherwise subject to an exclusion under the Code of Ethics. The Advisors also maintain policies and procedures to prevent insider trading that are designed to prevent the misuse of material, non-public information. Personnel of the Advisors are required to certify on an annual basis their compliance with such policies and procedures as well as the Code of Ethics.

If you or a related person recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that you or a related person buys or sells the same securities for your own (or the related person's own) account, describe your practice and discuss the conflicts of interest it presents. Describe generally how you address conflicts that arise. Please refer to the responses in Items 11.A, 11.B, and 11.C.

ITEM 12 – BROKERAGE PRACTICES Item 12.A.1

Describe the factors that you consider in selecting or recommending brokerdealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). 1.

Research and Other Soft Dollar Benefits. If you receive research or other products or services other than execution from a broker-dealer or a third party in connection with client securities transactions (“soft dollar benefits”), disclose your practices and discuss the conflicts of interest they create.

The Advisors recognize their duty to obtain “best execution” in effecting transactions on behalf of their Advisory Clients. In selecting brokers or dealers to execute transactions, the Advisors are not required to solicit competitive bids and do not have an obligation to seek the lowest available commission. In selecting the counterparties to execute a particular transaction, the Advisors use their best judgment in evaluating the terms of the transaction, and gives consideration to various relevant factors, which generally will include the size and type of the transaction; the nature and character of the market for the financial instrument; execution capabilities including the ability to handle trades and answer calls in a volatile market; commission rates; financial responsibility; value of research or brokerage provided; technology provided; willingness, ability, facilities and infrastructure to work with investment advisor firms; administrative resources; responsiveness; and pricing for services provided. Therefore, the Advisors may not necessarily negotiate “execution only” commission rates and may “pay up” for research and other services provided by the broker through the commission rate (“soft dollars”). However, since commission rates are generally negotiable, selecting brokers on the basis of considerations which are not limited to applicable commission rates may result in higher transaction costs than would be otherwise obtainable. Research and other services furnished by brokers may include, but are not limited to, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; conferences or trade shows; statistical and pricing services, along with software, data bases and other technical and telecommunication services and equipment utilized in the investment management process. Each of the Funds’ respective agreements with the Advisors authorizes the use of “soft dollars” to the extent permitted by applicable law. Notwithstanding this authorization, the Advisors currently do not accrue or intend to accrue soft dollar credits or obtain products or services from third parties from soft dollar credits. The Advisors have and will receive research services from brokers. Brokers may sometimes suggest a level of business they would like to receive in return for the various products and services they provide. Actual brokerage business received by any broker may be less than the suggested allocations or may exceed the suggestions because total brokerage is allocated on the basis of all the considerations described above. A broker will not be excluded from

receiving business simply because it has not been identified as providing research services. Item 12.A.2

Brokerage for Client Referrals. If you consider, in selecting or recommending broker-dealers, whether you or a related person receives client referrals from a broker-dealer or third party, disclose this practice and discuss the conflicts of interest it creates. a.

Disclose that you may have an incentive to select or recommend a broker-dealer based on your interest in receiving client referrals, rather than on your clients’ interest in receiving most favorable execution.

b.

Explain the procedures you used during your last fiscal year to direct client transactions to a particular broker-dealer in return for client referrals.

From time to time, the Advisors may participate in capital introduction events. However, the Advisors do not consider whether they receive investor referrals in deciding: (i) whether to participate in such events; or (ii) the manner in which it selects broker-dealers. In addition, it should be noted that an Advisors will not allocate Fund brokerage business to a broker-dealer unless such Advisor determines in good faith that the commissions payable to such broker are consistent with seeking best execution. Item 12.A.3

Directed Brokerage. a.

If you routinely recommend, request or require that a client direct you to execute transactions through a specified broker-dealer, describe your practice or policy. Explain that not all advisers require their clients to direct brokerage. If you and the broker-dealer are affiliates or have another economic relationship that creates a material conflict of interest, describe the relationship and discuss the conflicts of interest it presents. Explain that by directing brokerage you may be unable to achieve most favorable execution of client transactions, and that this practice may cost clients more money.

b.

If you permit a client to direct brokerage, describe your practice. If applicable, explain that you may be unable to achieve most favorable execution of client transactions. Explain that directing brokerage may cost clients more money. For example, in a directed brokerage account, the client may pay higher brokerage commissions because you may not be able to aggregate orders to reduce transaction costs, or the client may receive less favorable prices.

The Advisors do not have directed brokerage arrangements.

Discuss whether and under what conditions you aggregate the purchase or sale of securities for various client accounts. If you do not aggregate orders when you have the opportunity to do so, explain your practice and describe the costs to clients of not aggregating.

When appropriate, the Advisors may, but are not required to, aggregate Advisory Client orders to achieve more efficient execution or to provide for equitable treatment among accounts. Advisory Clients participating in aggregated trades will be allocated securities based on the average price achieved for such trades. The Advisors will act in a fair and equitable manner in allocating investment and trading opportunities, including private placements, among the Advisory Clients. In furtherance of the foregoing, the Advisors will consider participation in all appropriate opportunities within the purpose and scope of each Advisory Client’s objectives, and the Advisors will evaluate such factors as it considers relevant in determining whether a particular situation or strategy is suitable and feasible for each Advisory Client (which factors may include the investment restrictions and objectives of each Advisory Client, whether the Advisory Client is fully exposed to the issuer, the Advisory Client’s risk tolerance and liquidity requirements, the nature of the opportunity in the context of the Advisory Client’s other positions at the time, and available cash flow). It should be noted that the Advisors (for a variety of reasons) may allocate trades solely to one Advisory Client and/or may allocate trades on a non-pro rata basis. In the event that an investment opportunity is appropriate for more than one Advisory Client but is not allocated between such Advisory Clients on a pro rata basis, trading personnel are required, at the time of such trade entry, to complete a “Non-Pro Rata Trade Allocation Report” in the Trade Blotter which is subject to operational and compliance review and approval.

ITEM 13 – REVIEW OF ACCOUNTS Item 13.A

Indicate whether you periodically review client accounts or financial plans. If you do, describe the frequency and nature of the review, and the titles of the supervised persons who conduct the review. Yale Baron and Thibault Gournay, the Co-Chief Investment Officers of the Advisors, are responsible for overseeing the portfolio management, risk management, asset allocation, and investment decisions with respect to the Funds. Mr. Baron and Mr. Gournay may designate other Advisor employees to assist with these responsibilities and to review accounts and orders In addition, the Chief Compliance Officer will periodically review the trade policies and procedures to ensure that it represents the current practices of the Advisors and (to the best of its reasonable knowledge and belief) is in conformity with applicable law and regulations. The Advisors have written trade allocation procedures in place which were designed to seek to ensure that all Investors and Funds are treated fairly. To assist the Advisors with implementing and monitoring their trade allocation policies and procedures (and to seek to ensure that all Investors and Funds are treated fairly), the Advisors utilize certain proprietary software systems for trade entry and allocations. The software systems were designed to incorporate the trade allocation rules of the Advisors, pro rata allocation thresholds, and Fund trading restrictions directly into the real time trading process of the Advisors.

Item 13.B

If you review client accounts on other than a periodic basis, describe the factors that trigger a review. Please see Item 13.A. The accounts are under continuous review.

If you or a related person directly or indirectly compensates any person who is not your supervised person for client referrals, describe the arrangement and the compensation. The Advisors have, and may in the future, compensate certain third parties, such as placement agents, for helping with raising capital or marketing the Funds. Such entities may also provide other services to the Funds and/or the Advisors, for which they may be compensated. Certain unaffiliated third parties may refer investors to the Funds and/or the Advisors. The Advisors do not directly compensate such unaffiliated third parties for any referrals, absent a placement agent, solicitation or other similar arrangement. However, such third parties may have other business or personal relationships with the Advisors, such as being invested in the Funds, sourcing investment opportunities for the Funds, or providing other services to the Advisors or the Funds. To the extent applicable (taking into account current SEC guidance), such third party solicitation arrangements will be in compliance with Rule 206(4)-1 under the Advisers Act, as amended.

A self-regulatory organization (SRO) proceeding in which your firm or a management person 1.

was found to have caused an investment-related business to lose its authorization to do business; or

2.

was found to have been involved in a violation of the SRO’s rules and was: (i) barred or suspended from membership or from association with other members, or was expelled from membership; (ii) otherwise significantly limited from investmentrelated activities; or (iii) fined more than $2,500.

Not applicable to the Advisors.

ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Item 10.A

If you or any of your management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer, disclose this fact. Not applicable to the Advisors.

Item 10.B

If you or any of your management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities, disclose this fact. Not applicable to the Advisors.

Item 10.C

Describe any relationship or arrangement that is material to your advisory business or to your clients that you or any of your management persons have with any related person listed below. Identify the related person and if the relationship or arrangement creates a material conflict of interest with clients, describe the nature of the conflict and how you address it. 1. 2.

3. 4. 5. 6. 7. 8. 9. 10. 11.

broker-dealer, municipal securities dealer, or government securities dealer or broker investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) other investment adviser or financial planner futures commission merchant, commodity pool operator, or commodity trading advisor banking or thrift institution accountant or accounting firm lawyer or law firm insurance company or agency pension consultant real estate broker or dealer sponsor or syndicator of limited partnerships

Anchorage Capital Group, L.L.C. ("ACG") is a separately registered affiliate of the Advisors. ACG is a Delaware limited liability company and a limited partner of Anchorage. ACG continues to provide advisory services to certain pooled investment vehicles set forth on its Form ADV Part 1A. Anchorage and ACG operate their respective businesses using shared operational resources such as office space, advisory and non-advisory personnel and back office functions. Anchorage Collateral Management, L.L.C., Anchorage Credit Advisor, L.L.C., Anchorage Opportunities Advisor, L.L.C., Anchorage Strategies Advisor, L.L.C., Anchorage CLO ECM, L.L.C. and Anchorage Capital Advisors Europe LLP

(“ACAE”) are each an affiliate of Anchorage and are included in Anchorage’s registration with the Securities and Exchange Commission as Relying Advisors. ACAE is an FCA registered advisory affiliate that has been engaged by the other Advisors to provide sub-advisory services to certain Funds as well as certain advisory clients of ACG. The Advisors and their affiliates act on behalf of the Funds and carry on investment activities for other Advisory Clients (including other investment funds sponsored by the Advisors or their affiliates) in which the Funds will have no interest. In particular, employees of the Advisors may serve on boards of directors or executive committees or in other capacities at companies in which the Funds invest, either directly or indirectly. Serving in such a capacity may expose such employee, and by association the Advisors and the Funds, to certain limitations on the ability to trade the securities of the issuer company and certain conflicts of interest. As a result of such service, an employee may become aware, from time to time, of material non-public information about the company in which the Funds invest, and the employee’s knowledge is likely to be attributed to the Advisors and the Funds; therefore, the Funds’ ability to trade the securities of such company may become substantially restricted. The Funds’ ability to buy and sell such securities may be limited to such times as company insiders are permitted to do so. Such limitations may cause the Funds to forgo sales that it would otherwise make, thereby exposing the Funds to losses, or to forgo purchases, thereby exposing the Funds to lost opportunities. The Advisors and the Funds may also be subject to Section 16 of the Securities Exchange Act of 1934, as amended, including the disclosure requirements, the restrictions on purchases and sales, and the disgorgement of profits in certain circumstances. An employee serving as a director of a company owned, directly or indirectly, by the Funds may also face a conflict between the fiduciary duties owed by such employee to the Funds and the duties owed to such company. In such circumstances, an employee may act in ways that are in the best interests of such company but not the Funds. The Advisors maintain internal compliance policies that are intended to minimize the negative effects of such conflicts if they arise, and intends to prevent employees from taking such positions when, in the determination of the Advisors, the potential risks to the Funds outweigh the potential benefits. However, there can be no assurance that permitting the board membership of an employee will not result in less favorable results for the Funds than if the employee was not permitted to serve in such capacity. Advisory agreements between the Advisors and the Funds require the Advisors and their affiliates to act in a manner that it considers fair, reasonable and equitable in allocating investment opportunities to the Funds but does not otherwise impose any specific obligations or requirements concerning the allocation of time, effort or investment opportunities to the Funds or any restrictions on the nature or timing of investments for the proprietary account of the Advisors, their affiliates or their respective principals or for other accounts which Anchorage or its affiliates may manage. Advisor professionals are not obligated to devote any specific amount of time to the affairs of the Funds, and the Advisors and their affiliates are not required to accord exclusivity or priority

to the Funds in the event of limited investment opportunities. It is possible that one Fund may from time to time make an investment in one part of a company’s capital structure while another Fund makes an investment in another part of the company’s capital structure and that the interests of such Funds differ or conflict. Future investment activities by the Advisors, including the establishment of other investment funds or Advisory Clients, may give rise to additional conflicts of interest.

Describe the content and indicate the frequency of regular reports you provide to clients regarding their accounts. State whether these reports are written. Generally, Investors will receive monthly or quarterly account statements, as applicable, from the respective Fund’s administrator as well as monthly or quarterly letters detailing among other things Fund performance and assets under management by the Advisors. Lastly, Investors will receive annual audited financial statements. Investors in the Structured Credit Vehicles do not receive annual audited financial statements, but do receive periodic statements from the vehicles’ respective Trustees.

ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Item 14.A

If someone who is not a client provides an economic benefit to you for providing investment advice or other advisory services to your clients, generally describe the arrangement, explain the conflicts of interest, and describe how you address the conflicts of interest. For purposes of this Item, economic benefits include any sales awards or other prizes. The Advisors, their affiliates and their personnel, do not receive any economic benefit from someone who is not a client for providing investment advice or other advisory services to clients.

If you have custody of client funds or securities and a qualified custodian sends quarterly, or more frequent, account statements directly to your clients, explain that clients will receive account statements from the broker-dealer, bank or other qualified custodian and that clients should carefully review those statements. If your clients also receive account statements from you, your explanation must include a statement urging clients to compare the account statements they receive from the qualified custodian with those they receive from you. The Advisors have custody of client funds and securities under Rule 260(4)-2 of the Advisers Act because it has the authority to obtain possession of the funds and securities of the Funds and separately managed account clients. Account statements related to the separately managed account clients are sent by qualified custodians directly to such clients on at least a quarterly basis. Separately managed account clients should carefully review statements received directly from the qualified custodian and compare them to statements provided by the Advisors. Account statements related to the Funds are sent by qualified custodians to the Advisors on at least a quarterly basis. To ensure compliance with Rule 206(4)-2 under the Advisers Act, the Advisors are required to reasonably believe that all Investors will be provided with audited financial statements for their respective Fund prepared by an independent accounting firm that is registered with and subject to review by the Public Company Accounting Oversight Board, in accordance with U.S. Generally Accepted Accounting Principles, within 120 days of the end of such Fund’s fiscal years (i.e., generally by April 30). Investors should carefully review the audited financial statements of the Funds. The Advisors do not have actual or constructive custody with respect to the Structured Credit Vehicles, so Investors in these products do not receive annual audited financial statements.

If you accept discretionary authority to manage securities accounts on behalf of clients, disclose this fact and describe any limitations clients may (or customarily do) place on this authority. Describe the procedures you follow before you assume this authority (e.g., execution of a power of attorney). The Advisors have discretionary authority to manage securities accounts on behalf of the Funds. The Advisors are authorized to make transaction recommendations for the Advisory Clients. As explained in Item 4.C above, each Fund’s investment strategy is set forth in detail in the respective Fund’s private offering memorandum. Investors do not have the ability to impose limitations on the discretionary authority of the Advisors. Investors must execute a subscription agreement in which they make various representations, including representations regarding their suitability to invest in a high-risk investment pool, and Investors in the domestic limited partnerships must execute a limited partnership agreement that contains a limited power of attorney. As noted in Item 4, the Advisors have established certain Customized Funds. These entities may utilize different trading and/or investment strategies than the other Funds and may be subject to different terms and arrangements than the other Funds described above. It should be noted that any such future relationships may be subject to minimum investment size and other possible special requirements.

ITEM 17 – VOTING CLIENT SECURITIES Item 17.A

If you have, or will accept, authority to vote client securities, briefly describe your voting policies and procedures, including those adopted pursuant to SEC rule 206(4)-6. Describe how you address conflicts of interest between you and your clients with respect to voting their securities. Describe how clients may obtain information from you about how you voted their securities. Explain to clients that they may obtain a copy of your proxy voting policies and procedures upon request. The Advisors understand and appreciate the importance of proxy voting and will generally manage the receipt of incoming proxies, maintain a log of all proxies, and place votes based on established policies and guidelines. In the course of exercising discretion to vote a proxy, the Advisors will vote any such proxies in the best interests of Funds and in accordance with the procedures outlined below (as applicable). Prior to voting any proxies, the Proxy Voting Committee will determine if there are any conflicts of interest related to the proxy in question. If a conflict is identified, the Proxy Voting Committee will then make a determination (which may be in consultation with outside legal counsel) as to whether the conflict is material or not. If no material conflict is identified pursuant to its set procedures, the Proxy Voting Committee will, following discussion with investment personnel of the Advisors, make a decision on how to vote the proxy in question. The Advisors also have the flexibility to abstain from a particular proxy vote when it is determined to be in the best interest of the Advisory Client. Generally, Advisory Clients may not direct an Advisor's vote in a particular solicitation. As applicable, the Advisors will ensure delivery of the proxy, in accordance with instructions related to such proxy, in a timely and appropriate manner. The Advisors keep a record of its proxy voting policies and procedures, proxy statements received, votes cast, all communications received and internal documents created that were material to voting decisions and each Advisory Client request for proxy voting records and the response of the Advisors for the previous five years. If you have any questions about proxy policy of the Advisors, their proxy recordkeeping procedures or if you would like any detailed information about how proxies are actually voted, please contact Joel Koerner at (212) 432-4600 or by email at Joel.Koerner@anchoragecapital.com.

If you do not have authority to vote client securities, disclose this fact. Explain whether clients will receive their proxies or other solicitations directly from their custodian or a transfer agent or from you, and discuss whether (and, if so, how) clients can contact you with questions about a particular solicitation. Not applicable to the Advisors.

ITEM 18 – FINANCIAL INFORMATION Item 18.A

If you require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, include a balance sheet for your most recent fiscal year. 1.

The balance sheet must be prepared in accordance with generally accepted accounting principles, audited by an independent public accountant, and accompanied by a note stating the principles used to prepare it, the basis of securities included, and any other explanations required for clarity.

2.

Show parenthetically the market or fair value of securities included at cost.

3.

Qualifications of the independent public accountant and any accompanying independent public accountant’s report must conform to Article 2 of SEC Regulation S-X.

Not applicable to the Advisors. Item 18.B

If you have discretionary authority or custody of client funds or securities, or you require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, disclose any financial condition that is reasonably likely to impair your ability to meet contractual commitments to clients. Note: With respect to Items 18.A and 18.B, if you are registered or are registering with one or more of the state securities authorities, the dollar amount reporting threshold for including the required balance sheet and for making the required financial condition disclosures is more than $500 in fees per client, six months or more in advance. The Advisors are not currently aware of any financial condition that is reasonably likely to impair their ability to meet contractual commitments to clients.

If you have been the subject of a bankruptcy petition at any time during the past ten years, disclose this fact, the date the petition was first brought, and the current status. Not applicable to the Advisors.