Private company

BALYASNY ASSET MANAGEMENT L.P.

American company, incorporated in Delaware. Summary from the record

Last updated Oct 21, 2026.

Overview

  • HeadquartersDE1

Corporate structure

BALYASNY ASSET MANAGEMENT L.P. is part of a group headed by Balyasny Asset Management Holdings LP. 58 entities, 3 countries on record. Switch between the flow chart and the network, and select any entity to see its details.

Major holders of BALYASNY ASSET MANAGEMENT L.P.

  • Dmitry Balyasny Owns 50% to 75% of Balyasny Asset Management Partner Holdings LP, since 07/2020 (Form ADV)
  • Dames Gp LLC Owns control (general partner, trustee or manager) of Balyasny Asset Management Partner Holdings LP, since 07/2020 (Form ADV)

Built from major holders from Schedules 13D and 13G; stakes of 5% or more it reported on Schedules 13D and 13G (56 companies); owners and owned firms from Form ADV, the registration investment advisers file with the SEC. Each entity in the chart links to its source.

Investment adviser

BALYASNY ASSET MANAGEMENT L.P. is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.

  • Assets it manages$248.1B2 48 accounts, all with discretion
  • Employees2,434 1,026 in investment advice or research
  • ClientsPooled investment vehicles (other than investment companies and business: 48 ($248.1B)
  • How it is paidA percentage of assets under its management; Performance-based fees; Other: PASS THROUGH OF CERTAIN EXPENSES
  • What it doesPortfolio management for pooled investment vehicles (other than investment companies)
  • Holds client assetsYes: cash and securities
  • RegistrationSEC 801-66002, CRD 138111 IAPD record

Who owns it

Owners of 5% or more as the firm lists them (Schedule A), and the owners of those owners up the chain (Schedule B).

  • BALYASNY ASSET MANAGEMENT HOLDINGS LPowns 75% or more, since 07/2020
  • DAMES GP LLCowns general partner, trustee or manager of BALYASNY ASSET MANAGEMENT PARTNER HOLDINGS LP, since 07/2020
  • BALYASNY ASSET MANAGEMENT HOLDINGS LPowns 75% or more of BAM GP LLC, since 07/2020
  • Dmitry Balyasnyowns 75% or more of DAMES GP LLC, since 12/2003
  • Dmitry Balyasnyowns 50% to 75% of BALYASNY ASSET MANAGEMENT PARTNER HOLDINGS LP, since 07/2020

Disciplinary record

The firm answered yes to 1 of the disciplinary questions on Form ADV (Item 11). A yes can concern the firm itself or an affiliate.

  • Any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has found the firm or an advisory affiliate to have been involved in a violation of investment-related regulations or statutes.

Each event as the firm describes it on its Disclosure Reporting Pages:

STATE OF NEW HAMPSHIRE, DEPARTMENT OF STATE BUREAU OF SECURITIES REGULATION · May 17, 2019 · fine $2,500 · final about ATLAS ENHANCED FUND, L.P.

Allegations: ATLAS ENHANCED FUND, L.P. MADE A LATE SUBMISSION OF THE NOTICE FILING FOR ITS FIRST SALE OF SECURITIES IN THE STATE OF NEW HAMPSHIRE.

Sanction: Civil and Administrative Penalt(ies) /Fine(s)

How it ended: Settled

Detail: THE TOTAL SETTLEMENT AMOUNT OF $2,500.00 WAS LEVIED AGAINST THE ADVISORY AFFILIATE (ATLAS ENHANCED FUND, L.P.). THE SETTLEMENT AMOUNT WAS PAID ON JULY 17, 2019.

Summary: ATLAS ENHANCED FUND, L.P. MADE A LATE SUBMISSION OF THE NOTICE FILING FOR ITS FIRST SALE OF SECURITIES IN THE STATE OF NEW HAMPSHIRE.

Resolved: Jul 17, 2019

FINANSINSPEKTIONEN - SWEDISH FINANCIAL SUPERVISORY AUTHORITY ("SFSA") · Dec 10, 2018 · fine $15,416 · final about BALYASNY EUROPE ASSET

Allegations: BALYASNY EUROPE ASSET MANAGEMENT LLP ("BEAM")MADE A LATE SUBMISSION OF A NET SHORT FILING NOTIFICATION TO THE SWEDISH REGULATOR SFSA.

Sanction: Civil and Administrative Penalt(ies) /Fine(s)

How it ended: Decision

Detail: THE TOTAL SETTLEMENT AMOUNT OF $15,416 WAS LEVIED AGAINST THE RELYING ADVISOR BALYASNY EUROPE ASSET MANAGEMENT LLP. THE SETTLEMENT AMOUNT WAS PAID ON NOVEMBER 5, 2020.

Summary: SFSA DETERMINED THAT BEAM MADE A LATE NET SHORT POSITION NOTIFICATION TO THE SFSA. BEAM APPEALED THE DECISION. HOWEVER, THE APPEAL WAS UNSUCCESSFUL. THE APPEAL WAS DECIDED ON 06 SEPTEMBER 2019; HOWEVER, BEAM WAS NOT NOTIFIED OF THE DECISION. AS A RESULT, THE MATTER WAS NOT CONCLUDED UNTIL SUCH TIME BEAM WAS MADE AWARE OF THE FINAL DECISION.

Resolved: Sep 6, 2019

ICE NGX CANADA INC. · Apr 5, 2024 · fine $1,000 · final about ATLAS NG, LLC

Allegations: ATLAS NG LLC SUBMITTED AN INVOICE PAYMENT ONE DAY LATE TO ICE NGX CANADA INC.

Sanction: Civil and Administrative Penalt(ies) /Fine(s)

How it ended: Other

Detail: A SUMMARY SANCTION OF ONE THOUSAND ($1,000) CANADIAN DOLLARS WAS LEVIED AGAINST ATLAS NG LLC. THE SANCTION WAS PAID ON APRIL 11, 2024.

Summary: ATLAS NG LLC SUBMITTED AN INVOICE PAYMENT ONE DAY LATE TO ICE NGX CANADA INC.. A SUMMARY SANCTION OF ONE THOUSAND ($1,000) CANADIAN DOLLARS WAS LEVIED AGAINST ATLAS NG LLC. THE SANCTION WAS PAID ON APRIL 11, 2024. No Information Filed

Resolved: Apr 5, 2024

In its own words: the client brochure

Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/27/2026.3 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.

Item 4: Advisory business Services

As of December 31, 2025, BAM managed approximately $29,393,600,000 in client assets on a discretionary basis. BAM does not manage client assets on a non-discretionary basis. Item 5

Fees and Compensation

Item 5.A. As mentioned in Item 4.B., the Investment Funds are available only to persons who are “qualified purchasers” under the IC Act. In general, the fees for the Investment Funds are not negotiable. The Investment Funds, other than the Atlas Access Funds (as defined in this Item 5.A), typically pay an annual asset-based management fee (“Management Fee”), calculated and payable monthly in advance (for additional detail see Item 5.D.), depending on the specific Investment Fund and the terms associated with a specific share class or investment option. The Investment Funds, other than the Atlas Access Funds, are also responsible for an incentive allocation based on a percentage of the performance of the portfolio (“Incentive Allocation”), calculated on the basis of both realized and unrealized gains and losses. Depending on the specific Investment Fund and the terms associated with a specific share class or investment option, the Incentive Allocation will generally be calculated on net profits based on either a fixed rate of 20% or on a tiered rate of 10% to 30% of the annualized net rate of return of the specific investor, subject to a loss carryforward. Additionally, Investment Funds also pass-through expenses associated with the costs of the various Investment Teams, as defined and described more fully below (in this Item 5.A.). The pass-through expenses, including Investment Team-Related Expenses allocated to the Investment Funds, are material. The Atlas Access Funds do not pay a Management Fee. The Atlas Access Funds distribute carried interest to the general partner after investors in the Atlas Access Funds receive 100% of their capital contributions. Generally, the carried interest distributed by the Atlas Access Funds is 10%. The specific fees charged by each individual Investment Fund can be found in the confidential offering memorandum and/or the advisory contract associated with that specific Investment Fund. BAM does not negotiate fees; however, BAM may offer separate share class offerings of the Investment Funds where investors may receive a reduction of management fees or incentive fees otherwise payable with respect to certain other Investment Fund share classes. The difference in fees is generally due to investors meeting different minimum investment amounts in a specific Investment Fund share class. Performance-based allocations are only charged consistent with SEC rules and regulations, including Rule 205-3 under the Advisers Act. The Board of Directors of the Investment Funds or BAM (depending on the specific Investment Fund), in their sole discretion, may waive all or a portion of fees or offer different liquidity terms with respect to investments made by employees and certain other investors in the Investment Funds. In that connection, BAM employees that are permitted to invest in the Investment Funds are typically either charged a reduced Incentive Allocation or are not charged an Incentive Allocation at all (depending on the specific Investment Fund). Certain BAM employees, including partners of BAM, do not pay a Management Fee or an Incentive Allocation. Generally, Incentive Allocations are calculated and accrued monthly but are generally allocated annually at year-end or upon withdrawal/redemption. All performance-based allocations are calculated cumulatively; subject to a high-water mark (on a partner-bypartner basis or by share class) to prevent such allocation from being generated on recouped gains. (See Item 5.B. for additional detail regarding withdrawal/redemptions). Additionally, Investment Funds pay Investment Team-Related Expenses, which includes, without limitation:

Compensation of the Investment Team (as defined below) (including, but not limited to, signing bonuses, which may be in the form of buyouts of prior deferred compensation or other incentive

plans attributable to previous employers, as well as performance-based compensation, retention bonuses, draws, and benefits); compensation of all (i) members of the Investment Manager’s Management Committee and (ii) Chief Operating Officers of the Investment Adviser's investment strategies in which the Investment Funds participate; recruiting-related expenses (including, but not limited to, fees and expenses of third-party recruiters; internal referral payments; recruitment-related travel and lodging, meals, and entertainment; relocation expenses, legal fees, acquisition costs and other expenses related to the recruitment of Investment Team members); legal fees and expenses related to Investment Team members; meals; relocation expenses; market data, hardware and software expenses or similar expenses, including servers and other infrastructure (including cloud-based infrastructure) to the extent deployed in respect of the Investment Team; expenses related to communications systems and hardware, technology, services, and equipment (including dedicated or specialized links to trading venues, brokers, research and data providers, cloud-based computing, storage and services, and linkage to and connectivity with more general internet and telecommunications service providers); telephone/mobile services expenses; services related to the Investment Adviser’s research and investment functions, including corporate access charges; and travel and lodging related to the Investment Team function and other expenses incurred by or attributable to the Investment Team.

For reference, the Management Committee consists of some of the Investment Adviser’s most senior leadership. The size of the Management Committee can and will vary over time; it currently consists of the senior heads of business of the Investment Adviser and works directly with the Investment Adviser’s Investment Committee to develop and execute on business initiatives designed to enable the Investment Adviser to deliver risk-adjusted returns in all market cycles. The Management Committee does and will spend time and attention on issues faced by the Investment Adviser, its affiliates, partners and employees, as well as the clients it advises, such as the Investment Funds. The Investment Team includes, without limitation:

the Portfolio Managers; the Management Committee; analysts (including personnel focused on fundamental and quantitative research and personnel associated with data sourcing, strategy, analysis, processing and deployment); certain personnel that are part of business lines that support Portfolio Manager development, research and investment programs; trading (including personnel dedicated to optimizing the Investment Adviser’s investment strategies, central liquidity book personnel and syndicate desk personnel, etc.), trading assistants, brokerage and corporate access support personnel; portfolio finance and treasury personnel; risk management personnel; internal recruiting professionals and other business development and recruiting personnel (to the extent engaged on behalf of the Investment Team);

programmers, developers and application, data, and technology support personnel who participate in the investment program and/or support the Investment Team; professional development personnel, including Portfolio Manager and analyst development personnel; corporate strategy personnel, to the extent of their participation in the investment program; personnel attached to new business lines that are developed and launched, at times and from time to time, for the Investment Funds by the Investment Adviser; third-party consultants employed by the Investment Adviser to assist with functions relating to the Investment Team; and other Investment Team-related support personnel (e.g., administrative support personnel) (collectively, the “Investment Team”).

“Compensation” of the Investment Team members includes, without limitation:

salaries/draws; benefits (including, but not limited to, healthcare contributions, premiums and claims); payroll, withholding and similar taxes, sales or other taxes for non-employee Investment Team members; workers’ compensation contributions; 401(k) and similar retirement or savings plan contributions and administration fees; severance; professional dues and professional development related expenses; performance-based compensation, signing bonuses (which may be in the form of buyouts of prior deferred compensation or other incentive plans attributable to previous employers); and retention bonuses.

To the extent that Investment Team members also perform other services for BAM, or for additional Investment Funds managed by BAM, such expenses will be allocated across Investment Funds and/or to BAM based on a good faith methodology. In general, expenses, costs and liabilities borne by a particular trading program will be allocated to the classes or sub-classes of an Investment Fund that participates in such trading program (to the extent feasible to do so). While BAM believes its allocation methodology is appropriate, it involves good faith, but subjective judgment by BAM based on certain estimates and assumptions, which may be imprecise and could result in the Investment Fund bearing a larger portion of such expenses than if the allocations had been calculated in a different manner. Additionally, BAM will make these expense allocation determinations according to metrics that it determines to be reasonable, but such determinations will not be wholly objective, and the metric utilized may change over time. In considering whether and how to allocate an expense, BAM will consider factors such as whether such expense might ultimately directly or indirectly benefit BAM, one or more Investment Funds other than the initial beneficiary, or Other Accounts, and whether such expense is de minimis in nature, and/or whether the expenses associated with determining and administering such allocation would be disproportionate relative to the actual expense to be allocated. BAM’s expense allocation procedures are intended to establish an equitable, and administratively practical, approach to allocating shared expenses among BAM, the Investment Funds, and Other Accounts. While it is generally not possible to precisely determine the portion of a shared resource that was utilized for the benefit of a particular Investment Fund, strategy, account, or project, the methodologies utilized are intended to establish a reasonable basis for approximating such utilization. The following is a non-exhaustive list of examples of expense allocation methodologies that may be employed by BAM including, but not limited to, allocating based on: (i) an average cost basis (i.e., allocating total expenses based on a reasonable estimate of proportionate utilization, such as head count, licenses, or consumption metrics) or a marginal cost basis (i.e., charging for the incremental cost of additional utilization); (ii) independent third-party pricing for comparable transactions, goods, or services;

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Item 5: Fees and compensation Fees

No one under BAM’s supervision or control is compensated for the sale of interests in the Investment Funds.

Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks

Please review all risks detailed in Item 8.B. above. Item 9

Disciplinary Information

Item 9.A. Not applicable Item 9.B. In December of 2018, the Swedish Financial Supervisory Authority (“Finansinspektionen” or “SFSA”) determined that BAM’s relying adviser, Balyasny Europe Asset Management LLP (“BEAM”) made a late net short position notification to the SFSA (less than a month late). BEAM appealed the decision. However, the appeal was unsuccessful. The appeal was decided on September 6, 2019; however, BEAM was not notified of the decision. As a result, the matter was not concluded until such time BEAM was made aware of the final decision. The total settlement amount of $15,416 was levied against BEAM and the settlement amount was paid on November 5, 2020. As of November 1st, 2023, BEAM changed its name to Balyasny Asset Management (UK) LLP.

Item 7: Types of clients

Type of Clients

BAM provides investment advisory services to privately offered pooled investment funds. The investors in the Investment Funds include, but are not limited to, high net worth individuals, family offices, other private investment funds, funds of funds, investment companies, trusts, estates, U.S. and nonU.S. institutions, charitable institutions, sovereign wealth funds, foundations, endowments, municipalities, corporate pensions and profit-sharing plans, and other institutional clients. The Investment Funds are formed as limited partnerships, limited liability companies, and offshore corporations and trusts. As described in Item 4.B, the Investment Funds that are offered within U.S. Offerings are available only to persons who are “accredited investors” under the Securities Act, and only to persons who are “qualified purchasers” under the IC Act. Additionally, all investors must also be “qualified clients” under the Advisers Act. The Investment Funds are not registered as investment companies under the IC Act and are not made available to the general public. Interests in the Investment Funds are offered only by means of a private placement memorandum or a limited partnership agreement (collectively referred to as an “offering memorandum”). Item 8

Methods of Analysis Investment Strategies and Risk of Loss

Item 8.A. Investing is speculative and involves a high degree of risk. BAM will employ certain trading techniques, as described in Item 8.A. and Item 8.B., which may increase the risk of investment loss. As a result, an investor could lose all or a substantial amount of his or her investment. The Investment Funds managed by BAM include multi-strategy investment funds. BAM’s investment advisory services reflect a blend of strategies including fundamental long/short equity, fixed income & macro, commodities, systematic trading, and multi-asset arbitrage investing. BAM’s long/short equity and equity trading strategies include (but are not limited to) investments and trading in the following market sectors: Energy, Health Care, Financials, Industrials, Information Technology, Consumer Staples and Consumer Discretionary. BAM utilizes various analysis techniques including, but not limited to, technical analysis, fundamental analysis, and cyclical analysis. The analysis conducted by BAM for its long/short equity and multi-asset arbitrage strategies include, but is not limited to, company specific financial modeling, comprehensive review of earnings reports, interaction with analysts employed by broker-dealers and research vendors, interaction with industry experts as well as interaction with investor relations personnel employed by the companies whose securities or credit instruments the Investment Funds trade. The analysis conducted by BAM for its fixed income & macro strategy include, but is not limited to, global macroeconomics, policy decisions of central banks, as well as (but not limited to) data related to gross domestic product, consumption, investment, monetary and employment/unemployment data on a global basis. The analysis conducted by BAM for its commodities strategies include, but is not limited to, international political and economic developments, global or regional supply and demand, facilities used for the production, storage, or transport of commodities, and changes in government regulation as well as weather, prevailing prices of commodities, labor relations, operating failures, and business interruptions. The analysis conducted by BAM for its quantitative strategies includes the development of trading systems that involve financial, economic, econometric and statistical theories, research, and modelling, which are then translated into computer code.

The primary sources of information utilized by BAM include (but are not limited to) fundamental proprietary research and analysis developed by BAM, research reports and materials prepared by brokerdealers and other research vendors, financial newspapers and magazines, annual reports published by publicly listed companies and private companies, prospectuses, SEC and other regulatory filings, company press releases, corporate rating services, and data published by governments, central banks, exchanges, and clearinghouses. Regulators have recently increased their scrutiny of alternative data providers and market participants that use alternative data. There are certain risks associated with alternative data that require a process to review the vendors providing this type of data, the data collection techniques, and the data products themselves. The implementation of alternative data into the investment process carries certain risks, which require oversight. A lack of sufficient oversight and controls can result in regulatory scrutiny. Item 8.B. Please see Item 11.C. for details on BAM’s trade allocation policy. BAM’s various trading strategies may result in greater portfolio turnover and, consequently, greater transaction costs to the Investment Funds. An investor should be aware that it may lose all or part of its investment in the fund. All investments risk the loss of capital. BAM believes the Investment Funds’ research techniques will moderate this risk through a careful selection of securities, commodities, currencies, credit instruments, hedging, and the use of other financial instruments. However, no guarantee or representation is made that the Investment Funds’ investment program will be successful. Investment results may vary substantially over time. The Investment Funds may engage in, among others, options and futures transactions, margin transactions, short sales, forward contracts, total return swaps, credit default swaps, interest rate swaps, utilize leverage and have limited diversification, all of which can amplify negative performance in the Investment Funds’ portfolios. The success of the investment program depends on the ability of the Portfolio Managers to identify overvalued and undervalued investment opportunities and to exploit price discrepancies in the markets that the Portfolio Manager trades. Identification and exploitation of investment opportunities and the use of various trading strategies involves uncertainty. No assurance can be given that the Portfolio Managers will be able to correctly locate trading opportunities or exploit price discrepancies. In the event that the Portfolio Manager is incorrect in identifying perceived mispricing, the Investment Funds may incur losses. The Investment Funds may, from time to time, invest in both listed and unlisted securities that are traded on a securities exchange or traded over-the-counter respectively. The volume of trading in unlisted securities is generally less than that found on securities exchanges. Therefore, it may be more difficult to buy and sell these securities, which increases the volatility of their share prices. Equity securities fluctuate in value in response to many factors, including (but not limited to) the activities and financial condition of individual issuers, public sentiment, the market in which such companies compete and industry market conditions and general economic environments. Merger Arbitrage/Events is a strategy that seeks to profit from changes in the price of securities of companies involved in extraordinary corporate transactions. The difference between the price paid by an Investment Fund for securities of a company involved in a publicly known corporate transaction and the anticipated value to be received for those same securities upon completion of the proposed transaction will often be very small. Since the price bid for the securities of a company involved in an announced corporate transaction will generally be at a significant premium above the market price prior to the announcement, if the proposed transaction appears likely not to be completed or in fact is not completed or it is delayed, the market price of the securities will usually decline sharply, perhaps by more than the Investment Funds’ anticipated profit. The Merger Arbitrage business is extremely competitive. In any given transaction,

arbitrage activity by other firms will tend to narrow the spread between the price at which a security may be purchased by the Investment Funds and the Investment Funds expect to receive upon completion of the transaction. The Investment Funds may take positions to profit from index rebalances. Due to the large number of funds that now explicitly or implicitly track various equity indices around the world, additions and deletions of specific securities from a widely followed equity index can lead to substantial trading opportunities. For example, the addition of a stock to a particular index may lead to a significantly increased demand for that stock even after the announcement date. Successful index rebalancing efforts by the Investment Funds will be contingent upon BAM’s ability to predict movements in the price of specific stocks in light of related market considerations. Certain investments of the Investment Funds may involve start-up companies, companies developing new products or companies seeking to raise additional capital for expansion. In addition, the Investment Funds may invest in companies involved in bankruptcy or other reorganization and liquidation proceedings. Although such investments may result in significant returns to the Investment Funds, they involve a substantial degree of risk. Any one or all of the issuers of the instruments in which the Investment Funds may invest, directly or indirectly, may be unsuccessful or not show any return for a considerable period of time. The level of analytical sophistication, both financial and legal, necessary for successful investment in companies experiencing significant business and financial difficulties is unusually high. There is no assurance that the Investment Funds will correctly evaluate the nature and magnitude of the various factors that could affect the prospects for a successful reorganization or similar action. In any reorganization or liquidation proceeding relating to a company in which the Investment Funds participate, the Investment Funds may lose their entire investment or may be required to accept cash or instruments with a value less than the Investment Funds’ original investment. Special purpose acquisition companies, commonly referred to as “SPACs,” are publicly traded companies formed for the purpose of raising capital through initial public offerings to fund the acquisition, through a merger, capital stock exchange, asset acquisition or other similar business combination, of one or more operating businesses. Following the acquisition of a target company, a SPAC may exercise some degree of control over the management of such target company. Capital raised through the initial public offering of securities of a SPAC is typically placed into a trust until a target company is acquired or a predetermined period of time elapses. Investors in a SPAC would receive a return on their investment in the event that a target company is successfully acquired and the securities of the combined company increased in value relative to the pre-transaction value of the SPAC securities. In the event that a SPAC is unable to locate and acquire a target company by the deadline, the SPAC would typically be forced to liquidate its assets, which may result in losses due to the expenses and liabilities of the SPAC. Investors in a SPAC are subject to the risk that, among other things, (i) such SPAC may not be able to locate or acquire a target company by the deadline, (ii) assets in the trust may be subject to third-party claims against such SPAC, which may reduce the per share liquidation price received by the investors in the SPAC, (iii) such SPAC may be exempt from the rules promulgated by the SEC to protect investors in “blank check” companies, such as Rule 419 promulgated under the Securities Act, so that investors in such SPAC may not be afforded the benefits or protections of those rules, (iv) such SPAC may only be able to complete one business combination, which may cause it to be solely dependent on a single business, (v) the value of any target company may decrease following its acquisition by such SPAC, (vi) the value of the funds invested and held in the trust decline, (vii) the investor in the SPAC may not be able to redeem due to the failure to hold the securities in the SPAC on the record date or the failure to vote against the acquisition and (viii) if the SPAC is unable to consummate a business combination, public stockholders will be forced to wait until the deadline before liquidating distributions are made. In addition, interests in most SPACs are relatively illiquid and have a concentrated shareholder base that tends to be comprised of institutional investors, including hedge funds. Certain Investment Funds may, and often do, invest in a SPAC that, at the time of investment, has not

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Item 6: Performance-based fees and side-by-side management Conflicts of interest

Item 5.A. of this Brochure contains additional guidance on the Incentive Allocations or carried interest that each Investment Fund is responsible for. Please see Item 5.A. for this information. BAM manages several Investment Funds, some of which are arranged in a “master-feeder” structure. Investors invest their capital into “feeder funds.” The “feeder funds” typically invest all of their assets into a “master fund”. The master fund then invests all of its investable assets in “trading subsidiaries”. Under this structure, all trading is done by the trading subsidiaries. Certain feeder funds within a particular masterfeeder structure charge fees that are higher (or lower) than the other feeder funds in the same master-feeder structure. In addition, feeder funds may have more than one share class or investment option, and therefore, management fees and/or Incentive Allocations will be higher (or lower) for one share class or investment option than the other share classes or investment options. Because of the different Incentive Allocations charged by the feeder funds, there are inherent incentives to favor the feeder funds that are responsible for a higher Incentive Allocation. However, because the trading takes place at the Trading Subsidiary (as defined in Item 11.C) level and ownership of the portfolio investments are directly attributed to the trading subsidiaries, BAM is able to allocate the profit and loss of the assets to each specific investor in proportion to their ownership percentage of the master fund’s total assets (which in turn owns a percentage of the Trading Subsidiaries), thereby, mitigating the incentive to favor the feeder funds with the higher Incentive Allocation.

BAM’s trade order aggregation and allocation process is also intended to mitigate the inherent incentive to favor a fund structure (for example, one that charges higher fees) over another fund structure (one that charges lower fees). Please see Item 11.C. for greater detail on BAM’s allocation process.

Item 10: Other financial industry activities and affiliations Conflicts of interest

Not applicable Item 11

Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Item 11.A. BAM (including the Relying Advisers) have adopted a code of ethics in accordance with Rule 204A-1 under the Advisers Act and each non-U.S. Relying Adviser has adopted a code of ethics taking into account modifications as required by local laws or regulations (all such codes of ethics collectively, the “Code”). BAM prohibits employees from using or attempting to use their position at BAM to obtain improper personal benefits for themselves or any other person. Any exceptions to the Code require prior approval by a member of the Compliance Department. The Code sets out standards of business and personal conduct for each BAM Employee and addresses conflicts that arise from personal trading and personal investments by such persons and provides for disciplinary sanctions for Code violations. For purposes of the Code, “Employee” means any officer, member, partner, employee and personnel of BAM that is subject to the Code. The Code’s prohibitions apply to direct activity as well as indirect activity taken to avoid the Code’s prohibitions. The policies and procedures set forth in the Code recognize that an investment adviser is in a position of trust and confidence with respect to its clients. The Code includes a code of conduct which requires Employees to (i) abide by standards of ethical conduct in their relationships with each other, the Investment Funds, BAM’s investors, BAM’s competitors, and the public; (ii) adhere to standards with respect to any potential material conflicts of interest with the Investment Funds; and (iii) preserve the confidentiality of information that they may obtain in the course of BAM’s business and use such information properly and not in any way adverse to the interests of any of the Investment Funds, subject to the legality of using such information. The Code also includes a personal securities investment and reporting policy. This policy, among other things, restricts an Employee’s ability to engage in certain personal securities transactions without the prior consent of the Compliance Department and requires reporting of any such transactions. The Code restricts Employees’ ability to conduct certain activities outside the firm and places limits on the value of gifts that may be received and/or given by Employees. A copy of BAM’s Code of Ethics and Personal Trading Policy is available to investors and prospective investors upon request by calling (212) 808-2300 and asking to speak to someone in the Compliance Department. Item 11.B. BAM, in its capacity as investment manager to Atlas Enhanced Master Fund, Ltd. (“AEMF”), Atlas Enhanced Portable Alpha Master Fund II, Ltd. (“AEPAMF2”), and Atlas Enhanced Portable Alpha Master Fund III, Ltd. (“AEPAMF3”) recommends that AEMF, AEPAMF2, and AEPAMF3 purchase interests in Atlas Macro Master Fund, Ltd. (“AMMF”), Atlas Singapore Master Fund PTE. Ltd. (“ASMF”), Atlas Peak,

Ltd. (“APEAK”), Atlas Spark, Ltd. (“ASPARK”), Atlas Diversified Master Fund, Ltd. (“ADMF”), Atlas Global Trading Ltd. (“AGT”), and Atlas Alternative Strategies Master Fund, Ltd.(“AASMF”). BAM, in its capacity as investment manager to Atlas Leverage Feeder, LLC (“ALF”), recommends that ALF purchase interests in ADMF and ASMF. AEMF, AEPAMF2, and AEPAMF3 collectively wholly own 100% of AMMF, AGT, AASMF, APEAK, and ASPARK. The collective 100% ownership is adjusted monthly. AEMF, AEPAMF2, AEPAMF3, and ALF collectively own approximately 100% of ADMF and ASMF, where the ownership is adjusted monthly. Similarly, BAM, in its capacity as investment manager to AEMF, recommends that AEMF purchase interests in BAMAVT 1 LLC (“AVT”), Atlas Private Holdings, LLC (“APH”), Atlas Private Holdings II, LLC (“APH II”), Atlas Private Holdings III, LLC (“APH III”), Atlas Private Holdings V, LLC (“APH V”), Atlas Private Holdings VI, LLC (“APH VI”), Atlas Private Holdings VII, LLC (“APH VII”) Atlas Private Holdings VIII, LLC (“APH VIII”), Atlas Plus Privates Fund, LLC (“APPF”), Atlas Private Holdings (Cayman) II, Ltd. (“APH Cayman II”), Atlas Private Holdings (Cayman) III, Ltd. (“APH Cayman III”), Longaeva Private Growth I, LLC (“LPGI”), Longaeva Private Growth II, LLC (“LPGII”), and Longaeva Private Growth III, LLC (“LPGIII”). AEMF owns approximately 98% of AVT, approximately 97% of APH and APH II, and wholly owns 100% of APH III, APH V, APH VI, APH VII, APH VIII, APPF, APH Cayman II, APH Cayman III, LPGI, LPGII, and LPGIII. BAM, in its capacity as investment manager to ADMF, recommends that ADMF purchase interests in Atlas Private Holdings (Cayman) Ltd. (“APH Cayman”). ADMF wholly owns 100% of APH Cayman. BAM, in its capacity as investment manager to AMMF, recommends that AMMF purchase interests in Atlas NG LLC (“ANG”), Atlas Power, Ltd (“APOW”), and Atlas Macro Japan, Ltd. (“AMJP”). AMMF wholly owns 100% of ANG, APOW, and AMJP. BAM, in its capacity as investment manager to Atlas Peak, Ltd. (“APEAK”), recommends that APEAK purchase interests in Atlas Power (Central), Ltd. (“APOWC”), Atlas Power (East), Ltd. (“APOWE”), Atlas Power Southwest Ltd. (“APOWSW”), Atlas Power (TX), Ltd. (“APOWTX”), Peak Power I, Ltd. (“PPOWI”), and Peak Power II, Ltd. (“PPOWII”). APEAK wholly owns 100% of APOWC, APOWE, APOWSW, APOWTX, PPOWI, and PPOWII. BAM, in its capacity as investment manager to AEPAMF2 and AEPAMF3, recommends that AEPAMF2 and AEPAMF3 purchase interests in Atlas Enhanced Portable Alpha BH II, Ltd. (“AEPABH2”) and Atlas Enhanced Portable Alpha BH III, Ltd. (“AEPABH3”) respectively. AEPAMF2 wholly owns 100% of AEPABH2. AEPAMF3 wholly owns 100% of AEPABH3. BAM, in its capacity as investment manager to AGT recommends that AGT purchase interests in AGTF I, Ltd (“AGTFI”) and AGTF II, Ltd. (“AGTFII”). AGT wholly owns 100% of AGTFI and AGTFII. BCM is the general partner of Atlas Enhanced Fund, L.P., Atlas Institutional Equity Fund, L.P., Atlas Opportunistic Fund, L.P., and Longaeva Private Growth I, L.P. BAM Elevate GP, LLC is the general partner of the Atlas Access Funds. BCM and BAM Elevate GP, LLC are collectively referred to as the “General Partners.” In order to mitigate the conflict of advising certain Investment Funds managed by BAM to invest in other Investment Funds also managed by BAM, BAM does not permit these investors to obtain terms that are more favorable than the terms offered to any other investor. Notwithstanding the immediately preceding sentence, the feeder funds may redeem from the master funds and the master funds may redeem from the trading subsidiaries, without being subject to the liquidity restrictions applicable to all investors in the feeder funds (including BAM employees), in order to implement the Investment Funds’ investment programs and carry out their operations. It should be noted, however, that employees that are permitted to invest in the Investment Funds are typically charged a reduced Incentive Allocation or are not charged an

Incentive Allocation at all (depending on the specific Investment Fund). Further, partners of BAM do not pay a Management Fee or an Incentive Allocation. Through its marketing efforts, BAM solicits investors and prospective investors to invest in the Investment Funds. Likewise, in its capacity as investment adviser, BAM recommends the Investment Funds to investors and prospective investors. BAM mitigates this conflict by ensuring that its marketing efforts adhere to applicable securities and anti-fraud rules. As discussed in Item 5.A, BCM, BAM, or their respective affiliates may purchase and warehouse certain Warehoused Investments on behalf of the Investment Funds. BCM, BAM, or their respective affiliates are subject to conflicts between acting in the best interests of the Investment Funds and assisting themselves by selling the Warehoused Securities to an Investment Fund. In addition, BCM, BAM, or their respective affiliates may have information regarding the Warehoused Investments which are not available to prospective investors in the Investment Funds, due to confidentially restrictions with third parties or otherwise. BAM manages such conflicts by transferring such Warehoused Investments to an Investment Fund for a purchase price equal to the price paid plus reasonable out-of-pocket costs and expenses incurred in the acquisition of such Warehoused Investment, including interest and financing costs. No assurances can be given that such Warehoused Investment will be profitable for the Investment Funds. Given the illiquid nature of the Warehoused Investments, it is impossible to know their true fair market value at the time they are purchased by the Investment Fund, which value may be substantially less (or more) than the price at which the Warehoused Investment were purchased on behalf of the Investment Funds. As such, investors in the Investment Funds will be assuming the risk of fluctuations in fair market value of the Warehoused Investment from the date such Warehoused Investments were initially acquired by BCM, BAM, or their affiliates for the Investment Funds. Item 11.C. BAM follows certain policies and procedures for the aggregation of orders and allocating investment opportunities on behalf of Investment Funds, described below. In general, BAM will execute transactions on behalf of each of the Investment Funds (i) on a fair and equitable basis and (ii) pursuant to its obligations to seek to obtain best execution and realize favorable commission rates (or other transaction costs). BAM and its affiliates are, and may continue to be, affiliated with and render services to Investment Funds or Other Accounts (as defined in Item 11.C), as a result of which they will have a need to allocate time, as well as trading and investment opportunities (“Investment Opportunities”), between Investment Funds or Other Accounts. Certain of these Investment Funds or Other Accounts may have goals and trading strategies that are substantially similar to those of other Investment Funds or Other Accounts. In addition, BAM, BCM, or Dmitry Balyasny may in the future serve as the investment manager or a general partner of additional entities and managed accounts. Participation in specific Investment Opportunities may be appropriate, at times, to Investment Funds or Other Accounts with similar investment objectives. In such cases, BAM will determine whether participation in such Investment Opportunity on an aggregate basis among the Investment Funds or Other Accounts is appropriate. In making this determination, BAM will take into account several factors, including, without limitation, the risk-return profile of the proposed investment; investment guidelines; investment restrictions; investment objectives; investment program; diversification requirements; risk parameters and risk tolerance; available cash and/or liquidity requirements; exposure limitations and/or considerations; hedging; applicable counterparty relationships; tax, legal, or regulatory reasons; redemptions or other capital allocation changes; avoidance of odd-lots; avoidance of de minimis allocations; leverage considerations, including, margin and financing considerations; substitution, reinstatement, restoration, and/or “re-establishment” of comparable and/or relative exposure; position sizing; required or anticipated holding period(s); whether an Investment Fund or Other Account have an existing investment related to the Investment Opportunity; whether an Investment Fund or Other Account is subject to differing portfolio conditions or capital activity (i.e., inflows and outflows); an Investment Fund’s or Other Accounts’ structure and terms; whether an Investment Fund or

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Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest

BAM will not engage in principal transactions unless consent has been granted by all appropriate parties or such action otherwise comports with the Advisers Act (and other applicable securities laws). However, BAM may cause a security to be traded between two clients where it believes such trade to be in the interest of each client. BAM generally has such authority under the general grant of investment discretion given to

it by its clients. BAM’s practice is to engage in cross trades in limited circumstances where the purchase and sale of the same security at the same time by different clients helps to achieve more favorable terms to each client than through separate transactions not involving a cross trade. These circumstances can arise when a client wishes to sell a security to generate cash or to realign such client’s asset allocation at a time when BAM would like to purchase the security for other clients (for example, when rebalancing a fund (whether intra-month or at the beginning of a month)). Such transactions may also occur regularly and frequently. Cross transactions may also occur if one Portfolio Manager is exiting or reducing a position and another Portfolio Manager is building or increasing a position in the same security. In some cases, BAM may determine to reallocate assets (which may involve generating cash to fund withdrawals or investing new capital) within the Investment Funds and thereby create a need to sell the security from one Investment Fund and a need to purchase the same security in another Investment Fund. BAM’s duty to be unbiased and fair to clients on both sides of a cross transaction may pose an inherent conflict of interest. Cross transactions will only be effected in accordance with applicable law. To ensure that it fulfills its duty to each client that is party to a cross transaction, BAM seeks to ensure the appropriateness of the transaction for each client and that it is fair to both sides of the transaction. Cross trades between clients are generally priced at the closing price as established by an independent broker, but are, from time-to-time, done intra-day at market price or over-the-day using a volume-weighted average price, time-weighted average price, or other weighted average price algorithm. In causing cross trades to be effected between Investment Funds, BAM will effect a journal transaction with the Investment Funds’ prime brokers, generally at no cost, or utilize an unaffiliated broker-dealer at normal commission rates. Cross transactions require prior approval by a member of the Compliance Department. In addition to the above, BAM may correct misallocations of trades among client accounts by re-allocating the applicable trade using the intended allocation methodology prior to the trade’s settlement date (or as otherwise permitted under applicable exchange rules). If an erroneous allocation cannot be corrected prior to or after settlement, BAM may, if appropriate and subject to applicable law, correct the erroneous allocation by effecting a cross-trade between client accounts at the price at which the initial trade was effected. Private Companies may be shared with co-investors, either directly or through co-investment vehicles such as the Atlas Access Funds. Given the inherent conflict of interest present in co-investment opportunities, and to ensure that BAM allocates Private Companies in a manner that fulfills its fiduciary duty to treat clients fairly, BAM has developed policies and procedures around the allocation of such opportunities. Generally, and unless the Investment Funds are not interested in the investment opportunity, co-investors will not receive an allocation in Private Companies until the Investment Funds managed by BAM have received their entire allocation. Co-investment opportunities require approval from BAM’s Compliance Department. Teton Venture Partners GP I, LLC (“Teton GP”) is the general partner for an early (primarily, venture) stage fund of funds vehicle, Teton Venture Partners I, L.P. (“Teton”). Teton GP is under common ownership and control of BAM. The investor base for Teton primarily consists of partners and employees of BAM and BAM’s affiliates. Teton has a different investment strategy than the Investment Funds. Teton will generally seek investment opportunities in unaffiliated venture capital and private equity funds (collectively “VC Funds”) as opposed to direct investments in Private Companies (as the Investment Funds may make from time-to-time). VC Fund investment opportunities are generally appropriate for Teton, and not for the Investment Funds, which do not make investments in VC Funds. Despite the differing investment strategies, any potential conflicts of interest will be reviewed by BAM’s Compliance Department.

The Investment Adviser may identify vendor relationships where it would seek to obtain, on behalf of the Investment Funds, a subscription for a vendor’s research. However, in certain of these instances the Investment Adviser may determine that a strategic investment (either in lieu of a subscription, or alongside of a (possibly reduced) subscription) into the vendor is likely to offer additional benefits to the Investment Funds. Given the size (and valuation) of such vendors, the Investment Adviser would not typically consider them as a fund investment for the Investment Funds. However, an immaterial investment (as compared to the net asset value of the Investment Funds) may still be made if the Investment Adviser expects the investment to offer benefits to the Investment Funds (e.g., the ability to have tier-one access to a vendor, to work with a vendor to build a product customized to the needs of the Investment Funds, or to have advance access to new products being beta-tested by a vendor). In these and similar circumstances, the Investment Funds may make these types of strategic investments that are expected to benefit the Investment Funds, even if capital appreciation is not the primary reason for the investments. These strategic investments are expected to be a very small percentage of the total research and vendor budget of the Investment Funds. The actual benefits for the Investment Funds from such strategic vendor relationship in return of such investments could be less than expected and could benefit one or more Investment Funds more than another Investment Fund. In particular, not all the benefits received from such strategic vendor relations may be used by the Investment Adviser in connection with all of the Investment Funds. Nonetheless, the Investment Adviser believes that any such strategic vendor relationship provides the Investment Funds with benefits as described above that would otherwise not be available to the Investment Funds. Dmitry Balyasny (or his immediate family members and/or controlled entities), as well as other partners and/or employees of the Investment Adviser (collectively with Dmitry Balyasny, “BAM Investors”) and other funds or accounts managed by the Investment Manager or its affiliates, may invest in pooled investment vehicles (such as venture capital, private equity, or hedge funds) that are managed by thirdparty investment managers (each, a “Private Fund”). Through these investments, the Investment Adviser may be introduced to the underlying portfolio companies of the Private Funds and evaluate them for a potential direct investment by the Investment Funds. If the Investment Funds ultimately invest directly in any such portfolio company, it would likely do so at a higher valuation than the relevant Private Fund, and thereby, indirectly, BAM Investors. From time to time, certain Portfolio Managers will recommend that the Investment Funds make investments in portfolio companies similar to those described above. In addition to capital appreciation, these investments are also expected to provide improved access to investment opportunities in later-stage private companies that are more mature businesses and therefore, more appropriate from a risk/reward perspective for the Investment Funds to invest in. In addition to Private Funds, Dmitry Balyasny (or his immediate family members and/or controlled entities), as well as other BAM Investors and other funds or accounts managed by the Investment Manager or its affiliates, may invest in or otherwise participate in businesses, including start-ups, in which the Investment Funds later directly invests (including through a growth strategy) or ultimately engages as service providers. If an Investment Fund were to invest in a company that a BAM Investor and/or other funds or accounts managed by the Investment Manager or its affiliates had previously or currently are invested in, it might do so at a higher valuation, and such investment might indirectly benefit the BAM Investor and other funds or accounts managed by the Investment Manager or its affiliates. If the Investment Fund were to engage a service provider that a BAM Investor had previously or currently is invested in, it might also indirectly benefit the BAM Investor and/or other funds or accounts managed by the Investment Manager or its affiliates. Service providers will only be engaged if the Investment Manager determines that the arrangement is in the best interests of the Investment Fund and the terms are negotiated on an arm’slength basis.

It should be noted that the vast majority of Mr. Balyasny’s net worth is invested in the strategies of the Investment Funds; accordingly, Mr. Balyasny’s interests in the Private Funds and other businesses described above are a very small percentage of his total investments. In part, these investments are made with the goal of creating access and opportunity for the Investment Funds to potentially invest in a small number of attractive companies as they mature. In addition to the foregoing, third-party investment managers may present investment ideas to the Investment Adviser that the Private Funds have invested in. After the Investment Adviser conducts its own research and analysis, the Investment Adviser may also recommend that the Investment Funds make an investment in the same company. It should also be noted that, in certain instances, the Investment Adviser may have an ownership interest in the third-party investment manager that presented the recommendation. It should be further noted that these private companies are, at some point, expected to be taken public through the initial public offering process (“IPO”). This may lead to a situation where the Private Funds are selling shareholders in the IPO and the Investment Funds purchase shares in that same offering. It should be noted that all strategic vendor investments and all private investments will generally be allocated among the Investment Funds in accordance with the Investment Adviser’s aggregation and allocation policies and procedures (as described in Item 11.C.). Please see Item 11.A. for details on BAM’s Code of Ethics and Personal Trading Policy. Item 12

Brokerage Practices

Item 12.A. BAM allocates transactions to broker-dealers for execution on markets/exchanges and at prices and commission rates that in BAM’s good faith judgment are in the best interest of the Investment Funds. BAM takes into consideration primarily available prices, brokerage commission rates, and other relevant factors including, but not limited to, execution capabilities, the size of the transaction, the difficulty of execution, the operational facilities of the broker-dealer involved, the risk in positioning a block of securities, the quality of the overall brokerage and research services provided by the broker-dealer, the broker-dealer’s willingness to commit capital and the value of an ongoing relationship with such broker-dealer. Research services include, but are not limited to, economic forecasts, investment advice, fundamental and technical advice, market analysis, statistical services and analyses of particular securities and investment situations. Some of these services are considered part of a “soft dollar” arrangement, as described in greater detail below. Where these services are provided by an executing broker-dealer, the Investment Funds may pay a brokerage commission in excess of that which another broker-dealer might have charged for effecting the same transaction if BAM determines in good faith that the amount of commission is reasonable in relation to the value of the brokerage and research services provided by the broker-dealer (viewed in terms of either the particular transaction or BAM’s overall responsibilities with respect to the account over which it exercises investment discretion). BAM currently uses commission dollars generated by the Investment Funds’ trades to pay for third-party research and brokerage products. This is commonly referred to as paying with “soft dollars.” Research may include, among other things, proprietary research from brokers, which may be written or oral; market, economic and financial data; performance measurement services; analyses concerning specific securities, companies, industries or sectors; statistical information; pricing data; databases; and quotation services. There are also instances where BAM receives investment research and access to, or discounts from, a brokerage firm’s (or such firm’s affiliate’s) research and/or trading platforms in exchange for trade orders. Certain of these soft dollar arrangements require BAM to generate a specific level of commissions in order to receive such research or brokerage products. All of BAM’s soft dollar usage is within the safe harbor

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Item 12: Brokerage practices Conflicts of interest

See Item 11.C. for more detail on BAM’s aggregation and allocation policy and procedures. Item 13

Review of Accounts

Item 13.A. and Item 13.B. All accounts are reviewed on a regular basis to determine their conformity with risk parameters, investment objectives, and guidelines. All accounts are reviewed in light of emerging trends and developments as well as market volatility. The Investment Committee meets monthly at a minimum to review the accounts. Multi-Portfolio Manager Process Each Portfolio Manager is evaluated on a regular basis to assess the continued effectiveness of his or her investment style and approach, as well as the associated risks thereof. BAM continues to monitor the Portfolio Managers’ performance, both on a stand-alone basis and in relation to the performance of all the Portfolio Managers. BAM regularly reassesses the allocation of the Investment Funds’ assets for possible reallocation among other Portfolio Managers or other investment strategies and at times when particular investment opportunities or market dislocations are recognized, and attempts to analyze prevailing and anticipated market conditions in determining which strategies have the best potential to be profitable. Each Portfolio Manager receives daily updates of portfolio positions and transactions for which such Portfolio Manager is responsible. Further, the Portfolio Managers and analysts meet regularly to review and discuss portfolio status, potential investments and related issues. External Subadvisor Program In general, External Managers follow investment strategies that are in-line with BAM’s investment program. External Managers are not employees of BAM. External Managers are responsible for the hiring of personnel and certain other aspects of their business. Although various levels of discretion may be given to External Managers, BAM remains responsible for monitoring the External Managers’ performance in the Investment Funds’ portfolio. BAM generally retains ultimate control of the accounts managed by such External Managers.

Item 14: Client referrals and other compensation Conflicts of interest

BAM currently uses the services of non-affiliated placement agents to offer interests in certain of the Investment Funds. From time to time, BAM may use additional placement agents as well. If BAM compensates such placement agents for their referrals, then these arrangements will be governed by Rule 206(4)-1 under the Advisers Act to the extent the arrangements are covered by the rule, as amended, as well as other forms of guidance (for example, no-action letters) provided by the SEC.

Item 9: Disciplinary information

Not applicable Item 10

Other Financial Industry Activities and Affiliations

Item 10.A. Not applicable Item 10.B. BAM became a CFTC registered Commodity Pool Operator (“CPO”) and National Futures Association member as of January 2013. Item 10.C. In 2011, BAM created BCM, an affiliate of BAM. BCM serves as the general partner to Atlas Enhanced Fund, L.P., Atlas Institutional Equity Fund, L.P., Atlas Opportunistic Fund, L.P., and Longaeva Private Growth I, L.P. BCM owns shares issued by AEMF, AEPAMF2, AEPAMF3, and the Atlas Opportunistic Master Fund, Ltd. (“AOMF”). BCM’s ownership of shares issued by AEMF, AEPAMF2, AEPAMF3, and AOMF allows BCM to collect the Incentive Allocation. The Incentive Allocation is the mechanism used in the place of a performance fee. The Incentive Allocation works by increasing the value of the shares owned by BCM by a percentage (refer to Item 5.A. and the specific offering memorandum for full details) of the excess of the realized and unrealized appreciation (if any) of the net asset value corresponding to each investor’s investment. The incentive allocation is subject to a “high-watermark” in order to prevent an incentive allocation from being taken on recuperated losses. In 2021, BAM created BAM Elevate GP, LLC, an affiliate of BAM. BAM Elevate GP, LLC serves as general partner to the Atlas Access Funds. BAM Elevate GP, LLC maintains a capital account in each of the Atlas Access Funds that allows the Atlas Access Funds to distribute carried interest to BAM Elevate GP, LLC (refer to Item 5.A and the specific offering memorandum for full details). Please see Item 6 and

Item 11.C. for details on how BAM addresses the conflict raised by the fact that certain Investment Funds are responsible for higher Incentive Allocations or carried interest. BAM is the beneficial owner of Balyasny Asset Management (UK) LLP (“BAM UK”) which is regulated by the Financial Conduct Authority of the United Kingdom (the “FCA”). Registration with the FCA permits BAM UK to conduct investment advisory services within the United Kingdom. In addition, BAM wholly owns the following subsidiaries: Balyasny Asset Management (Singapore) PTE. Ltd. (“BAM SG”). BAM SG is registered as an Asset Manager with the Monetary Authority of Singapore (“MAS”). Registration with MAS permits BAM SG to conduct investment advisory services within Singapore; Balyasny Asset Management (EQVOL) L.P. (“BAM EQVOL”) and its general partner BAM (EQVOL) GP LLC. BAM EQVOL is a Delaware Limited Partnership; Balyasny Asset Management (Hong Kong) Limited (“BAM HK”). BAM HK is registered as an Asset Manager with the Securities and Futures Commission of Hong Kong (the “SFC”). Registration with the SFC permits BAM HK to conduct investment advisory services within Hong Kong. BAM HK has entered into sub-advisory agreements with BAM and certain of the Investment Funds with all compensation being paid to BAM HK by BAM; Balyasny Asset Management (Japan) Limited (“BAM Japan”). BAM Japan is registered as a Discretionary Investment Manager with the Kanto Local Finance Bureau of Japan’s Ministry of Finance (the “KLFB”). Registration with the KLFB permits BAM Japan to conduct investment advisory services within Japan; Balyasny Korea Limited (“BAM Korea”), based in Seoul Korea, is a limited company; Balyasny Asset Management (Canada) ULC, (“BAM Canada”). BAM Canada is registered as a Portfolio Manager with the Ontario Securities Commission (“OSC”), the Alberta Securities Commission (“ASC”), and the British Columbia Securities Commission (“BCSC”). BAM Canada is registered as an Exempt Market Dealer with the OSC, ASC, BCSC, and Quebec Autorité des Marchés Financiers (“AMF”). BAM Canada is registered as a Commodity Trading Manager with the OSC. Registration with the OSC, ASC, BCSC, and AMF permits BAM Canada to provide regulated services to the Investment Funds within Canada; Balyasny Asset Management (Middle East) Limited (“BAM ME”), which is based in the Dubai International Financial Centre, holds a category 3C license (approved on June 9, 2023) and is authorized and regulated by the Dubai Financial Services Authority; Balyasny Management (Denmark) ApS (“BAM Denmark”), a private limited company registered in Denmark under the laws of the Danish Companies Act on 17 August 2023 under registration number CVRNO. 44 24 06 88; Balyasny Asset Management (Europe) Fondsmæglerselskab A/S (“BAM Europe”), a public limited liability company registered in Denmark under the laws of the Danish Companies Act on 1 December 2023 under registration number CVR-NO. 44 46 83 60. BAM Europe is authorized and regulated by the Danish Financial Supervisory Authority (“DFSA”), since October 8, 2024 under license number 8357; Balyasny Asset Management (AD) Limited (“BAM AD”), a private limited company registered in Abu Dhabi; Balyasny Asset Management (Puerto Rico) LLC (“BAM PR”), a limited liability company formed under the laws of the Commonwealth of Puerto Rico; and Longaeva Partners L.P. (“Longaeva Partners”) and its general partner, Longaeva Partners GP LLC.

BCM, BAM UK, BAM SG, BAM EQVOL, BAM HK, BAM Japan, BAM Korea, BAM Canada, BAM ME, BAM Denmark, BAM Europe, BAM AD, BAM PR, and Longaeva Partners are relying advisers to BAM (collectively, the “Relying Advisers”). BAM utilizes the Relying Advisers to manage a portion of the Investment Funds’ assets. Please see Item 6, Item 11.B., Item 11.C., and Item 11.D. for conflicts that may arise due to BAM’s management of multiple Investment Funds as well as how these conflicts are addressed by BAM.

Item 13: Review of accounts

Investors in the Investment Funds generally receive monthly or quarterly statements from the Investment Funds’ primary Administrator indicating their capital balances or net asset value. Additionally, investors in

the Investment Funds, other than the Atlas Access Funds, generally receive quarterly or annual letters highlighting the developments for the period. Investors in the U.S. domiciled Investment Funds are generally issued Schedule K-1s between March and May. Furthermore, audited financial statements are also provided to all investors within 120-days of fiscal year-end. Certain investors may receive additional information. Item 14

Client Referrals and Other Compensation

Item 14.A. Please see Item 12.A. for details concerning soft dollar benefits.

Item 15: Custody

On an annual basis BAM delivers audited financial statements to investors in the Investment Funds within 120-days of fiscal year-end. The Investment Funds are audited annually by an accounting firm that is a member of the Public Company Accounting Oversight Board. The audit of the Investment Funds is conducted in accordance with auditing standards and accounting principles that are generally accepted in the U.S. (i.e., U.S. GAAS and U.S. GAAP).

Item 16: Investment discretion

BAM has full discretion with respect to transactions and investments effected for the Investment Funds as well as full discretion to allocate capital to External Managers. This authority is granted pursuant to an investment management agreement (“IMA”) between BAM and the Investment Funds. Individual investors grant authority to the Investment Funds to enter into an IMA with BAM by signing the relevant subscription agreement. BAM exercises its investment discretion consistent with the applicable investment strategy, as well as any investment guidelines or restrictions imposed by the relevant Investment Fund and accepted by BAM. BAM does not advise clients concerning holdings outside their respective accounts that are managed by BAM. BAM generally has full authority to determine broker-dealers and counterparties to be utilized and commissions to be paid with respect to transactions effected for the Investment Funds. In all cases, this discretion is to be exercised in a manner consistent with the stated investment objectives for the particular Investment Fund.

Item 17: Voting client securities

BAM is generally responsible for determining how to vote all proxies with respect to securities held in the Investment Funds. BAM has retained the advisory services of Glass, Lewis & Co. (“Glass Lewis”) to provide research, vote execution, reporting, and recordkeeping services. To minimize material conflicts of interest, BAM generally follows voting guidelines established with Glass Lewis. However, certain BAM personnel may override the recommendations from the voting guidelines on a case-by-case basis, provided that BAM does not face a conflict of interest in voting such securities. BAM seeks to vote consistently on different issues in accordance with its policies and guidelines. However, recognizing the limitations of any policy to address all potential situations, BAM may use discretion when voting, considering the specific circumstances described in the proxy statement and other company disclosures, as applicable. In certain

instances, BAM’s vote may diverge from the preset voting guidelines should BAM determine it is in the best long-term interests of the Investment Funds. Additionally, BAM may abstain from voting (which generally requires submission of a proxy voting card) or affirmatively decide not to vote if BAM determines that abstaining or not voting is in the best interests of the Investment Funds. Investors that wish to obtain a record of BAM’s proxy voting policy or proxy voting history can contact BAM by calling (212) 808-2300 and asking to speak to someone in the Compliance Department. Item 18

Financial Information

Item 18.A. Not applicable Item 18.B. There are no conditions that impair BAM’s ability to meet its contractual and fiduciary commitments to its clients.

Item 18: Financial information

Neither BAM nor any of the Partners of BAM have been the subject of a bankruptcy proceeding in the past 10 years.

Filings

25 filings to the SEC since October 2021: 25 other. The latest 20:

  1. Aug 14, 202613F-HR EDGAR
  2. Aug 6, 2026N-PX/A EDGAR
  3. Jul 22, 2026N-PX EDGAR
  4. May 15, 202613F-HR EDGAR
  5. Feb 17, 202613F-HR EDGAR
  6. Nov 14, 202513F-HR EDGAR
  7. Aug 22, 2025N-PX EDGAR
  8. Aug 14, 202513F-HR EDGAR
  9. May 15, 202513F-HR EDGAR
  10. Feb 14, 202513F-HR EDGAR
  11. Nov 14, 202413F-HR EDGAR
  12. Aug 16, 2024N-PX EDGAR
  13. Aug 14, 202413F-HR EDGAR
  14. May 13, 202413F-HR EDGAR
  15. Feb 14, 202413F-HR EDGAR
  16. Nov 14, 202313F-HR EDGAR
  17. Aug 14, 202313F-HR EDGAR
  18. May 15, 202313F-HR EDGAR
  19. Feb 14, 202313F-HR EDGAR
  20. Nov 15, 202213F-HR EDGAR

The 25 filings since October 2021 can be filtered by form type and year here when JavaScript is on.

Every filing from the last five years, summarized. The full record is on SEC EDGAR.

Stakes it holds

BALYASNY ASSET MANAGEMENT L.P. has told the SEC it owns more than 5% of 56 companies, latest first (Schedules 13D and 13G).

All 56 companies

Sources

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