Private company

CR Group L.P.

American company, incorporated in Delaware. Summary from the record

Last updated Oct 21, 2026.

Overview

  • HeadquartersDE1

Corporate structure

CR Group L.P. is part of a group headed by Capital Royalty Holdings L.P.. 4 entities, 1 country on record. Switch between the flow chart and the network, and select any entity to see its details.

Major holders of CR Group L.P.

  • Caprx L.L.C. Owns control (general partner, trustee or manager) of Caprx Capital, since 04/2003 (Form ADV)
  • Nathan Dehass Hukill Owns 75% or more of Caprx L.L.C., since 03/2018 (Form ADV)
  • Capital Royalty Holdings L.P.

Built from major holders from Schedules 13D and 13G; stakes of 5% or more it reported on Schedules 13D and 13G (2 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

CR Group 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$2.2B2 10 accounts, all with discretion
  • Employees21 9 in investment advice or research
  • ClientsPooled investment vehicles (other than investment companies and: 10 ($2.2B)
  • How it is paidA percentage of assets under its management; Performance-based fees
  • What it doesPortfolio management for pooled investment vehicles (other than investment companies)
  • Holds client assetsYes: cash and securities
  • RegistrationSEC 801-63545, CRD 132967 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).

  • CAPITAL ROYALTY HOLDINGS L.P.owns 75% or more, since 12/2015
  • CAPRX L.L.C.owns general partner, trustee or manager of CAPRX CAPITAL, since 04/2003
  • Nathan Dehass Hukillowns 75% or more of CAPRX CAPITAL, since 03/2018
  • Nathan Dehass Hukillowns 75% or more of CAPRX L.L.C., since 03/2018

In its own words: the client brochure

Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/31/2026.3 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.

Item 4: Advisory business Services

CR Group L.P., a Delaware limited partnership (“CRG”, or the “Adviser”), is an investment advisory firm established in 2003 that primarily provides investment advisory services to pooled private investment partnerships (each, a “Fund” or together the “Funds”), and other institutional clients (collectively, the “Clients”). CRG’s investment strategy focuses on making debt and equity investments in companies operating in the healthcare sector (collectively, “Portfolio Investments”). CRG’s investment strategy covers a broad range of healthcare verticals, including biopharma, medical devices, tools, diagnostics, pharmaceuticals, and services. As of December 31, 2025 the Adviser had regulatory assets under management of $2.20 billion, all of which is on a discretionary basis. CRG’s team currently comprises 21 professionals including internal legal, accounting and compliance personnel, as well as professionals employed by Piedmont Evergreen LLC, an affiliate of the Adviser (“Piedmont Evergreen”). Piedmont Evergreen is based in Dorado, Puerto Rico and is registered as a relying adviser of the Adviser with the SEC. Piedmont Evergreen employs Nathan Hukill, the Adviser’s Chief Executive Officer. Members of the investment committee include Mr. Hukill, Luke Düster, the Adviser’s Chief Investment Officer, David Carter and Scott Li, each a Partner of the Adviser. Below outlines each investment committee member’s position and role/responsibility. Name

Role / Responsibility

• •

Strategic direction of CRG Day-to-day management and oversight of investments, investor relations and finance

CIO and Partner

• • •

Chief Investment Officer (“CIO”) Management of the investment team and process Portfolio management and investment structuring

David Carter

•

Head of tools & diagnostics vertical

•

Head of healthcare services and specialty pharma vertical

Nate Hukill Managing Partner Partner, Piedmont Evergreen

Luke Düster

Partner

Scott Li Partner

Item 5: Fees and compensation Fees

CRG generally receives an annual management fee (the “Management Fee”), as described in the Client’s respective Advisory Agreements, based upon (a) during the applicable Client’s investment period, either (1) total investor commitments or (2) total invested capital or the fair value of managed assets, and (b) thereafter, total invested capital or the fair value of managed assets, as such terms are defined in the Client’s operating agreement (the “Operating Agreement”). Under the terms of each Advisory Agreement, the Management Fee is generally payable quarterly in advance, prorated for the actual number of days if less than three months; in such a case, the Adviser will return the unearned portion to the Fund. Page 1 of 24

In addition, CRG may be entitled to receive carried interest or a performance fee (an “Incentive Fee”), as described in the respective Client’s Operating Agreement and Advisory Agreement. CRG may negotiate a specific fee arrangement with a particular investor pursuant to a side letter or other account agreement.

CRG or its affiliates additionally may receive fees from the Funds for additional services provided to the Funds or their underlying investments not covered by the client’s management fee (“Related Services”). Any such amounts received for Related Services will generally reduce management fees paid to the Adviser.

All Clients will incur expenses in connection with custodial or brokerage services discussed in Item 12. In addition, Clients bear their own operating costs and expenses relating to their organization and operations, which may include, but are not limited to expenses incurred in identifying, assessing, acquiring, negotiating, structuring, and disposing of investment opportunities, including any financing, legal, accounting, management and consulting fees whether or not a Client actually invests in the specific investment opportunity or not; administrative expenses associated with an annual audit, financial and tax returns and tax reporting to a Client’s investors; registration and other investment costs; interest and fees associated with any permitted borrowings; costs of any litigation, D&O insurance and other types of insurance, indemnification or extraordinary expense or liability; meetings of Client investors; fees and disbursements to attorneys, consultants, accountants, fund administrators, service providers and any other professionals relating to Client matters.

Allocation of Expenses

CRG frequently will be required to decide how certain costs and expenses are to be allocated to one or more Funds, and to other Clients of the Adviser. Certain expenses may be suitable for only a particular Fund or Funds or another participating Client and borne only by such vehicles, or, as is more often the case, expenses may be allocated pro rata among each participating Client in accordance with expense allocation policies and procedures developed by the Adviser, as may from time to time be amended or revised by the Adviser in its sole discretion. Generally, expenses are expected to be allocated based on contributions to the applicable Portfolio Investment. However, the Adviser may determine in its sole discretion that allocation in a different manner would be fair and equitable in certain cases that may result in one or more Funds bearing a higher share of expenses. For example, the Adviser may determine to use a different allocation of expense where the applicable expense has been incurred based on some factor other than asset or investment size (such as the number of investors in each parallel fund) or where the expense would be incurred by one or more parallel funds regardless of the existence of, or participation in the benefits of such expense by, another parallel fund or client. Notwithstanding the foregoing, the portion of an expense allocated to a Fund for a particular service may not reflect the relative benefit derived by the Fund from that service in any particular instance. CRG may make allocation decisions that result in a general partner or the Adviser bearing a smaller portion of expenses and/or receiving greater amounts of management fees than would have been the case had expenses been allocated pro rata. Page 2 of 24

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

Methods of Analysis and Investment Strategies The Adviser’s investment strategy is to invest in Portfolio Investments as described in Item 4. Investments are selected through a proprietary screening and due diligence process which utilizes the knowledge and skills of the Adviser’s investment professionals, healthcare industry contacts and consultants, published sales and technical information and operating partners composed of outside healthcare industry veterans. Material Risks

Investing involves risk of loss that investors should be prepared to bear. These investments are not suitable for all investors and are intended for sophisticated investors who can accept the risks associated with the Adviser’s investment program. Among the risks to be considered are that the investments will be concentrated in the healthcare industry and are not expected to provide diversification across industries. Investors should be aware and seek diversification Page 3 of 24

by including other types of investments in their portfolio. Certain risks that are associated with an investment in the Funds include, but are not limited to, the following.

Risks Associated with Investments in Healthcare Companies CRG’s Clients will invest primarily in companies whose revenues to a large extent are derived from biotechnology and pharmaceutical products, medical and diagnostic devices, and healthcare services and facilities, including healthcare information technology (the “Target Products”). The ability of a healthcare or life sciences company to make payments to its investors will depend, at least in part, on the revenue levels achieved by the Target Products. The risks of investing in these investments will include the risks of investing in the underlying industry. In addition, these investments will not be widely traded or understood and the Client may not be able to sell its investments when it wants to do so or at the prices at which they are carried on the books of the Client.

Risks Associated with “High Yield” Debt The debt investments that the Funds make are typically not initially rated by any rating agency, but we believe that if such investments were rated, they would be below investment grade (rated lower than “Baa3” by Moody’s Investors Service, lower than “BBB-” by Fitch Ratings or lower than “BBB-” by Standard & Poor’s Ratings Services), which under the guidelines established by these entities is an indication of having predominantly speculative characteristics with respect to the issuer’s capacity to pay interest and repay principal. Bonds that are rated below investment grade are sometimes referred to as “high yield bonds” or “junk bonds.” Therefore, the Funds’ investments could result in an above average amount of risk and volatility or loss of principal.

Risks Associated with Illiquid Investments The debt investments to which the Funds are primarily exposed are expected to consist predominantly of loans and notes that are obligations of corporations, partnerships or other entities. This debt often has no, or only a limited, trading market. The investment in illiquid debt will often restrict our ability to dispose of investments in a timely fashion, for a fair price, or at all. If an underlying issuer of debt experiences an adverse event, this illiquidity would make it more difficult for us to sell such debt, and we could instead be required to pursue a workout or alternate way out of the position. To the extent debt in a portfolio company is also held by other third-party investors, we would generally have limited control over a workout or alternate means of disposition and the person(s) having such control could have interests that are not aligned with ours. We would likely also face other restrictions on our ability to liquidate an investment in a portfolio company to the extent that we have material non-public information regarding such portfolio company. Investments in Highly Leveraged Companies. Certain Funds’ investments are expected to include investments in entities whose capital structures have significant leverage (including substantial leverage senior to the Fund’s investment, a considerable portion of which may be secured by first liens and/or may be at floating interest rates). Such investments are inherently more sensitive to declines in revenues, competitive pressures and increases in expenses and interest rates. The leveraged Page 4 of 24

capital structure of such entities will increase their exposure to adverse economic factors such as downturns in the economy or deterioration in the condition of a company or its industry, and such entities may be subject to restrictive financial and operating covenants. This leverage may result in more serious adverse consequences to such entities (including their overall profitability or solvency) in the event these factors or events occur than would be the case for less leveraged companies. If an entity cannot generate adequate cash flow to meet debt obligations, it may default on its loan agreements or be forced into bankruptcy resulting in a restructuring of its capital structure or liquidation of the entity. Furthermore, to the extent companies in which certain Funds have invested become insolvent, such Funds may determine, in cooperation with other debt holders or on its own, to engage, at the Funds’ expense in whole or in part, counsel and other advisors in connection therewith.

We may be exposed to higher risks with respect to our investments that include PIK interest or exit fees. The Funds’ investments may include contractual payment-in-kind, or PIK, interest and exit fees. PIK interest represents contractual interest added to a loan’s principal balance and is due in accordance with the loan’s amortization terms. Exit fees represent a contractual fee accrued over the life of the loan and are typically due at loan payoff. To the extent PIK interest and exit fees constitute a portion of the Fund’s income, the Fund will be exposed to typical risks associated with such income being required to be included in taxable and accounting income prior to receipt of cash, including the following: • PIK interest and exit fee instruments may have higher yields, which reflect the payment deferral and credit risk associated with these instruments; • PIK interest and exit fee instruments may have unreliable valuations because their continuing accruals require continuing judgments about the collectability of the deferred payments and the value of the collateral; and • PIK interest and exit fee instruments may represent a higher credit risk than coupon loans; even if the conditions for income accrual under generally accepted accounting principles in the United States of America (“U.S. GAAP”) are satisfied, a borrower could still default when actual payment is due upon the maturity of such loan.

Risks Factors Relating to Use of Leverage The Funds may borrow money to fund investments, which is often referred to as leverage. Although the use of leverage may create an opportunity for increased returns for the Funds, it also results in additional risks and can magnify the effect of any losses and thus could negatively impact a Fund’s business and results of operation and have important adverse consequences to a Fund’s Portfolio Investments. It is likely that any debt the Funds incur will be governed by an indenture or other instrument containing covenants that may restrict the Funds’ operating flexibility, including covenants that, among others, likely will limit the Funds’ ability to: (i) pay distributions in certain circumstances, (ii) incur additional debt, and (iii) engage in certain transactions. If a Fund secures its leverage through the pledging of collateral, a Fund may, if such Fund is unable to generate sufficient cash flow to meet principal and interest payments on its indebtedness, be subject to risk that a lender seizes its assets through margin calls or otherwise that could require liquidation of Portfolio Investments at inopportune times or at prices that are not favorable to such Fund and cause significant losses. If a Fund defaults on secured Page 5 of 24

indebtedness, the lender may foreclose and a Fund could lose its entire investment in assets that serve as collateral for such loan. If a lender seizes and liquidates pledged collateral, such collateral will likely be sold at distressed price levels. The Funds will fail to realize the full value of such asset in a distressed sale. In the event performing Portfolio Investments are crosscollateralized with under-performing or non-performing assets, the Funds’ interests in the performing assets may be adversely affected. Moreover, each Fund may also be jointly and severally liable with one or more of its parallel funds or feeder funds with respect to a credit facility or other leverage. If any such parallel fund or feeder fund defaults on its obligation, such Fund that may also be adversely affected. The Funds may be required to pay commitment fees and other costs of borrowings under the terms of a credit facility. Moreover, interest on borrowings will be an expense of the Funds. With the use of borrowings, there is a risk that the interest rates paid by a Fund on the amount it borrows will be higher than the return on such Fund’s Portfolio Investments. In addition, any leverage instruments that a Fund may issue in the future will likely have rights, preferences and privileges over such Fund’s and against such Fund’s assets in liquidation that are more favorable than those of the interests in such Fund. Such additional costs and expenses may affect the operating results of the Funds. If a Fund cannot generate sufficient cash flow from its Portfolio Investments, it may need to refinance all or a portion of its indebtedness on or before maturity. The inability to obtain additional financing could have a material adverse effect on a Fund’s operations and on its ability to meet its debt obligations. If it is unable to refinance any of its indebtedness on commercially reasonable terms or at all, a Fund’s business and returns may be harmed.

General Economic and Market Conditions The success of a Fund’s activities will be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, economic uncertainty, changes in laws (including laws relating to taxation of a Fund and its Portfolio Investments and laws relating to intellectual property protections), trade barriers, currency exchange controls, and national and international political circumstances (including wars, terrorist acts or security operations). These factors may affect the level and volatility of prices of investments and the liquidity of a Fund’s Portfolio Investments. Volatility or illiquidity could impair a Fund’s profitability or result in losses. Unpredictable or unstable market conditions may result in reduced opportunities to find suitable investments to deploy capital or make it more difficult to exit and realize value from a Fund’s existing Portfolio Investments. The illiquid nature of a Fund’s Portfolio Investments may make it difficult, if not impossible, for a Fund to exit Portfolio Investments prior to their scheduled maturity. In addition, any sale of a Fund’s Portfolio Investments may be made at substantial discounts and/or otherwise disadvantageous terms. Interest Rate Risk Interest rate risk refers to the risks associated with market changes in interest rates. In general, the price of most fixed income investments moves in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income investments falls. Consequently, the longer the maturity of a fixed income security, the greater Page 6 of 24

the risk that interest rates may rise and thus the fall in price of the security may be larger than the fall in price would have been for a security with a shorter maturity. If a Fund holds a fixed income security to maturity, the change in its price before maturity may have little impact on such Fund’s performance; however, if a Fund has to sell the fixed income security before the maturity date, an increase in interest rates may result in a loss to such Fund. Adjustable rate instruments also react to interest rate changes in a similar manner although generally to a lesser degree (depending, however, on the characteristics of the reset terms, including the index chosen, frequency of reset and reset caps or floors, among other factors). A Fund’s other Portfolio Investments may also be affected by changes in interest rates. Interest rate sensitivity is generally more pronounced and less predictable in instruments with uncertain payment or prepayment schedules. Declines in market value, if not offset by any corresponding gains on hedging instruments, may ultimately reduce earnings or result in losses to a Fund.

The prices of long-term debt obligations generally fluctuate more than prices of short-term debt obligations as interest rates change. To the extent a Fund invests in longer-term portfolio investments, it will be impacted to a greater degree by changes in market interest rates than if a Fund invested primarily in short-term debt securities. The Funds may, but will not be required to, hedge interest rates. Any hedging strategies may not be successful and even if they are, they will impose costs that may decrease the returns of the Funds.

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Item 7: Types of clients

The Adviser provides investment management services to several Funds. Investors in the Funds may include certain qualified individuals, public pensions, corporate pension and profitsharing plans, charitable institutions, foundations, endowments, municipalities, private investment funds, trust programs, insurance companies, sovereign funds, foreign funds and other U.S. and international institutions. CRG has also provided investment management services to separately managed accounts of investors with similar profiles as those who have invested in the Funds.

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

Each of the Clients that CRG currently manages pays an Incentive Fee and therefore CRG does not currently manage any accounts that have an Incentive Fee side-by-side with accounts that do not have an Incentive Fee.

The payment by some, but not all, Clients of an Incentive Fee (or the payment of Incentive Fees at varying rates) may create an incentive for the Adviser to disproportionately allocate time, services or functions to Clients paying an Incentive Fee (or Clients paying Incentive Fees at a higher rate), or allocate securities to such Clients. Generally, and except as may be otherwise set forth in the organizational documents of the Funds, this conflict is mitigated by (i) certain limitations on the ability of the Adviser to establish new investment funds, (ii) contractual provisions requiring certain Funds to purchase and sell investments contemporaneously and/or (iii) contractual provisions and procedures setting forth investment allocation requirements. CRG will always endeavor to recommend the allocation of investment opportunities in a fair and equitable manner.

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

CRG has no business relationships and/or activities with other participants in the financial industry that may create a conflict of interest, such as broker-dealer arrangements and commodity trading or affiliation with financial planners, banks, consultants or other advisers from whom the Adviser will receive compensation.

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The Adviser maintains a policy described in Item 11 to address any actual or potential conflicts of interest arising from its management of the Funds and client accounts described in Item 4 or from the service of affiliates of the Adviser as general partners of such Funds.

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

Trading Code of Ethics The Adviser has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct and fiduciary duty to its advisory clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at the Adviser must acknowledge the terms of the Code of Ethics annually, or as materially amended.

The Adviser anticipates that, in appropriate circumstances, consistent with investment objectives of the Funds, it will cause a Client to effect the purchase or sale of interests in which the Adviser, its affiliates and/or clients, directly or indirectly, have a position or interest. In such circumstances, the Adviser’s employees and persons associated with the Adviser are required to follow the Adviser’s Code of Ethics. Officers, directors and employees of the Adviser and its affiliates are prohibited from investing in any security or debt instrument in which any Fund has invested or those in which an investment is contemplated, except as provided in employment contracts and Operating Agreements or otherwise disclosed to its Clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with making decisions in the best interest of advisory clients. The Code of Ethics requires pre-clearance of certain transactions, and restricts trading in certain securities. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between the Adviser and its clients. The Adviser personnel who violate the Code of Ethics may be subject to remedial actions, including, but not limited to, profit disgorgement, fines, demotion, suspension or dismissal. The Adviser personnel are required to annually certify compliance with the Code of Ethics. Prospective clients may request a copy of the Adviser’s Code of Ethics by contacting the Chief Compliance Officer (email: info@crglp.com).

Participation or Interest in Client Transactions The Adviser and certain employees and affiliates of the Adviser are permitted to invest in and alongside the Funds, either through the general partners, as direct investors in the Funds or otherwise. A Fund or its general partner, as applicable, may waive all or a portion of the Management Fee and Incentive Fee related to investments held by such persons. Such transactions will be subject to the provisions of CRG’s Code of Ethics, as described immediately above. Page 15 of 24

Due in part to the fact that potential investors in a Fund or a co-investment opportunity (see below) may ask different questions and request different information, the Adviser may provide certain information to one or more prospective investors that it does not provide to all of the prospective investors or limited partners.

Conflicts of Interest The Adviser and its related entities engage in a broad range of activities, including investment activities for their own account and for the account of other Clients, and providing transactionrelated, investment advisory, management and other services to Clients and operating companies. In the ordinary course of conducting its activities, the interests of a Fund may conflict with the interests of the Adviser, other Funds or their respective affiliates. Certain material conflicts of interest encountered by a Fund include those discussed below, although the discussion below does not necessarily describe all of the conflicts that may be faced by a Fund. Other conflicts may be disclosed throughout this brochure and a Fund’s offering documents, and the brochure and the offering documents should be read in their entirety for other conflicts.

Allocation of Investment Opportunities a mong Clients and Allocation of Co-Investment Opportunities In connection with its investment activities, the Adviser may encounter situations in which it must determine how to allocate investment opportunities among various clients and other persons. The Adviser has adopted written policies and procedures relating to the allocation of investment opportunities, and will make allocation determinations consistently therewith. Such policies and procedures are generally detailed in the Advisory Agreement, Operating Agreement and/or offering documents for the particular Fund.

As a fiduciary to its Clients, CRG has a duty to treat Clients fairly and equitably over time in the allocation of investment opportunities. Investment opportunities that are appropriate for a Client and other accounts will be allocated in accordance with CRG’s investment allocation policy, and CRG may consider the Clients’ relative size to each other subject to their available capital at the time of investment, and such matters as the nature and time horizon of the investment, suitability and portfolio positions of each of accounts and other entities for which participation is appropriate, including concentration, diversification, liquidity and other limitations, applicable tax and regulatory considerations and others, in CRG’s discretion but in all events on a fair and equitable basis. If an order on behalf of more than one account cannot be fully executed under prevailing market conditions, the securities acquired will be allocated among the different accounts on a basis considered fair and equitable. In addition, Clients may invest in certain non-marketable securities that, given the nature of these instruments and differences in relative assets of the accounts, it might not be possible to allocate such an investment on a pro rata basis between these accounts. In such event, opportunities will be allocated such that all Clients are treated on a fair and equitable basis over time.

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Principal and Agency Cross Transactions Section 206 under the Advisers Act regulates principal transactions among an investment adviser and its affiliates, on the one hand, and the clients thereof, on the other hand. Generally, an investment adviser may not purchase a security from, or sell a security to, a client (what is commonly referred to as a “principal transaction”) without first (1) making certain disclosures to the client of the terms of the proposed transaction and (2) obtaining the client’s consent to the transaction. The Adviser and its affiliates may engage in principal transactions with Clients as permitted under applicable law. The Adviser has established certain policies and procedures to comply with the requirements of the Advisers Act as they relate to principal transactions. In addition, the offering documents, Operating Agreements or other organizational documents and related documents relating to the Funds generally contain additional restrictions on the ability of the Funds or the Adviser to engage in principal transactions.

In certain cases, the Adviser may cause a Client to purchase investments from another Client, or it may cause a Client to sell investments to another Client (what is commonly referred to as a “cross-trade”). Such transactions create conflicts of interest because, by not exposing such buy and sell transactions to the market forces, a Client may not receive the best price otherwise possible, or the Adviser might seek to prop up the performance of one Fund by selling underperforming assets to another Fund in order, for example, to earn fees. Additionally, in connection with such transactions, the Adviser, its affiliates and/or their professionals (i) may have significant investments or intentions to invest in the Fund that is selling and/or purchasing such an investment or (ii) otherwise have a direct or indirect interest in the investment (such as through certain other participations in the underlying investment). To the extent permitted by applicable law and the applicable governing documents, CRG may effect “cross-trades” between the Client accounts. CRG would only recommend Clients enter into such transactions if the transactions were consistent with the best interests of both Clients and at a price that CRG and/or its related persons believe constitutes a fair valuation for both Clients. Neither CRG nor any related party receives any commission or commission equivalent in connection with these transactions.

The Adviser may cause a Client to engage in “cross-trades” with one or more accounts, typically for purposes of rebalancing the portfolios of the Fund and such accounts in order to further the Fund’s and such accounts’ respective investment programs, or for other reasons consistent with the investment and operating guidelines of the Fund and such accounts. The value of any positions that are so cross-traded will be determined in a manner that is consistent with the valuation policies used by the Adviser. In some cases, the Adviser may seek the approval of an independent third party (including an advisory committee) for such trade. The Adviser may also cause the Funds to engage in “rebalancing” transactions intended to allocate investments among such Funds in a manner consistent with applicable allocation guidelines. Such transactions will be priced in a manner consistent with the Fund’s offering documents.

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Fee Structure Because there is a fixed investment period after which capital from investors in the Funds may only be drawn down in limited circumstances and because Management Fees are, at certain times during the life of the Funds, based upon capital invested by the Funds, this fee structure may create an incentive to deploy capital when the Adviser may not otherwise have done so.

Additionally, as discussed above in Item 6, the general partners of the Funds, or the Adviser, as applicable, are entitled to Incentive Fees under the terms of the Operating Agreements of the Funds. Such general partners are affiliates of the Adviser. The existence of the general partners’ Incentive Fees may create an incentive for the general partners or the Adviser to cause such Funds to make more speculative investments than they would otherwise make in the absence of performance-based compensation. Additionally, certain of the Funds use borrowed funds in advance of capital contributions, such that the Funds’ investors generally make correspondingly later capital contributions, but the Funds will bear the expense of interest on such borrowed funds. As a result, the Funds’ use of borrowed funds will impact the calculation of net performance metrics (to the extent that they measure investor cash flows) and may make net internal rate of return calculations higher than it otherwise would be without fundlevel borrowing as these calculations generally depend on the amount and timing of capital contributions. While the Funds will bear the expense of borrowed funds, such borrowings can also increase the Incentive Fees received by the general partners of the Funds or the Adviser by decreasing the amount of distributions from the Funds that are required to be made to Fund investors in satisfaction of any preferred return described in Item 6. The general partners of the Funds and the Adviser therefore have a conflict of interest in deciding whether to borrow funds because the general partner or the Adviser may receive disproportionate benefits from such borrowings.

Operating Partners The general partner and the portfolio companies will from time to time retain other companies and individuals (“Operating Partners”), which may be affiliates of the general partner, employees of such affiliates, portfolio companies of other of the Adviser’s funds, third party consultants (including specialized consultants, external executives, and industry advisory roundtable members), “operating partners” or “senior advisors”. The Operating Partners are engaged to provide operational support, specialized operations and consulting services and similar or related services to, or in connection with, one or more portfolio companies in relation to the identification, due diligence, acquisition, holding, improvement and disposition of such portfolio companies (“Operations Support Services”). Operating Partners may be offered the ability to co-invest alongside Funds, including in investments in which such Operating Partner is involved or participates in the management thereof. Fees and expenses associated with Operations Support Services (“Operations Expenses”) are paid and/or reimbursed by portfolio companies and/or the Funds. Compensation in the form of profits or equity interests in a portfolio company (or intermediate holding company) generally has a dilutive impact on the Fund’s investment, and has the potential to result in economic effects greater than the original amount of compensation. To the extent any such Operations Expenses are payable to any affiliated Operating Partner by the Funds or a Page 18 of 24

portfolio company, such Operations Expenses will not reduce any fees otherwise payable to the management company or its affiliates.

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Item 12: Brokerage practices Conflicts of interest

Broker-Dealer Selection Since CRG generally acquires and disposes of investments in privately negotiated transactions, broker-dealers and other intermediaries are infrequently used in the normal course of business. On the limited occasion that CRG executes a transaction in a publicly traded security, the investment team is primarily responsible for the selection of the broker used to execute the transaction and negotiate the brokerage commissions. If the investment team has the occasion to select a broker or dealer, it will seek to obtain best execution, i.e., the most favorable results reasonably attainable under the circumstances, taking into account a variety of factors, including price and costs as well as qualitative factors. In selecting brokers, CRG generally considers such factors as price (including the applicable brokerage commission or dealer spread), size of order, difficulty of execution, and operational facilities of the broker and the broker’s risk and skill in positioning blocks of securities. CRG may not necessarily select the broker that offers the lowest spread or commission available, consistent with the duty to seek best execution. Page 20 of 24

Research and Soft Dollar Benefits As noted above, CRG’s investment strategies do not typically utilize broker-dealers or other securities intermediaries. However, subject to applicable legal requirements, CRG could select a broker based partly upon the research or other products or services provided to it in connection with Client securities transactions (“soft dollar benefits”). In return for such services, a Client could pay a higher commission than another broker would charge, if it is determined in good faith that such commission is reasonable in relation to the brokerage services provided. When CRG uses client brokerage commissions (or markups or markdowns) to obtain soft dollar benefits, they will serve all Clients’ accounts and any benefits that are capable of being quantified will be allocated to Client accounts proportionately. Order Aggregation

Because CRG’s investment strategies do not typically involve utilizing broker-dealers or other securities intermediaries, CRG will generally not have the opportunity to aggregate purchase or sale orders to execute transactions more efficiently. If investment recommendations in traded securities were to be made contemporaneously for multiple Clients in the same instrument, CRG may, if consistent with market conditions, portfolio characteristics, its investment allocation policy, and applicable law, “bunch” or aggregate orders (including orders for Clients in which CRG, its related persons, and/or its personnel have beneficial interests) for execution if, in its reasonable judgment, such aggregation is reasonably likely to result in an overall economic benefit to a Client and/or other Clients. CRG does not allocate brokerage transactions in exchange for Client referrals. CRG does not currently participate in directed brokerage.

Item 14: Client referrals and other compensation Conflicts of interest

The Adviser uses the services of placement agents to sell interests in the Funds and may use a placement agent in the future to sell any other investment vehicles organized by related parties. The placement agent is compensated for the services provided in accordance with an agency contract. Such agents generally will receive a fee in an amount equal to a percentage of the capital commitments for interests made by such potential investors in the Fund in which they subsequently invest. As such, the placement agents have an incentive to recommend the Firm, resulting in a material conflict of interest. Such fees paid to placement agents are generally paid by the Fund and offset against management fees.

Item 9: Disciplinary information

CRG believes there are no legal or disciplinary events that are material to a Client’s evaluation of CRG’s advisory business or the integrity of its management.

Item 13: Review of accounts

The Adviser reviews accounts of the Funds periodically and the financial position of each investor in the Funds is determined by the Controller. The accounts are reviewed by the Chief Financial Officer and the Partners and/or the Investment Committee. Account activity and balances are prepared by the Controller and reviewed by the Chief Financial Officer. Investors receive a detailed confirmation at the time of the transaction from the Partners and/or the Chief Financial Officer or at any other time and in any other manner in accordance with the relevant agreement with such investor. Detailed account information is also available to each investor on the internet in an individual password-protected section of the Adviser’s website. The investors in the Funds receive financial statements and a written update on investments quarterly and audited financial statements and a written update on investments annually in accordance with the terms of the applicable Operating Agreement. Page 21 of 24

Item 15: Custody

Most investors in the Funds are not clients of the Adviser, and will not receive custody statements from the Fund’s custodian. Instead, they receive the Fund’s quarterly and annual financial statements referred to above. With respect to the Adviser’s clients, clients should receive quarterly and annual statements from the bank or other qualified custodian that holds and maintains client’s investment assets. The Adviser urges you to carefully review the account statements you receive from the qualified custodian and compare these records to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Clients are urged to contact the Adviser if there is any question about account statements.

Item 16: Investment discretion

The Adviser receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives and the terms and conditions of the relevant Fund’s Operating Agreement. When selecting securities and determining amounts, the Adviser observes the investment policies, limitations and restrictions of the clients for which it advises.

Item 17: Voting client securities

The Adviser has established written policies and procedures setting forth the principles and procedures by which the Adviser votes or gives consent with respect to securities owned by the Funds (the “Votes”). The guiding principle by which the Adviser votes all Votes is to vote in the best interests of each Fund by maximizing the economic value of the relevant Fund’s holdings, taking into account the relevant Fund’s investment horizon, the contractual obligations under the relevant Advisory Agreements or comparable documents, and all other relevant facts and circumstances at the time of the vote. The Adviser does not permit voting Page 22 of 24

decisions to be influenced in any manner that is contrary to, or dilutive of, this guiding principle. It is the Adviser’s general policy to vote or give consent on all matters presented to security holders in any Vote. However, the Adviser reserves the right to abstain on any particular Vote or otherwise withhold its vote or consent on any matter if, in the judgment of the relevant investment professional, the costs associated with voting such Vote outweigh the benefits to the relevant Funds or if the circumstances make such an abstention or withholding otherwise advisable and in the best interests of the relevant Funds. Funds generally cannot direct the Adviser’s Vote in a particular solicitation.

In most cases, the investment professional covering the particular investment will make the decision as to the appropriate vote for any particular Vote. In making such decision, he or she may rely on any of the information and/or research available to him or her. If the investment professional is making the voting decision, the investment professional will inform the General Counsel of any such voting decision, and if the General Counsel does not object to such decision as a result of his conflict of interest review, the Vote will be voted in such manner. If the investment professional and the General Counsel are unable to arrive at an agreement as to how to vote, then the General Counsel may consult with the Adviser’s investment committee as to the appropriate vote, who will then review the issues and arrive at a decision based on the overriding principle of seeking the maximization of the economic value of the relevant Funds’ holdings.

The Chief Compliance Officer has the responsibility to monitor Votes for any conflicts of interest, regardless of whether they are actual or perceived. All voting decisions will require a mandatory conflicts of interest review by the Chief Compliance Officer in accordance with these policies and procedures, which will include consideration of whether the Adviser or any investment professional or other person recommending how to vote and/or the Adviser’s affiliates and their clients has an interest in how the Vote is voted that may present a conflict of interest. In addition, the Adviser’s investment professionals are expected to perform their tasks relating to the voting of Votes in accordance with the principles set forth above, according the first priority to the best interest of the relevant Funds. The Chief Compliance Officer will use his best judgment to address any such conflict of interest and ensure that it is resolved in accordance with his or her independent assessment of the best interests of the Funds.

Where the Chief Compliance Officer deems appropriate, unaffiliated third parties may be used to help resolve conflicts. In this regard, the Chief Compliance Officer shall have the power to retain independent fiduciaries, consultants, or professionals to assist with voting decisions and/or to delegate voting or consent powers to such fiduciaries, consultants or professionals.

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Copies of relevant proxy logs, identifying how proxies were voted in connection with a Fund and copies of proxy voting policies are available to any client upon written request to the Adviser at the address on the cover page or email to info@crglp.com. Prospective clients may obtain a copy of the Adviser’s proxy voting policies and procedures by emailing a request to info@crglp.com.

Item 18: Financial information

Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about the adviser’s financial condition. The Adviser has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding.

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Stakes it holds

CR Group L.P. has told the SEC it owns more than 5% of 2 companies, latest first (Schedules 13D and 13G).