Deer Park Road Management Company, LP

Deer Park Road Management Company, LP (“Deer Park” or the “Adviser”), a Delaware limited partnership, is an alternative investment adviser focused on the structured finance segment of the global fixed-income markets that also provides discretionary investment advisory services to a privately offered investment fund that invests in a variety of real estate assets. Deer Park provides discretionary investment advice to private funds (the “Private Funds”) and serves as a discretionary sub-adviser to a registered mutual fund (collectively the “Funds” or “Clients”). The Funds will be managed in accordance with their investment objectives, as described in their respective offering documents and governing agreements (together, the “Governing Documents”). Certain of the Private Funds are structured as “funds of one” wherein the Adviser’s services are tailored to the needs of a single investor in such Fund. Deer Park was founded in 2003 by Michael Craig-Scheckman, its current Chief Executive Officer and founder. Mr. Craig-Scheckman has been in the investment business for over 40 years and has over 30 years of experience in the distressed mortgage-backed and assetbacked securities field. Scott Burg joined the Adviser in 2010 and is currently the Chief Investment Officer and managing partner. Mr. Burg has over 20 years of experience in the MBS/ABS (each as defined below) market. Brad Craig has been with the Adviser since 2007 and currently serves as its Chief Operating Officer. Deer Park is owned and controlled by Michael Craig-Scheckman, Scott Burg and Brad Craig. Deer Park aims to identify potentially attractive investment opportunities primarily by exploiting trading and investment opportunities with a strong, but not exclusive, focus on mortgage-backed securities (“MBS”), asset-backed securities (“ABS”), corporate debt, and other credit investments. The Adviser has also taken significant equity positions in early stage and public companies that operate in the real estate, mortgage or mortgage service industry. Certain of these companies provide services to funds managed by the Adviser or its affiliates. The Adviser employs a fundamental research approach on security selection in the MBS/ABS market. Specifically with regard to ABS, security selection is based on a valuation process that seeks to exploit the disparity between the intrinsic and market value of these securities, capitalizing on the traditionally inefficient MBS/ABS marketplace. Portfolios also include long and short positions in derivatives, corporate debt and equities. For certain of the Private Funds, Deer Park also aims to identify potentially attractive investment opportunities in the single family residential real estate market by purchasing and offering properties to rent. The Adviser does not participate in any wrap fee programs. As of December 31, 2025, Deer Park managed approximately $2,679,000,000 on a discretionary basis.

The fees and expenses applicable to the Private Funds and the mutual fund are set forth in each Private Fund’s and mutual fund’s offering or constitutive or organizational documents. A summary of those fees and expenses follows. Fees and expenses on new private funds and other products are negotiable. The Adviser or entities that the Adviser owns, controls or is under common control with (its “Affiliates”) are entitled to receive an annual incentive allocation (“Performance Allocation”) from certain Private Funds based on a percentage of the net realized and unrealized income and capital appreciation, if any, of the capital accounts or net asset value (“NAV”) of the shares, as applicable. Compensation received by the Adviser from the Private Funds also includes “Management Fees” and, in some cases, carried interest. The Adviser may, in its discretion, negotiate lower Management Fees or graduated Performance Allocations, or both, with individual investors or as a separate class or fund, in its sole discretion. The Adviser has discretion to waive, and with investor consent, modify or change the amount or calculation method for the Management Fee or Performance Allocation with respect to any Private Fund, class or individual investor including affiliates or employees of the Adviser. Management Fees will generally be paid quarterly in arrears and may be subject to high watermark. Deer Park’s fee schedule is omitted because this brochure is only being delivered to qualified purchasers as defined in the Investment Company Act of 1940, as amended. In addition to compensation payable to Deer Park described above, each Fund will typically bear its pro rata share of the following types of expenses: 

management fees;

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expenses related to initial and ongoing due diligence of investments and loan security, including outside legal and accounting services, title work and services, lien searches, travel (including airfare, lodging, ground transportation, and related fees and expenses);

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expenses related to the acquisition, holding, transfer and disposition of investments and other investments or assets, such as commissions, brokerage and prime brokerage fees, advisory fees, transfer fees, custodial fees, administration fees, exchange fees, clearing costs and bank service fees;

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investment-related expenses (including with respect to broken deals), including research expenses, the cost of software packages utilized in connection with the management of the Fund or any subsidiary thereof, market data and systems, and

the costs of any periodicals, subscriptions or other market intelligence services or publications; 

costs related to any borrowings, facilities or other indebtedness incurred by the Fund or any subsidiary thereof, including any interest, fees and expenses (including upfront fees, fees and expenses of counsel and other advisers, and other closing fees and expenses) payable with respect thereto;

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external transaction-related expenses, external legal fees, and third-party professional fees relating to investments or otherwise (including expenses of consultants and experts, if any);

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fees of any third-party administrator(s), and external accounting and investor reporting expenses, including the fees and expenses of the partnership representative;

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the cost of accounting, order management and portfolio management software packages;

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valuation expenses, including the fees and expenses of any third-party valuation firm;

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auditing and tax expenses, including any such expenses related to the Fund’s U.S. Foreign Account Tax Compliance Act and Common Reporting Standard compliance obligations and any taxes imposed on or payable by the Fund, a master fund or any subsidiary thereof (as determined by the General Partner);

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insurance expenses (including costs related to any retention or deductibles) for the Fund, a master fund and the General Partner (including D&O and E&O insurance);

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all expenses incurred in connection with organizing any subsidiary of the Fund or a master fund and obtaining any necessary regulatory registrations or authorizations;

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expenses relating to the registration and ongoing regulatory and compliance obligations (including legal fees, costs and expenses, regulatory filing or other expenses of the Fund, a master fund, their subsidiaries, a general partner or Deer Park, including Form PF, commodity pool operator (CPO) and commodity trading advisor (CTA) filings and any compliance or filings related to the European Union Alternative Investment Fund Managers Directive but not including Deer Park’s Form ADV filings);

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costs relating to the termination, winding-up and dissolution of the Fund, a master fund or any subsidiary thereof;

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other similar expenses related to the Fund, a master fund or any subsidiary thereof and all other normal operating expenses incurred by the Fund or any subsidiary thereof; and

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all extraordinary expenses (e.g., litigation expenses, costs or damages and indemnification obligations).

Deer Park (and any affiliate thereof) will be entitled to reimbursement from a Fund or any subsidiary thereof for any operating expenses or organizational expenses paid by such party on behalf of such Fund or any such subsidiary. The expenses of the Funds may be borne by any Fund or master fund and will generally be apportioned between onshore feeders and offshore feeders (if applicable) based on the relative capitalization of each or as otherwise determined by the Adviser or its Affiliate in good faith. However, if a certain Fund or master fund cost or expense relates solely to the onshore feeder or the offshore feeder, then Deer Park may, but is under no obligation to, allocate such cost or expense solely to the applicable feeder. Costs and expenses attributable to one or more limited partners, but not attributable to a Fund and any master fund as a whole, may in the Adviser’s or its Affiliates’ discretion be allocated only to the relevant limited partners. From time to time, a Fund will incur costs or expenses that are applicable to Deer Park or, the general partner or one or more other investment funds, client accounts, special purpose entities, co-investment vehicles, and other similar accounts that are sponsored, managed or advised, or may in the future be sponsored, managed or advised by the general partner, Deer Park or its or their respective affiliates. If an expense is properly allocable to more than one client of Deer Park, then the expense will be allocated in a manner that Deer Park deems to be fair and reasonable, depending on the circumstance of the expense and how it relates to such Fund and the other clients. Please refer to the applicable Fund’s Governing Documents for a detailed listing of the types of expenses that may be allocated to such Fund. Please also see “Item 12 – Brokerage Practices” below for additional information regarding Deer Park’s broker selection policies.

INVESTMENT STRATEGY As described in Item 4 above, the Adviser pursues various investment strategies depending on Client objectives. For those Clients related to MBS, ABS, corporate debt, and other credit investments, the Adviser employs a strong but not exclusive focus on distressed securities. The Adviser utilizes a value-oriented approach to source and manage a portfolio of opportunistic credit and other investments which the Adviser anticipates will provide commensurate risk-adjusted returns and cash flows. Such MBS include RMBS and CMBS that are rated below investment grade, or not rated. The Adviser also invests in other types of asset-backed or debt securities as well as equity securities and derivatives. These investments generally present a higher risk of default than securities rated as investment grade, but which the Adviser believes are undervalued. By using proprietary fundamental analysis and modeling key variables, the Adviser seeks investments expected to provide steady and substantial cash flows. The Adviser’s Risk Management Committee is part of the investment oversight process and is charged with identifying, assessing, monitoring and mitigating trading and investment risks. The Risk Management Committee sets hedging parameters for the portfolios, and therefore its decisions will impact the instruments used, and the extent to which they are used for hedging purposes in any portfolios managed by the Adviser. The Adviser will typically invest in fixed and floating rate securities, and securities that bear no interest. Investments include, among other permitted investments, deep value, high cash flow, short duration RMBS. The Adviser invests without restriction as to issuer capitalization, country, credit quality and maturity (for fixed income securities). The Adviser invests in discounted and deeply discounted, asset-backed debt, predominately backed by real estate, which the Adviser anticipates will provide steady and substantial cash flows. Although the Adviser actively trades Client portfolios on an opportunistic basis, the Adviser’s philosophy is based on buying securities that the Adviser is comfortable holding to term. The Adviser focuses on investing in securities backed by real estate or mortgages but will also take significant positions in equity and exchange-traded fund (“ETF”) securities (some of which are backed by gold, silver and/or mining companies), debt securities backed by corporate credit, derivatives and securities backed by other collateral, including, but not limited to, automobiles, boats, planes and credit cards. Investors in the mutual fund have the option to redeem their investments on a daily basis, while Private Fund interest holders have more limited redemption terms. Securities purchased for Private Funds are likely to have more limited liquidity characteristics than the mutual fund. The Adviser seeks to drive portfolio returns through fundamental analysis and security selection. However, depending on Client guidelines and regulatory restrictions, the Adviser will incur leverage from time to time for the purpose of enhancing returns or hedging against

volatility in Client portfolios. Leverage is defined differently for each Fund according to the terms of the governing documents for each Fund. Although the Adviser primarily follows a buy and hold approach to sourcing and managing the securities in the portfolios, the Adviser also uses a number of other investment strategies and techniques depending on market conditions and Client restrictions, including, without limitation, hedging, directional allocation, credit default swaps, shortterm trading and other investment techniques and strategies to capitalize on market movements. The Adviser takes long positions and short positions in portfolio securities. The Adviser also takes long or short positions in derivative instruments such as credit default swaps and options for hedging and speculative purposes. Current income is not a significant criterion in the selection of most investments, but the Adviser attempts to generate cash flow (including both the payment of interest and return of principal) each month. The Adviser will follow a general policy of seeking to spread a Fund’s capital among a number of investments; however, each Fund’s portfolio will not necessarily be diversified within the spectrum of investments described above. A Fund will not utilize a set formula to determine how its assets are allocated among different classes of investments. Through a certain Private Fund, the Adviser aims to identify potentially attractive investment opportunities in the single family residential real estate market by purchasing and offering properties to rent. In this section, the term “Adviser” is used in reference to activities undertaken by the Adviser on behalf of its Clients, including their underlying investors. The risks undertaken by the Adviser should be read to include risks undertaken by each investor in the Adviser’s products except where indicated otherwise. GENERAL RISKS General. Neither the Adviser nor any of its Affiliates makes any guarantee or representation that the Funds’ investment objectives will be achieved or that their investment approaches will be successful. As is true of any investment, there is a risk that an investment in a Fund will be lost entirely or in part. In particular, there is a risk that the Funds may be wound up earlier than anticipated if they fail to meet their investment objectives or for any other reason in the discretion of the respective general partners. Overall Investment Risk. All securities investments risk the loss of capital. The nature of the securities to be purchased and traded by the Adviser and the investment techniques and strategies to be employed in an effort to increase profits may increase this risk. Many unforeseeable events, including but not limited to actions by government agencies and domestic and international political events, may cause sharp market fluctuations. Investors must be able to sustain substantial or total losses on the value of their investment.

Interest Rate Risk. A change in interest rates can have a significant effect on any portfolio of fixed income assets. To the extent that the cash flow from a fixed income security is known in advance, the present value (i.e., discounted value) of that cash flow decreases as interest rates increase; to the extent that the cash flow is contingent, the dollar value of the payment may be linked to then-prevailing interest rates. RMBS may react very differently from other fixed income securities: their durations can vary dramatically as interest rates move, making them more difficult to hedge, and some may be “negatively convex,” meaning that price increases may be limited in relation to price declines. Some securities can have unusually high durations (rising dramatically in price when rates fall, and falling dramatically in price when rates rise); others can have highly negative durations (falling dramatically in price when rates fall, and rising dramatically in price when rates rise). For example, most RMBS, especially most fixed-rate RMBS and most RMBS backed by fixed rate mortgage loans, decline in value when long-term interest rates increase. Even in the case of agency RMBS, the guarantees provided by government-sponsored enterprises do not protect a Fund from declines in market value caused by changes in interest rates. In the case of RMBS backed by adjustable rate mortgages (“ARMs”), increases in interest rates can lead to increases in delinquencies and defaults as borrowers become less able to make their mortgage payments following interest payment resets. At the same time, an increase in short-term interest rates would increase the amount of interest owed on a Fund’s reverse repurchase agreements. Conversely, during periods of low interest rates, borrowers are likely to refinance their existing loans. This typically results in increased prepayments, which could result in a Fund receiving payments of principal of its RMBS investments earlier than anticipated, and the Fund may not be able to reinvest those funds in investments with similar yields. In addition, RMBS investments may be structured to use interest rate hedges and other financing techniques to reduce the risk of interest rate mismatches and exposures. This typically exposes the RMBS issuer to counterparty risk as well as to the risk that the hedging strategy or other financing technique is ineffective. If a swap counterparty defaults and cannot be replaced, amounts available to make payments on the related RMBS may be reduced (including as the result of a termination payment payable to the counterparty, if applicable), and the issuer may not have sufficient available funds on distribution dates to make required payments of interest or principal on RMBS. Likewise, if the hedging strategy is ineffective, the issuer may not have sufficient available funds on distribution dates to make required payments of interest or principal on RMBS. In particular during periods of changing interest rates, a failed hedging strategy with respect to an RMBS investment by a Fund, whether due to ineffectiveness or a counterparty default, could cause a Fund’s business to be materially and adversely affected or result in significant losses for a Fund. Custody Risk. Institutions, such as brokerage firms, banks and broker-dealers, generally have custody of portfolio assets managed by the Adviser and often hold such assets in “street name.” The Adviser is subject to the risk that these firms and other brokers, counterparties or clearinghouses with which it deals may default on their obligations. Any default by any of such parties could result in material losses to the investor. Bankruptcy or

fraud at one of these institutions could also impair the operational capabilities or the capital position of the Adviser. In addition, securities and other assets deposited with custodians or brokers may not be clearly identified as being assets of the Adviser, causing the Adviser to be exposed to a credit risk with regard to such parties. The Adviser generally will only be an unsecured creditor of its trading counterparties in the event of bankruptcy or administration of such counterparties. In some jurisdictions, the Adviser may also only be an unsecured creditor of its brokers in the event of bankruptcy or administration of such brokers. The Adviser attempts to limit its brokerage and custody transactions to wellcapitalized and established banks and brokerage firms in an effort to mitigate such risks, but the collapse in 2008 of the seemingly well-capitalized and established banks demonstrates the limits on the effectiveness of this approach in avoiding counterparty losses. Cybersecurity Risk. The Adviser’s information and technology systems may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by its respective professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. The Adviser has implemented various measures to manage risks relating to these types of events. The failures of these systems or the disaster recovery plan for any reason could cause significant interruptions in the Adviser’s operations and result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including private information relating to Clients. Such a failure could harm the Adviser’s reputation or subject it or its affiliates to legal claims and otherwise affect their business and financial performance. Additionally, any failure of the Adviser’s information, technology or security systems could have an adverse impact on its ability to manage the Fund. The Funds depend on the Adviser to develop and implement appropriate systems for their activities. The Funds will rely extensively on computer programs and systems to conduct their investment business. In addition, certain operations will interface with or depend on systems operated by third parties, and the Funds or the Adviser may not be in a position to verify the risks or reliability of such third-party systems. These programs or systems may be subject to certain defects, failures or interruptions. Any such defect, failure or interruption could have a material adverse effect on the Funds. The Adviser and any service providers hired by the Adviser to provide services to Clients, including counterparties and electronic communication networks, are susceptible to operational and information security risks. While third-party service providers have procedures in place with respect to information security, their technologies may become the target of cyberattacks or information security breaches that could result in the unauthorized gathering, monitoring, release, misuse, loss or destruction of the Adviser’s or the Funds’ confidential and other information, or otherwise disrupt the operations of the Funds or those of any third-party service providers. Disruptions or failures in the physical infrastructure or operating systems that third-party service providers, or cyberattacks or

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The Adviser and its Affiliates serve as the management company, investment adviser or subadviser for pooled investment vehicles. The pooled investment vehicles are typically structured as domestic limited partnerships, offshore exempted companies, or offshore exempted limited partnerships. They can take the form of a “master-feeder” structure where investors invest in a feeder fund that invests exclusively in a master fund that is managed by the Adviser or can be stand-alone vehicles. With respect to the Private Funds, limited partnership interests in any domestic limited partnerships are offered on a private placement basis, and in reliance on Section 3(c)(7) of the 1940 Act, to persons who generally are “accredited investors” as defined under the 1933 Act, and “qualified purchasers” as defined under the 1940 Act, and who are subject to certain other conditions that are set forth in the offering documents for the applicable Fund. Shares in offshore Funds are generally offered to persons (x) who are not “U.S. Persons” as defined under Regulation S of the 1933 Act, or who are tax-exempt U.S. Persons (or entities substantially comprised of tax-exempt U.S. Persons) on a private placement basis and in reliance on Section 3(c)(7) as described above; and (y) who are subject to certain other conditions that are set forth in the offering documents for the applicable Private Funds. Investors in the Private Funds include some or all of the following: institutional investors, pension and profit-sharing plans, trusts, estates, charitable organizations, high net worth individuals, corporations or business entities other than those listed previously, private investment funds or other entities. Certain of the Private Funds are structured as standalone private investment vehicles, each for a single institutional investor. The mutual fund is registered under the 1940 Act and the 1933 Act. The mutual fund is advised by advisers that are not affiliated with Deer Park. These unaffiliated advisers contract with Deer Park to manage the investments of the mutual fund as a sub-adviser. The Adviser may manage separate accounts for institutional advisers from time to time.

As discussed in Item 5, the Adviser or its Affiliates are entitled to receive Performance Allocations from the Private Funds. The Private Funds have different Performance Allocation calculations and different Management Fees, and they all differ from the mutual fund. Affiliates of the Adviser also make investments into a proprietary investment vehicle managed by Related Persons (as defined in Deer Park’s Form ADV Part 1A) of Deer Park, some of which investments may also be purchased and held by the Funds. As a result of managing various Client and proprietary accounts on a side-by-side basis, the potential exists for the Adviser to seek to favor one of its Clients over another or itself over Clients in allocating investment opportunities or otherwise. Additionally, Performance Allocation arrangements may create an incentive for the Adviser or its Affiliates to make investments that are riskier or more speculative than would otherwise be the case if such an arrangement were not in effect, particularly in any period after losses have been suffered since losses from prior periods must be recovered before any Performance Allocation is payable. The Adviser may also invest more heavily in one of its Funds than in others, which may also serve as an incentive to favor one Client over another. Management Fees for certain Clients that are higher than others may create similar incentives. Additionally, while the other Private Funds will not purchase the same assets as those purchased by a certain Private Fund (residential homes), they do purchase and hold shares in companies that provide essential services to such Private Fund. These holdings create conflicts of interest between the Private Funds, the Adviser, and the Adviser’s Affiliates. The Adviser has adopted and implemented policies and procedures intended to address conflicts of interest. Performance Allocations may create an incentive for Deer Park to make investments that are riskier or more speculative than would be the case if a performance-based compensation arrangement were not in effect. Due to the method of calculating the Performance Allocation for any Fund, compensation of Deer Park may be affected by the timing of dispositions and other factors that will be within the control of Deer Park or one of its Affiliates. Deer Park or its Affiliates operate multiple lines of business and engage in a wide variety of business transactions and business ventures. Deer Park has invested the assets of Client portfolios in companies, entities and other investments in which Deer Park or its Affiliates (including proprietary accounts set up for principals of Deer Park or its Affiliates) hold a financial interest or derive other financial benefits, and Clients may make such investments at a different price, on different terms or with different conditions than Deer Park or its Affiliates. Deer Park has previously recommended, and will under circumstances appropriate for each Client, recommend that Clients purchase or sell an investment that is being sold or purchased, respectively, at the same time by Deer Park or an Affiliate. Under such circumstances Deer Park will have conflicts of interest in effecting transactions for its Clients, including transactions in which Deer Park or certain of its Affiliates may have a greater financial interest than their financial interest in a Fund.

Allocation Policy In general, the decision to aggregate and allocate investments among Clients, or to source and execute trades separately for any one Client, will be made on a fair and equitable basis. The effect of these activities may, however, operate to the advantage or disadvantage of any specific Client. For example, if the Adviser decides to purchase securities in a block trade for more than one Client, but there is not a quantity of the security available in the market sufficient to satisfy the investment amount desired for each Client, then each Client will be allocated less of the security or pay a higher price than if it had acted alone. In this circumstance, the Adviser may not be able to execute an investment decision for each Client as effectively as it could have if it acted on behalf of each Client alone. The Adviser may also execute trades that are not aggregated but rather are executed for one Client even where such security is suitable for other Clients. This may occur when the portfolio managers of one Client source a bond that is illiquid or not available in sufficient quantity to allocate to other Clients, when existing positions of the other Clients are being added to, when a Client does not have sufficient cash to participate in a minimum size, or in other circumstances. There may be a conflict of interest in the allocation of investment opportunities among Clients, including proprietary accounts and other investment vehicles managed currently or in the future by the Adviser. The Adviser, its employees, and its Affiliates manage Clients that may have investment objectives, programs, strategies and positions substantially similar to or in conflict with those of other Clients, or that may compete with or have interests adverse to other Clients. Such conflicts could affect the prices and availability of securities in which each Client is invested. In addition, the Adviser may, because of differing investment objectives, programs, strategies or other factors, cause Clients to take different and even opposite positions in a particular security or other transaction or take different positions within an issuer’s capital structure, or may give advice or take action with respect to the investments held by, and transactions of, a Client that may differ from the advice given or the timing or nature of any action taken with respect to the investments held by, and transactions of, another Client due to a variety of reasons, including, without limitation, differences between the recommendations or research of the portfolio managers of the Client and the portfolio managers of the other Client, or differences between the investment strategy, financing terms, regulatory treatment and tax treatment of one Client and other Clients. The ability to allocate a portion of a trade to a proprietary investment vehicle creates a conflict of interest for the Adviser in that the Adviser will profit disproportionally if the trade is profitable. In order to mitigate this risk, the Adviser has instituted policies and procedures to safeguard against unfair allocations. These procedures include a requirement that the portfolio manager ensure that Clients participating in a bulk trade with a proprietary account receive a full allotment before the proprietary account receives an allocation.

In some cases, participation in specific opportunities may be appropriate, at times, for one or more Clients that may or may not have similar trading objectives. In such cases, the Adviser may have conflicts of interest with respect to the allocation of investments among the Clients, as well as the aggregation of trade orders, where the Adviser, to the extent legally permissible, is authorized to combine purchase or sale orders on behalf of a Client together with orders on behalf of other Clients managed by the Adviser or any of its Affiliates. To address this conflict of interest and minimize potential adverse effects to Clients, the Adviser has adopted policies and procedures regarding allocations of trades. Pursuant to these policies and procedures, each of the Adviser’s portfolio managers, associate portfolio managers and senior analysts (collectively, the “Traders” and individually, a “Trader”) with responsibility for one or more Clients may, in his or her discretion, share information and source and execute trades jointly or may source and execute trades separately, each for Clients for which such Trader has responsibility. Similarly, each Trader may, in his or her discretion, execute block trades for multiple Clients over which such Trader has responsibility or for one Client and not others. The decision to aggregate trades or place a particular security in one Client and not in another will be based on a number of factors, including but not limited to: which Trader sourced the trade, different investment guidelines or yield targets, different cash positions, expected cash flows, expected withdrawals and capital contributions, existing positions in the subject security, or risk parameters and sizing constraints. Accordingly, each Client may have substantially different portfolios and investment returns as compared to any other Client. The Adviser and each of its Traders will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to any Client solely because the Adviser or its Traders purchase or sell the same security for another Client. This may occur where such security or transaction is sourced or recommended by the portfolio managers of one Client and such recommendation is not allocated to another Client. Similarly, the portfolio managers with responsibility for a Client may source or recommend a security or transaction that is not allocated to other Clients. This may also occur if the security or transaction does not appear to be suitable, practicable or desirable for any specific Client. Conflicts of interest may also arise when the Adviser makes decisions on behalf of a Client with respect to matters where the interests of the Adviser or one or more Clients differs from the interests of a Client in which the Adviser or an Affiliate holds an interest. The Adviser may cause Clients to purchase the same securities but at different times for several reasons. Because some Clients may have a different hold period target than other Clients, their analysis and confirmatory due diligence may take longer or be shorter than that of another Client. It is often not possible to determine in the early stages of analysis the correct allocations among different Clients, and follow-on allocations may substantially differ at times. Also, different Clients may have a tendency to sell during general market downturns (during which other Clients might be buying the same securities, because of differing investment goals). In some cases, a Client may pay a higher price for certain securities than those of other Clients.

The Adviser has in the past been aware, and in the future may become aware, of business opportunities in which a Client has not or will not be given an opportunity to participate. The Adviser may refer such business opportunities to its Affiliates or others and may receive a commission or other compensation in connection therewith. In certain cases, Clients may be competing for scarce or illiquid securities. For example, a Trader of one Client and the Trader of another Client may identify desirable but otherwise scarce or illiquid portfolio investments and purchase those securities for one or the other Client. In this case, a Client may not have the opportunity to purchase that specific security for its portfolio. The Adviser also manages three proprietary accounts that invest in securities that are also purchased or held by a Client. This creates the potential that the Adviser will seek to allocate to itself a security that it believes will be profitable, which could disadvantage Clients. As described above, the Adviser has instituted reasonably designed policies and procedures to mitigate these conflicts of interest. Side Letters In Private Funds, side letters or agreements with specific investors may be reached under which such investors may be granted preferential fee or liquidity terms, or other terms of such Private Fund may be waived or modified. Additionally, terms and conditions of Private Funds that are “funds of one” have been directly negotiated with the applicable investor. As a result, certain investors obtain additional benefits which other investors will not receive. Since a fund of one invests in many of the same securities as other Private Funds, there is the possibility that a fund of one could liquidate its holdings ahead of other Clients of the Adviser. Except as required by applicable law, in general, notification of other investors of such arrangements is not required nor is the Private Fund required to offer such additional and/or different rights and/or terms to any or all of the other investors.

Deer Park is an exempt commodity pool operator and commodities trading adviser. Neither the Adviser, its Affiliates nor any of its management personnel or employees: 1) are registered as a broker/dealer or a registered representative of a broker/dealer; or 2) have any application pending to register as a broker/dealer or a registered representative of a broker/dealer. The Adviser, its affiliates or any employees, officers, members, principals or directors of the Adviser or its affiliates may earn transaction fees, investment banking fees, break-up fees, advisory fees (including management fees received from portfolio investments), monitoring fees, directors’ fees or other similar fees (collectively, “Ancillary Fees”). Each quarterly installment of the Management Fee borne by the Fund investors participating in the investment to which any such fees relate will be reduced by such investor’s pro rata share of Ancillary Fees received by the Adviser; provided, however, that the Management Fee will not be reduced in circumstances set forth in the governing documents of the Funds (e.g., not in excess of the Management Fees earned in that period). Deer Park (through its Funds or their subsidiaries) has and may in the future engage portfolio companies of its Funds, or their affiliates, to provide various services relating to the analysis, acquisition, ownership and management of the Funds’ investments. Such portfolio companies or their affiliates may receive fees and compensation for the services provided to the Funds and their subsidiaries. In addition, Deer Park, its affiliates, or other Funds managed by Deer Park or its affiliates may have an ownership interest in such portfolio companies or their affiliates. Such an arrangement may create an incentive for Deer Park to engage such portfolio companies or their affiliates with more frequency than it otherwise would have and/or to agree to greater fees to be paid to them. Furthermore, such portfolio companies’ or their affiliates’ entitlement to certain fees related to the investments of the Funds may encourage them to make investment decisions or take other actions in respect of their services to the Funds and their subsidiaries that increase the total value of the investments held by the Funds. The fees earned by such portfolio companies or their affiliates in respect of services provided to the Funds and their subsidiaries, as well as any equity that Deer Park and its affiliates receive from them, will not reduce the Management Fees payable to Deer Park by the Funds. Deer Park is exposed to a conflict of interest in that Deer Park is incentivized to engage such portfolio companies or their affiliates over more qualified service providers due to Deer Park’s interest in them. There is a possibility that the Funds’ general partners, because of such incentive or for other reasons (including whether the use of such persons or entities could establish, recognize, strengthen or cultivate relationships that have the potential to provide longer-term benefits to the Funds’ general partners, and the Funds), may favor such retention or continuation even if a better price and/or quality of service provider could be obtained from another person or entity. Whether or not the Funds’ general partners have a relationship with or receive financial or other benefit from retaining such

portfolio companies or their affiliates or a particular service provider, there can be no assurance that no other service provider is more qualified to provide the applicable services or could provide such services at lesser cost. Deer Park may, in its sole discretion, determine to engage such portfolio companies or their affiliates to provide services in addition to those described in the Funds’ offering materials and, in such event, will determine the compensation to be paid to them and will generally have the authority to negotiate any services agreements entered into between them, on the one hand, and the Funds, on the other hand. Such service agreements will not be subject to review or consultation by any third party. Deer Park will have a conflict of interest in determining the costs of such services that will be charged to the Funds. In addition to determining the amount of compensation payable to such portfolio companies or their affiliates, Deer Park will have the authority to determine other key terms of the service arrangement, including terms relating to expense reimbursement, termination fees, indemnification payable to them and exculpation provided to them. While Deer Park will seek to ensure that the terms of the transactions and arrangements with such portfolio companies or their affiliates will contain terms at least as favorable to the Funds as are generally obtainable on an arm’slength basis from unrelated third parties and will provide for compensation that is competitive with the compensation paid to third parties for comparable services which could reasonably be made available to the Funds, there is no guarantee that such compensation will be consistent with market terms or that a third party would not have provided the same services at more favorable rates.

Trading Deer Park adopted a Code of Ethics (the “Code”) expressing the Adviser’s commitment to ethical conduct. Deer Park has a fiduciary duty to its Clients, which means that it must put the interests of its Clients ahead of its own interests. It is the Policy of Deer Park that all employees must: • • • • • •

Observe high standards of commercial honor and just and equitable principles of trade in all their dealings on behalf of the Adviser. Comport themselves in a manner consistent with the standard of conduct as set forth in this Code. Comply with all federal securities laws and other applicable laws and regulations. Report all personal securities transactions and holdings to the Adviser as provided below. Report any violations of this Code to the Chief Compliance Officer of the Adviser. Certify to the Adviser on an annual basis acknowledgement of the policies and procedures referred to in this Code and agreement to abide by them.

The Adviser’s Code of Ethics also places restrictions on the personal trading activities of employees. The Code of Ethics requires employees to register all personal trading accounts (and certain trading accounts in which the employee has a substantial interest or over which the employee has discretion) with the Adviser’s Compliance Department. Employees are required to report all transactions in securities and all positions in securities to the Compliance Department within 10 days after becoming an employee of the Adviser and thereafter at least once per calendar year. Employees are also required to report on a quarterly basis to the Compliance Department all transactions in securities within 30 days after the end of each calendar quarter. Additionally, the Code of Ethics requires that all employees receive written approval from the Chief Compliance Officer prior to investing in any limited or restricted securities offerings and/or MBS/ABS transactions. The Adviser maintains an approved list of securities that Employees may purchase and sell for their personal accounts. Employees are prohibited from purchasing securities (or derivatives thereof) that are not on this list, with the exception of certain broad-based ETFs, managed accounts by independent third-party investment advisers and other securities. The Adviser requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices. The Code of Ethics includes the Adviser’s policy prohibiting the use of material non-public information. Any individual not in observance of the above may be subject to discipline or termination.

An affiliate of the Adviser acts as general partner to the Private Funds that are managed by the Adviser. Additionally, Affiliates and employees of the Adviser have invested substantial amounts in the Private Funds and therefore have a financial interest in the Private Funds. Investments made by the Adviser and its employees are generally made on the same terms as other investors in the Funds; however, fees, investment minimums and redemption restrictions may be waived or reduced for them. The Adviser does not believe that this arrangement presents any material conflicts of interest because the Adviser’s financial interests are aligned with the interests of Clients. Deer Park’s Code of Ethics may be obtained by Clients or prospective Clients upon request.

The Adviser has full, discretionary authority to manage the investment of the Clients, including the authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and the commissions or mark-ups and markdowns paid. The Adviser need not solicit competitive bids or offers for any particular security. Accordingly, if the Adviser determines in good faith that the price paid for a security is reasonable relative to the value of such security, it may pay a price higher than or receive a price lower than another broker or dealer may have charged. Best Execution. It is the obligation of all investment advisers to obtain “Best Execution” of securities transactions for their clients. Best Execution is not defined in securities laws or regulations, but it is generally understood to require the adviser to obtain the most favorable total cost or proceeds in a securities transaction for its clients under the circumstances. The Adviser’s duty is not necessarily to find the best price or lowest cost, but rather to achieve the best qualitative execution for the Client. In doing this, the Adviser may take into consideration such factors as knowledge of the counterparty, speed of execution, confidentiality, market depth, capital commitment and recent order flow. A periodic and systematic assessment of execution services is important to the Adviser meeting its Best Execution obligation. Best Execution in fixed income markets is difficult to exactly define. Limited transparency, liquidity, size and other factors relating to the market for MBS and ABS securities make trading these instruments difficult and not subject to an exacting review of trading alternatives on either a pre-trade or post-trade basis. Cross Trades. Section 206(3) of the Investment Advisers Act of 1940, as amended, contains strict rules related to several types of transactions between different clients of an investment adviser. An adviser that arranges for a security to be purchased from or sold to a client from its own account – as opposed to purchasing or selling the security in the secondary markets – is engaging in a “Principal Trade.” An “Agency Cross Trade” occurs when an adviser arranges for a trade to be executed between a client and another party, and a “Cross Trade” occurs when an adviser effects a trade between accounts of two or more of its advisory clients but does not charge a fee for effecting the transaction. Principal Trades, Agency Cross Trades and Cross Trades can benefit Clients in a number of ways, including, but not limited to: 1) enabling the transfer of securities among Clients without having to expose the security to the market; 2) eliminating counterparty risk; and 3) providing the Adviser with added flexibility when dealing with an illiquid asset. Although Principal Trades, Agency Cross Trades and Cross Trades can be appropriate in many circumstances, they can also create the potential for conflicts of interest for the Adviser (i.e. the better price an adviser obtains for the selling client, the worse it can be for the purchasing client).

As is consistent with its duty to seek to obtain best execution, occasionally the Adviser may execute cross trades for Client accounts. Deer Park utilizes “cross” trades when it specifically deems the practice to be advantageous for each participant. In no instance does Deer Park receive additional compensation when crossing trades for Client accounts. Deer Park will seek to ensure that the terms of the transaction, including the consideration to be paid or received, are fair and reasonable, and the transaction is done for the sole benefit of the Clients. The Adviser will not affect Principal or Agency Cross Trades involving ERISA clients. Trade Errors. The Adviser may, on occasion, experience “Trade Errors” with respect to trades made on behalf of Clients. A Trade Error occurs when a transaction is not executed according to the Adviser’s intent and instructions. Trade Errors can result from a variety of situations, including, but not limited to, when the wrong security is purchased or sold, when the wrong amount is purchased or sold, when a security is purchased when it was meant to be sold or vice versa or when the same trade is executed twice. Not all errors are properly classified as Trade Errors. Certain errors in booking transactions are not considered Trade Errors, nor are mistakes in calculating NAV for a Fund. If an error is identified and corrected before any Client books or settles the position in their account or incurs a loss as a result, the error is not considered a Trade Error. If the error occurs as a result of the actions of a third party (such as a broker/dealer) then it is not considered a Trade Error. Clients will be reimbursed for any material loss realized as a result of a Trade Error. Any gains will be for the benefit of the Account. The Adviser may take such other action as is reasonable under the circumstances. Soft Dollars. In selecting any broker-dealer and in determining the reasonableness of brokerage commissions charged, the Adviser may take into account the fact that a brokerdealer has furnished or will furnish the Adviser or its Affiliates, without charge, with statistical, research or other information or services which may enhance its services generally, whether or not such services, in any particular instance, are of any benefit to the Adviser’s Clients. Such services may take the form of research services, special execution capabilities, clearance, settlement, net price, online pricing, block trading and block positioning capabilities, economic and market information, portfolio strategy advice, industry and company comments, technical data, recommendations and general reports. Accordingly, the Clients may be deemed to be paying for research and such other services with “soft” or commission dollars. The Adviser will only enter into such “soft dollar” arrangements where it reasonably believes that they will be within the “safe harbor” of Section 28(e) of the Securities Exchange Act of 1934, as amended. The Adviser does not currently pay and does not anticipate the need or desire to pay, for research or other services with “soft dollar” arrangements. Nonetheless, in the future, the Adviser may choose to pay for research or other services through “soft dollar” arrangements. In such case, even though the Adviser believes that a Client will benefit from many of the services obtained with “soft” dollars generated by trades, each affected Client

will likely pay higher transaction costs than it would in the absence of such arrangements and may not benefit from all of these “soft dollar” services or one Client may benefit disproportionally to other Clients. Furthermore, the Adviser and its Affiliates and other funds or accounts that they may manage may also derive substantial direct or indirect benefits from these services, particularly to the extent that any of them uses “soft” or commission dollars to pay for expenses that it would otherwise be required to pay itself. If the Adviser does choose to pay for research or other services through “soft dollar” arrangements, broker-dealers may provide research and brokerage services directly or by paying service providers engaged by the Adviser. In connection with any receipt of products or services under “soft dollar” arrangements, the Adviser will determine in good faith that the amount of commissions charged is reasonable in relation to the value of the products or services provided by the broker-dealer. Where a product or service provided has both “eligible” uses under Section 28(e), i.e., uses related to the Adviser’s investment decisionmaking process, but also has other uses, then the Adviser will make a reasonable allocation between the eligible and non-eligible uses and use soft dollars only for the eligible portion. It should be noted that the investment information received from broker-dealers, irrespective of whether such investment information was received complimentary or through “soft dollar” arrangements, may be used by the Adviser or its Affiliates in servicing various Clients regardless of the amount of “soft dollar” commissions contributed by that Client. The Adviser believes that such an allocation of brokerage business will help each Client to obtain research and execution capabilities and will provide other benefits to the Clients. The Adviser may, but is not obligated to, enter into arrangements under which certain direct expenses of a Client are paid with soft dollars. The Adviser will enter into such arrangements where it believes that it is administratively or operationally expedient to do so or where the Adviser believes it is more favorable to than an arrangement under which a Client pays for the products or services in question with cash. However, such arrangements make it more difficult for investors to evaluate the cost structure of a fund because the costs of such products or services are not broken out separately. In addition to any “soft dollar” arrangements that the Adviser enters into with brokerdealers, broker-dealers may provide certain research or other products or services to all of their customers, including the Adviser, without being requested to do so. Similarly, brokerdealers may refer investors to the Adviser. The Adviser may take advantage of the products or services provided rather than producing or paying for them from another provider. Similarly, the Adviser may accept investor referrals from broker-dealers in appropriate circumstances. In these situations, the Adviser receives a benefit because it does not have to pay for the products or services, such as research, or because it will receive additional compensation if a Client accepts new investments. The Adviser has an incentive to recommend broker-dealers based on benefits that it receives from broker-dealers, whether or not pursuant to “soft dollar” arrangements, rather

than the interests of a Fund in receiving the most favorable execution. Any products or services that the Adviser receives from broker-dealers may be used in connection with its management of more than one Client. The Adviser assumes no responsibility for the actions or omissions of any broker-dealer or dealer selected by the Adviser in good faith.

Deer Park does not receive any economic benefit from anyone other than its Clients for providing investment advice or advisory services to its Clients. The Adviser and its affiliates have entered into agreements with placement agents with respect to investors introduced to a Private Fund managed by the Adviser providing for the placement agent to receive a portion of the Adviser’s fee with respect to investors introduced. Any amounts paid to a placement agent will reduce the amount of fees paid to the Adviser from the Private Fund; the fees paid to placement agents will not increase fees paid by any Private Fund investor.

On June 4, 2019, Deer Park and Mr. Burg entered into an order (the “Order”) with the SEC. Without admitting or denying the findings in the Order, the SEC found that from at least October 2012 through December 2015 (the “Relevant Period”) the Adviser’s policies failed to address sufficiently how to conform its valuations with Generally Accepted Accounting Principles (“GAAP”). Further, the SEC found that the Adviser’s policies were not reasonably designed for its business practices, given its use of valuation models and pricing vendors and the potential conflict of interest arising from Traders’ ability to determine the fair value of a portion of the positions they manage. The Order also states that the Adviser failed to implement its existing policy. In accordance with GAAP, the Adviser’s valuation policy included a requirement to maximize the use of relevant observable inputs, however, during the Relevant Period the Adviser failed to ensure that certain RMBS were valued in accordance with GAAP. Specifically, the Adviser may have undervalued certain assets by failing to maximize relevant observable inputs, such as trade prices. The SEC found that Mr. Burg was a cause of the Adviser’s failure to implement the valuation policy that required maximizing observable inputs. The SEC censured the Adviser and ordered the Adviser and Mr. Burg to cease and desist from committing or causing any violations of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The SEC fined the Adviser $5 million and Mr. Burg $250,000. To the best of the Adviser’s knowledge, there are no other legal or disciplinary events that would be material to an advisory client or prospective advisory client’s evaluation of the Adviser’s advisory business or the integrity of the Adviser’s management. As part of the Adviser’s routine compliance training and monitoring program, all employees are asked to certify upon hire, and annually thereafter, whether they have been the subject of any disciplinary actions.

Client accounts are reviewed on an as-needed basis, but no less frequently than monthly. Reviews are undertaken by portfolio managers. All investors in the Private Funds receive monthly reports from the Administrator and regular performance updates and commentary from the Adviser. The monthly updates consist of statistical information and a marketspecific narrative. Information on each Private Fund is also made available to investors through the Adviser’s password protected website. In addition, tax reports and annual audited financial statements are issued relating to the relevant Private Fund within 120 days after the end of such Private Fund’s fiscal year.

The Adviser is deemed to have custody over the funds and securities of each Private Fund. The Adviser is subject to SEC Rule 206(4)-2 under the Investment Advisers Act of 1940, as amended. However, it is not required to comply, or is deemed to have complied, with certain requirements of the rule because it complies with the so-called “Pooled Vehicle Audit Exception.” This exception requires that each Private Fund be subject to audit at least annually by an independent public accountant that is registered and subject to regular inspection, by the Public Company Accounting Oversight Board, and requires that each Private Fund distributes its audited financial statements to all investors within 120 days of the end of the Private Fund’s fiscal year.

As noted in Item 4, the Adviser or its Affiliate has been appointed the investment manager, investment adviser, or the sub-adviser with full discretion with respect to investment decisions on behalf of and trading in the Clients’ accounts, or sub-accounts. Investment guidelines and restrictions are set forth in respective Investment Management Agreements, Limited Partnership Agreements, and/or offering documents for each Client. When selecting securities or determining amounts, the Adviser observes the investment policies, limitations and restrictions imposed by the Client.

The Investment Advisers Act of 1940, as amended, requires investment advisers that have proxy voting authority to: (i) adopt policies and procedures for voting proxies in the best interest of the client; (ii) describe the procedures to clients; and (iii) inform clients how they may obtain information about how the adviser has actually voted their proxies. Since we invest almost exclusively in fixed income securities (as opposed to equities), we rarely receive proxies to vote. The Adviser’s general policy is to vote proxy proposals, amendments, consents or resolutions relating to securities, including interests in pooled investment vehicles, if any (collectively, “proxies”), in a manner that serves the best interests of the Clients, as determined by the Adviser in its discretion, taking into account the following factors: (i) the views of management; (ii) the impact on the value of the investments; (iii) the continued or increased availability of portfolio information; and (iv) industry and business practices. In addition, the Adviser may not vote proxies in certain situations where the associated costs outweigh the anticipated benefits to Clients. If a material conflict of interest exists between the interests of the Adviser and those of the relevant Client with respect to any issue to be voted on, the Adviser will base its voting decision exclusively on the Adviser’s judgment of what will best serve the financial interests of the Client that beneficially owns the securities that are the subject of the vote. Investors in a Private Fund may request a copy of the proxy voting policies and the proxy voting record relating to the relevant Private Fund by contacting the Adviser.

Deer Park is not required to attach a balance sheet to this brochure because it does not require the prepayment of more than $1,200 in fees per Client, six months or more in advance. Deer Park is not aware of any financial commitments that impair its ability to meet contractual and fiduciary commitments to Clients and has never been the subject of a bankruptcy proceeding.