Anchorage Capital Group, L.L.C.

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, Anchorage manages approximately $3.7 billion of regulatory assets under management on a discretionary basis. Anchorage does 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. Anchorage typically charges 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 Evergreen Funds and Drawdown Funds is provided in the relevant Fund’s confidential private placement memorandum, including any supplements, which are provided to prospective investors. 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 is typically from 1.0% to 2.0% of each Investor’s assets with the applicable Evergreen Funds and Drawdown Funds. In addition, consistent with the Investment Advisers Act of 1940, as amended (“Advisers Act”) and Rule 205-3 thereunder to the extent applicable, Anchorage or its 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 Anchorage generally range from 15% to 20% of the net profits allocable to a particular Investor. For certain Funds, the performance allocation is subject to a hurdle or preferred return rate. The fees and performance allocations detailed above are negotiable in that Anchorage reserves the right to reduce, waive or calculate differently such fees and performance allocations for certain Investors. Partners, employees and certain affiliates of Anchorage 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 Anchorage is compensated for its 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. Anchorage or its affiliates deducts fees from Investors’ assets invested in the Funds. 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 Anchorage, Advisory Clients (and, therefore, Investors therein) are also subject to other costs and expenses related to their respective activities as further summarized below: The Evergreen Funds generally pay the following expenses: • organizational expenses; • pro rata share of the relevant master fund’s expenses; • all costs and expenses directly related to investments or prospective investments (whether or not consummated) such as external research and transaction costs (including travel and travel-related meals, legal and other advisory fees and expenses); all deal and access fees, whether paid to third-party managers or brokers, for transactions in which the Funds participate; • legal fees and costs (including settlement costs) arising in connection with any litigation or regulatory investigation instituted against the Funds or Anchorage, each in its capacity as such (whether incurred by the Funds or by Anchorage or the Board on the Funds’ behalf); • 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 a 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 Fund business) engaged by the Funds or Anchorage; • legal and accounting fees, including expenses associated with the Funds’ financial statements and reports, tax returns and schedule K-1s; • all (or such pro rata portion, as determined by Anchorage) fees and expenses related to any investment vehicle or subsidiaries utilized to facilitate the Funds transactions (including legal, administrative, custodial, audit, registered office and other fees, rent, overhead and salary); • litigation and indemnification expenses; • offering expenses, including external legal and accounting expenses, placement fees and printing costs; • investment expenses such as commissions, clearing fees, research fees, interest and costs on margin accounts or other financings or refinancings, borrowing charges on securities sold short, custodial fees, and bank service fees; • any withholding or transfer taxes imposed on the Funds or any of their Investors; • 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 Funds or Anchorage in compliance with the rules of any self-regulatory organization or any federal, state or local or foreign laws; • the Administrator’s fees; • expenses incurred in connection with the admission of Investors or the acceptance of additional subscriptions (including expenses incurred in connection with side letters for existing Investors); • 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; • 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; • costs and expenses in connection with operational risk management (including third party risk assessment, due diligence and ongoing monitoring); • the costs of any insurance obtained on behalf of the Funds, Anchorage, the principal, the affiliates of any of them, directors, officers and any other indemnified person; • all costs and expenses associated with reporting and providing information to existing and prospective Investors; • costs of communications with prospective investors and shareholders and costs of meetings of Investors; and • any other reasonable expenses related to the purchase, sale, holding or transmittal of Fund assets or liabilities. 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 Anchorage to be of a general nature or beneficial to its research in general. The Drawdown Funds generally pay the following expenses: • organizational expenses; • pro rata share of the relevant master fund’s 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; all deal and access fees, whether paid to third-party managers or brokers, for transactions in which the Drawdown Funds participate; 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 applicable Drawdown 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 Funds or Anchorage in compliance with the rules of any self-regulatory organization or any U.S. federal, state or local laws; any legal fees and costs (including settlement costs) arising in connection with any litigation or regulatory investigation instituted against the Funds, the General Partner or Anchorage; 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), including as it relates to the Funds’ Luxembourgbased investment vehicle or other non-U.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 Anchorage), other expenses and/or a profit margin to such investment vehicle(s); the fees and expenses (if any) associated with the Conflicts Advisory Board; the cost of the audit of the Funds’ financial statements and the preparation of its tax returns; fees and expenses for financial and tax accounting and reporting services; the fees and expenses of the Funds’ counsel in connection with advice directly relating to the Funds’ legal affairs (including lenders’ counsel for any credit facility); administration expenses; expenses incurred in connection with the admission of Investors or the acceptance of additional capital contributions (including expenses incurred in connection with side letters for prospective and existing 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 a Fund holds a direct or indirect interest, operating partners, consultants or similar roles, as well as, public

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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 Anchorage.

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 Anchorage.

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 Anchorage.

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. Anchorage (or an affiliate) provides discretionary investment advisory services including, but not limited to, managing and directing the investment and reinvestment of assets for private investment funds. 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 range from $1,000,000 to $10,000,000, subject to the discretion of the general partner of the Fund.

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 Anchorage and its affiliates utilize a variety of resources or services to form an investment idea or strategy. In general, Anchorage assesses 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 Evergreen Funds: The ACP Funds have employed hedged investment strategies, such as capital structure arbitrage, curve and paired trades, and directional investment strategies such as total return, reorganization, liquidation, and direct loan investments. These Funds have primarily invested in the leveraged issuer and distressed debt markets of North America and Europe, in addition to other markets, where they seek to capitalize on relative and absolute value investment opportunities using hedged and directional investment strategies. These funds are no longer actively investing capital. Drawdown Funds: The AIO 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 AIO 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 Anchorage or its affiliates. The SCF Funds may

also opportunistically invest in other structured credit investments and may (but are under no obligation to) employ hedged investment strategies. 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 Anchorage. The information contained herein is a summary only and is qualified in its entirety by such documents. Use of Leverage Anchorage (or an affiliate) 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 Anchorage 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 Anchorage 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 Anchorage 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. Anchorage 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 Anchorage to implement its strategies successfully. Cybersecurity, Information Security and Systems Risk Anchorage relies 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. Anchorage, 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 Anchorage maintains 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 Anchorage, the Funds or third parties. 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 Anchorage seeks 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 Anchorage 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 Anchorage, 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 business activity generally, or in any of the countries in which the Funds may invest specifically. In particular, increased tensions between Russia and Ukraine have resulted in a Russian invasion of Ukraine. Escalating tensions involving these two countries may result in more widespread conflict. Additionally, recent hostilities between the United States and Iran have also escalated tensions. Such hostilities could have a severe adverse effect on the applicable local region, including significant negative impacts on the U.S. and/or global economy and the markets for certain securities and commodities, such as oil and natural gas. How long such tensions and related events will last cannot be predicted. These tensions, and any related events, could have significant impact on Fund performance and the value of an investment in the Funds. Political Uncertainty Some of the results of elections and referenda in recent years in the United States, Europe, and other developed and emerging market countries have been unexpected and resulted in material market changes and increases in market uncertainty. The foregoing changes in political regimes have destabilized longheld treaties and customs between nations leading to further market instability in both developed and emerging countries. Given changes in administrations and applicable law following these votes, the future of current regulations, or the adoption of new regulations, is also uncertain. These uncertainties may have adverse impacts on, or alternatively create investment opportunities for, the Funds. Potential Interest Rate Increases

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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, Anchorage (or an affiliate) receives performance-based allocations or fees from certain Advisory Clients. Where each Fund managed by Anchorage pays performance-based compensation, it should be noted that Anchorage reserves 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 Anchorage to disproportionately allocate the best opportunities to Funds that pay the highest rates of performance based fees. Anchorage is 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, Anchorage’s (or its affiliate’s) 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 affiliates of Anchorage, including ACA (each, an “Affiliated Structured Credit Manager”), manage in return for fees for acting as collateral manager (such vehicles, the “Structured Credit Vehicles”), the Affiliated Structured Credit Manager generally reduces or waives, rebates, pays or otherwise transfers 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 the Affiliated Structured Credit Manager will be reimbursed for any of its outof-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 Affiliated Structured Credit Manager 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 affiliate-managed Structured Credit Vehicles to a third party because the Affiliated Structured Credit Manager 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 affiliate-managed Structured Credit Vehicles since the Affiliated Structured Credit Manager would not earn collateral management fees with respect to such equity. Please also see Item 11 for a discussion of such conflicts.

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

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. As noted in Item 4, Moorstone, L.P. was previously a relying adviser of ACA. As of January 2, 2026, Moorstone, L.P. became separately registered with the SEC and no longer shares operational resources, office space, or personnel with Anchorage or ACA. Anchorage retains a minority ownership interest in Moorstone, L.P. which has been engaged to provide non-discretionary advisory services to certain pooled investment vehicles managed by Anchorage.

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 Anchorage (the “Code”) is designed to meet the requirements of Rule 204A-1 of the Advisers Act. The Code applies to “supervised persons” (as defined in Advisers Act Rule 204A-1) of Anchorage and may apply to certain other individuals identified by the Chief Compliance Officer (together, “Access Persons”). The Code sets forth a standard of business conduct that takes into account the status of Anchorage 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. Anchorage’s 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, Anchorage’s 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, Anchorage serves as the investment manager to the Funds and as such offers interests in the Funds to prospective investors. Anchorage and its 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 Anchorage to raise or otherwise increase assets under management to a higher level than would be the case if Anchorage were receiving a lower or no management fee. Performance-based fees or allocations may create an incentive for Anchorage 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. Anchorage, its employees or 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 Anchorage have financial ownership interests in the Funds also creates a potential conflict in that it could cause Anchorage to make different investment decisions than if such parties did not have such financial ownership interests. Affiliated Structured Credit Managers act as collateral managers to Structured Credit Vehicles. Certain partners, officers and employees of Anchorage and its affiliates 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, Affiliated Structured Credit Managers have effectively waived the collateral management fees due to them; however, the Affiliated Structured Credit Managers 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 an Affiliated Structured Credit Manager 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 Affiliated Structured Credit Manager -managed CLO/CDO to a third party because an affiliate of Anchorage 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 Affiliated Structured Credit Manager -managed CLO/CDO since the Affiliated Structured Credit Manager would not earn collateral management fees with respect to such equity. Anchorage and/or its affiliates have invested in Structured Credit Vehicles in the past and may continue to invest in existing and new Affiliated Structured Credit Manager-managed CLOs/CDOs for risk retention requirements or other reasons. Anchorage affiliates 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 affiliate-managed CLOs and/or CDOs for which other Anchorage-managed funds or accounts or third party investors may acquire an interest, provided that such interest is acquired at a price determined by Anchorage 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 Anchorage to represent the fair market value. Furthermore, upon the redemption, liquidation, winding up or termination of an affiliate-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 affiliate-managed CLOs and/or CDOs (including any warehouse or similar transaction relating thereto) for use in a subsequent primary issuance affiliate-managed CLO and/or CDO (or warehouse or similar transaction relating thereto). Additionally, from time to time, Anchorage may cause an Advisory Client to purchase securities from or sell securities to other Advisory Clients when Anchorage believes 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 affiliate-managed CLO and/or CDO (including any warehouse or similar transaction relating thereto). Anchorage has competing fiduciary duties to such Advisory Clients when considering cross trades. Although Anchorage 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 Anchorage wishes 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. In addition, Anchorage may recommend that an Advisory Client purchase or sell an investment that is being sold or purchased, respectively, at the same time by Anchorage, an affiliate thereof or another Advisory Client. If Anchorage effects a cross trade between Advisory Clients, it will not receive any fee in connection with the completion of the transaction. Additionally, Anchorage’s compliance policies require that all cross-trades be pre-cleared by the Chief Compliance Officer. In addition, the principals, officers and employees of Anchorage and its 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. Anchorage and its affiliates may 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. Potential conflicts of interest may arise in connection with the personal trading activities of employees of Anchorage.

As stated in Item 11 herein, in order to address these potential conflicts and in recognition of the fiduciary obligations of Anchorage to Advisory Clients and the desire of Anchorage to maintain high ethical standards, Anchorage has adopted a Code of Ethics containing provisions designed to: (i) prevent improper personal trading by “Access Persons” (as defined in Advisers Act Rule 204A-1) of Anchorage; (ii) prevent improper use of material, non-public information about securities recommendations made by Anchorage 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. Anchorage and its affiliates believe that high ethical standards are essential for its success and to maintain the confidence of its Advisory Clients. The Code is designed to ensure that the personal securities transactions of Anchorage and its affiliates, officers and employees (and members of their household) do not conflict with transactions effected on behalf of the Advisory Clients. Employees of Anchorage 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, Anchorage requires its Access Persons to report their securities transactions on a quarterly basis and disclose their securities holdings upon employment and on an annual basis thereafter. Anchorage also restricts the personal trading of its Access Persons. In particular, Anchorage maintains a Restricted List containing the names of securities which Access Persons are generally prohibited from trading and requires each of its Access Persons to pre-clear transactions in all reportable securities unless otherwise subject to an exclusion under the Code of Ethics. Anchorage and its affiliates also maintain policies and procedures to prevent insider trading that are designed to prevent the misuse of material, non-public information. Personnel of Anchorage is required to certify on an annual basis its 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.

Anchorage and its affiliates recognize its duty to obtain “best execution” in effecting transactions on behalf of its Advisory Clients. In selecting brokers or dealers to execute transactions, Anchorage is 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, Anchorage uses its 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, Anchorage 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 Anchorage authorizes the use of “soft dollars” to the extent permitted by applicable law. Notwithstanding this authorization, Anchorage currently does not accrue or intend to accrue soft dollar credits or obtain products or services from third parties from soft dollar credits. Anchorage has 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, Anchorage may participate in capital introduction events. However, Anchorage does 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 Anchorage will not allocate Fund brokerage business to a broker-dealer unless Anchorage 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.

Anchorage does 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, Anchorage may, but is 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. Anchorage 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, Anchorage will consider participation in all appropriate opportunities within the purpose and scope of each Advisory Client’s objectives, and Anchorage 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 Anchorage (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. Kevin Ulrich, Chairman of Anchorage, is responsible for overseeing the portfolio management, risk management, asset allocation, and investment decisions with respect to the Funds. Mr. Ulrich may designate other Anchorage employees to assist with these responsibilities and to review accounts and orders. Yale Baron and Thibault Gournay are the Co-Chief Investment Officers of Anchorage also serve on the Investment Committee of the Funds. Mr. Baron and Mr. Gournay may designate other Anchorage 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 Anchorage and (to the best of its reasonable knowledge and belief) is in conformity with applicable law and regulations. Anchorage has written trade allocation procedures in place which were designed to seek to ensure that all Investors and Funds are treated fairly and equitably over time. To assist Anchorage with implementing and monitoring its trade allocation policies and procedures (and to seek to ensure that all Investors and Funds are treated fairly and equitably over time), Anchorage utilizes certain proprietary software systems for trade entry and allocations. The software systems were designed to incorporate the trade allocation rules of Anchorage, pro rata allocation thresholds, and Fund trading restrictions directly into the real time trading process of Anchorage.

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. Anchorage has, 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 Anchorage, for which they may be compensated. Certain unaffiliated third parties may refer investors to the Funds and/or Anchorage. Anchorage does 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 Anchorage, such as being invested in the Funds, sourcing investment opportunities for the Funds, or providing other services to Anchorage 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 Anchorage.

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 Anchorage.

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 Anchorage.

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 Advisors, L.P., a Delaware limited partnership, is separately registered with the SEC as an investment adviser with the following affiliates registering in reliance on the ACA Form ADV as relying advisers: 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. ACA and a number of its relying advisers were relying advisers of Anchorage until January 2, 2024. ACA and its relying advisers provide advisory services to certain pooled investment vehicles set forth on their Form ADV Part 1A. Anchorage and ACA operate their respective businesses using shared operational

resources such as office space, advisory and non-advisory personnel and back office functions. Anchorage Capital Advisors Europe, LLP, an affiliate of Anchorage and a relying adviser of ACA, is a limited liability partnership incorporated in England and Wales. Anchorage Capital Advisors Europe, LLP, has been granted authorization by the UK Financial Conduct Authority to carry on its investment management business. Anchorage Capital Luxembourg S.à.r.l., a Luxembourg société à responsabilité limitée and affiliate of Anchorage, provides certain administrative and support services (e.g., documentation, accounting, tax) to Anchorage and its affiliates in connection with European trading activity conducted by Luxembourg trading vehicles. Anchorage has a relationship with Reservoir Capital Group, L.L.C. (“Reservoir”), which is a non-affiliated investment adviser. Reservoir manages a number of entities that serve as non-managing members of Anchorage and Anchorage Capital, L.L.C., but none of the Reservoir entities exercise any control over investment decisions or management of Anchorage. Anchorage and its affiliates act on behalf of the Funds and carry on investment activities for other clients (including any other investment funds sponsored by Anchorage or its affiliates) in which the Funds will have no interest. In particular, employees of Anchorage 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 Anchorage 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 Anchorage 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. Anchorage 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. Anchorage maintains 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 Anchorage, 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 Anchorage and the Funds require Anchorage and its 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 Anchorage, its affiliates or their respective principals or for other accounts which Anchorage or its affiliates may manage. Anchorage professionals are not obligated to devote any specific amount of time to the affairs of the Funds, and Anchorage and its 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 Anchorage, 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 Anchorage. Lastly, Investors will receive annual audited financial statements.

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. Anchorage, its affiliates and its personnel, will, from time to time, receive benefits such as gifts, entertainment or discounts from direct or indirect service providers to, counterparties of and portfolio companies of clients. Such benefits have the potential to create conflicts of interest in the selection and retention of service providers and counterparties and the acquisition and disposition of investments.

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. Other than for one Customized Fund, Anchorage has custody of client funds and securities under Rule 206(4)-2 of the Advisers Act because it has the authority to obtain possession of the funds and securities of the Funds. To ensure compliance with Rule 206(4)-2 under the Advisers Act, Anchorage is 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.

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). Anchorage has discretionary authority to manage securities accounts on behalf of the Funds. Anchorage is 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 Anchorage. 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, Anchorage has 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 whether (and, if so, how) your clients can direct your vote in a particular solicitation. 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. Anchorage understands 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, Anchorage 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 Anchorage, make a decision on how to vote the proxy in question. Anchorage also has the flexibility to abstain from a particular proxy vote when it is determined to be in the best interest of an Advisory Client. Generally, Advisory Clients may not direct voting in a particular solicitation. As applicable, Anchorage will ensure delivery of the proxy, in accordance with instructions related to such proxy, in a timely and appropriate manner. Anchorage keeps 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 Anchorage for the previous five years. If you have any questions about proxy policy of Anchorage, its 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 Anchorage.

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 Anchorage. 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. Anchorage is not currently aware of any financial condition that is reasonably likely to impair its 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 Anchorage.