HORIZON KINETICS ASSET MANAGEMENT LLC

Horizon Kinetics Asset Management LLC (“HKAM”, “Adviser” or the “Firm”) is a Delaware limited liability company formed and registered with the SEC in 1994 that is a wholly owned subsidiary of Horizon Kinetics Holding Corporation (“HKHC”), a publicly traded company (OTC: HKHC). The Firm has two affiliated brokerdealers, KBD Securities, LLC (“KBD”) and Kinetics Funds Distributor LLC (“KFD”). As a wholly owned subsidiary of HKHC, HKAM is subject to the governance and oversight of HKHC’s Board of Directors. The Firm has discretionary management over separately managed accounts, mutual funds, exchange traded funds (“ETFs”), a closed-end fund, a European UCIT fund, and multiple private funds. There are no principal owners that have beneficial ownership of over 25% or more of the Firm’s parent company, HKHC, as indicated on Schedule A of Part 1A of Form ADV, which is available on the SEC’s website. As noted above, the Firm’s parent company is a publicly traded company. Since the Firm was co-founded in 1994 by Murray Stahl, Steven Bregman, Peter Doyle, Tom Ewing and John Meditz, we have had consistency in our investment teams, supported by stability in our organization. Steven Bregman and Peter Doyle, as Co-Chief Executive Officers, are responsible for overseeing the Firm’s investment process. The Firm’s research team, which has been publishing research continuously since its founding, has worked closely together for over 30 years. Certain research reports are available to the public on the Firm’s website, www.horizonkinetics.com. In late 2026, the Firm’s research model returned to the spirit of its original Contrarian Research Report. The objective is to focus on what we believe independent research does best: identifying interesting, underappreciated or misunderstood investment opportunities wherever they may exist. HKAM provides discretionary investment advisory services to a variety of investment products: Mutual Funds Kinetics Mutual Funds, Inc. The Firm provides discretionary investment advisory services to the Kinetics Mutual Funds, Inc. (“KMF”), a series of U.S. investment companies (each a “Fund” or collectively, the “Funds”) registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”). KMFs are generally appropriate for longterm investors and as such the Funds impose a Redemption Fee equal to 2.00% for any redemptions made within 30 days of purchase. The Firm’s management of KMFs is consistent with the strategies and objectives outlined in each Funds’ Prospectus and Statement of Additional Information. Closed-End Fund The Renn Fund, Inc. The Firm provides discretionary investment advisory services to the Renn Fund, Inc. (the “Renn Fund”), a closedend investment company that trades on the New York Stock Exchange (“RCG”) and is registered under the Investment Company Act of 1940. Exchange Traded Funds The Firm provides discretionary investment advisory services to several actively managed exchange traded funds (“ETFs”) which are structured as part of a multiple series trust (“MST”) overseen by US Bancorp Fund Services, LLC. UCITs The Firm provides discretionary investment advisory services to one UCIT ETF with three share classes that are traded on the Euronext Amsterdam Stock Exchange (EAM) and the Euronext Dublin Stock Exchange (XDUB).

Separately Managed Accounts The Firm provides discretionary investment advisory services to numerous institutional and retail separate accounts (“SMAs”), including through direct, model delivery and wrap programs. SMAs are generally only available to institutional and High Net Worth investors. In addition to offering a variety of established investment strategies, the Firm also offers customized investment management strategies through separate accounts (“Custom Accounts”). Custom Accounts may utilize a combination of existing strategies offered by the Firm or may invest in securities or other instruments not otherwise offered by the Firm. Fees for a Custom Account may vary and depend on, among other things, the strategy and the complexity of managing the account. Placing investment restrictions on a separately managed account or on investment advice in general may adversely affect the Firm’s ability to implement its investment strategy, to track a composite, or to generate the returns the Firm might otherwise have been able to produce if the investment restrictions were not imposed on the account. The Firm’s management of SMAs is consistent with the terms of each account’s investment advisory agreement. The Firm is not a wrap program sponsor; however, it is a participant in wrap programs as it provides portfolio management services to those clients who invest through a wrap program with their custodian. In these instances, the Firm does not evaluate a client’s individual investment objectives, and the Firm does not review a client’s suitability for a particular strategy. These responsibilities are undertaken by the wrap fee sponsor and/or the client’s broker. The strategies managed by the Firm through model delivery and wrap programs may differ from other accounts managed by the Firm in that they may be more or less concentrated, have more or less investment restrictions, hold more or less cash, employ special methods to address end of year tax issues and may use directed brokerage (as further described under Item 12). Private Funds The Firm provides discretionary investment advisory services to private funds (as defined under the Dodd-Frank Wall Street Reform and Consumer Protection Act) which employ a variety of investment strategies, including those focused on equity, fixed income, alternatives, and multi-strategies. The private funds are generally only available to certain sophisticated, qualified investors. In addition, the Firm and/or its related entities also serve as the General Partner to the private funds. The Private Funds are intended for long-term investors and as such, HKAM reserves the right to impose restrictions, as it may deem necessary or appropriate, to discourage or prevent short-term trading activity in connection with its advisory services. Such restrictions could include, without limitation, a fee imposed on the redemption or transfer of assets made within a certain time period, a lock-up of investor money for a period of time, or suspension of a redemption for any reason, in the sole determination of the Firm. The Firm’s management of private funds is consistent with each funds’ offering documentation. Sub-Advised Funds The Firm serves as sub-adviser to certain U.S. investment companies. In such arrangements, the Firm generally provides investment and back-office services while another third party serves as adviser to the funds. FRMO Corporation FRMO Corp. (“FRMO”) (OTC: FRMO) is a publicly traded intellectual capital that is separate and apart from HKAM and HKHC. However, several of the founders and senior executives of the Firm act as principals and board members of FRMO and it is a shareholder of HKHC. FRMO also has a contractual arrangement with HKHC whereby it derives certain of its revenue from the revenue generated at HKHC. The Firm has adopted several policies and procedures to address any potential conflicts that arise as a result of the relationship between the Firm and FRMO. Consensus Mining and Seigniorage Corporation Consensus Mining and Seigniorage Corporation (“CMSG”) (OTC: CMSG) is a publicly traded cryptocurrency mining company that is separate and apart from HKAM and HKHC. CMSG has a contractual agreement with HKHC whereby HKHC provides management and oversight services for a fee. The Firm has adopted several

policies and procedures to address any potential conflicts that arise as a result of the relationship between the Firm and CMSG. Other On a limited basis, HKAM also provides other investment advisory services such as asset allocation solutions, investment consulting, investment and investment policy monitoring, non-discretionary investment management, and advice relating to current and future investments. Clients retain discretion over all assets under consulting arrangements and are responsible for implementing or declining to implement any consulting services or advice provided by HKAM. The Firm’s management of client assets is made considering potential tax consequences, but the Firm does not manage assets with regard for each underlying investor’s specific tax objectives. Investors are responsible for any tax liabilities resulting from transactions (including any arising from, the addition of assets to, or withdrawal of assets from the investor’s capital account). HKAM makes no representation regarding the likelihood or probability that any proposed investment will in fact achieve a particular goal. Each client must carefully consider the appropriateness of the proposed investments in light of the client’s own personal financial circumstances, including cash flow needs, unusual tax circumstances or other complex or subjective concerns. Clients are urged to seek the advice of tax professionals and to use all available resources to educate themselves about investments in general, as well as the investments made by HKAM. Assets under Management As of June 30, 2026, client assets managed by HKAM totaled approximately $10,780 million; discretionary assets totaled $10,435 million and non-discretionary assets totaled $345 million.

HKAM’s advisory fee schedules are based on, among other things, the type of investment product. Kinetics Mutual Funds, Inc. Fees The Firm receives a management fee based on the assets under management in client accounts. Fees from KMFs are deducted and paid monthly in arrears pursuant to the investment advisory agreement between the Firm and KMFs. The Firm receives a management fee of between 0.90% and 1.25% of the assets under management for its services as investment manager to KMFs. The complete list of expenses attributable to each fund is located in each fund’s most recent prospectus, which can be accessed here: www.kineticsfunds.com. Investors holding shares of KMF are subject to certain fees and expenses, which primarily consist of brokerage and transaction fees charged by executing brokers, administration fees charged by the administrator, and audit fees charged by the auditor. Investors should consult the prospectus of KMF for a complete list of fees and expenses relating to an investment. There may also be fees for exchange fees, SEC fees, advisory and administrative fees charged by mutual fund companies and exchange-traded funds held in the portfolios, custodial fees, transfer taxes, wire transfer and electronic fund processing fees, and commissions or mark-ups/mark-downs on security transactions. Many fees, including custodian, audit and administrative fees may be negotiated between KMFs and the service provider. Separately Managed Account Fees The Firm’s fee schedule for SMAs distinguishes between private clients and institutional accounts. Institutional accounts are generally those that invest a minimum of $5 million. Fees are generally paid directly or deducted from a client’s account quarterly, in arrears, although certain clients may elect to pay the Firm in advance. Clients invested through wrap programs sponsored by third party financial institutions generally pay the wrap program sponsor and/or custodian directly. In that instance, the Firm receives its fee from the sponsor and/or custodian. The Firm reserves the right to negotiate minimum account size, dependent upon various factors, including, but not limited to, the scope of the advisory services provided, economies of scale, the expectation of future assets, and any historic relationship with HKAM. Certain types of delivery versus payment (DVP) arrangements may result in higher minimums than those stated. Fees for client accounts are generally based on the market value of the assets under management in accordance with the schedules stated below. Certain Custom Accounts may charge fees that are higher or lower than other accounts that have holdings similar to the strategies listed below. The Firm may also offer strategies that impose a performance fee (also referred to as an incentive fee). A performance fee is a fee based on a share of capital gains on, or capital appreciation of, the assets of an account. Performance fees are generally deducted from an investors account annually, at the end of every calendar year, but may also be deducted quarterly. Performance fees may also be subject to a “high water mark,” or other “hurdle rate,” pursuant to the investment management agreement. Fees may be assessed either monthly or quarterly (the “accounting period”), using a 365-day calendar, and either in advance or in arrears, in accordance with the terms of the offering memorandum, client’s investment management agreement and/or the practices of the sponsor program servicing the client account. Typically, clients authorize the deduction of fees from their accounts; however, certain clients may choose to be billed directly. Fees are generally calculated based on the period-end market value of all assets in the client account, including securities, cash and cash equivalents. Security values are determined in accordance with HKAM’s written pricing policies and procedures which primarily rely on pricing from independent third-party sources but may be made by HKAM where such third-party pricing is not available or where it reasonably believes third-party prices are

incorrect. Fees for accounts that are active for partial accounting periods are prorated, based on the number of days the account was open. Clients with a portion of their separately managed account assets invested in KMF, the Renn Fund, the ETFs or the private funds managed by HKAM are not charged a fee on the portion of their account invested in such products. However, accounts that hold funds managed by HKAM will incur the costs related to being a shareholder in such funds, including management fees, administrative fees, and other similar fees as described in each products’ applicable offering documents. The annual total net expense ratio for a particular fund may be higher or lower than the management fee HKAM charges for an investment account. Clients may pay investment management fees in advance; however, HKAM does not require prepayment of advisory fees. If a Client has paid fees in advance, upon termination, HKAM will remit to the Client the remaining prorated portion of any prepaid fees. The Firm’s basic SMA fee schedule is as follows. Please note that fees may be negotiated with certain clients. Private Client Accounts:

Strategy All-Cap Asia Opportunities Core Value Japanese Special Opportunities Large Cap Research Select Small Cap Spin-Off Strategic Value

Fees

First $5 million = 1.00% Next $5 million = 0.95% Next $15 million = 0.85% Over $25 million = 0.75%

Investment Minimum

$500,000

Institutional Accounts: Although fees may be negotiated, the Firm’s basic fee schedules and investment minimum amounts are stated below. The minimum account size for institutional accounts is generally $5,000,000. Strategy Asia Opportunities Japanese Special Opportunities

Fees

Investment Minimum

First $25 million = 1.00% Over $25 million = 0.75%

$5,000,000

Core Value Large Cap

First $5 million = 1.00% Next $5 million = 0.75% Next $15 million = 0.60% Next $25 million = 0.50% Over $50 million = 0.45%

$5,000,000

Research Select Strategic Value Spin-Off

First $5 million = 1.00% Next $5 million = 0.85% Next $15 million = 0.75% Next $25 million = 0.65% Over $50 million = 0.60%

$5,000,000

Small Cap

First $5 million = 1.00% Next $5 million = 0.90% Next $15 million = 0.80% Over $25 million = 0.70%

$5,000,000

Private Fund Fees With respect to private investment funds (“Private Funds”), HKAM receives fees as set forth in each Private Fund’s respective confidential Private Placement Memorandum (the “Offering Documents”), which generally consists of a management fee and/or, as applicable, a performance fee. A management fee is a fee the Firm charges on fund assets and is generally deducted from an investor’s capital account monthly, in arrears. A performance fee is a fee based on a share of capital gains on, or capital appreciation of, the assets of a fund. Performance fees are generally deducted from an investor’s capital account annually, at the end of every calendar year, but may also be deducted quarterly. Any such performance fees will comply with the applicable requirements of the Advisers Act and specifically Section 205-3 thereof (otherwise referred to as the “Performance Fee Rule”). Some Fund investors, including employees of HKAM, may negotiate or be entitled to terms and conditions that differ from those of other Fund investors, with respect to fees and other provisions. Private Funds are not appropriate for all investors. Eligible prospective investors and current investors should refer to each Private Fund’s confidential Private Placement Memorandum for a complete list of risks, expenses, investment minimums and other important information. Closed-End Fund Fees The Firm is the investment adviser to the Renn Fund, a closed-end fund. Pursuant to the terms of the investment advisory agreement between the Firm the Renn Fund, the Firm does not charge a management fee until the fund has assets of greater than $25 million. The fee payable to the Firm thereafter will be 1.00%. Investors should read the Renn Fund’s annual and semi-annual reports carefully before investing. Exchange-Traded Fund Fees The Firm is the investment adviser to several ETFs. Pursuant to the terms of the investment advisory agreements, the Firm charges a unified management fee of 0.85% (85 basis points) for each ETF, which is calculated daily and paid monthly based on the funds’ average daily net assets. UCITs The Firm manages one UCITs fund, the fees of which are contained in the fund’s prospectus. Mutual Fund Sub-Advisory Fees Mutual fund sub-advisory fees vary by fund and are described in each such fund’s Prospectus and Statement of Additional Information. You should read a fund’s Prospectus carefully before investing. Research Reports Horizon Kinetics previously authored seven research reports. In late 2026, the Firm’s research model returned to the spirit of its original Contrarian Research Report. The objective is to focus on what we believe independent research does best: identifying interesting, underappreciated or misunderstood investment opportunities wherever they may exist. While all acknowledge the tremendous power of compounding, practically speaking (and by definition) this benefit simply cannot be harnessed in a short time frame. Our investment strategies – supported entirely by our own independent, fundamental research – typically reflect contrarian views that seek to take advantage of the short-term focus of the marketplace.

Negotiability of Fees Fees may be negotiated and a client may pay more or less than similar clients depending on various factors, including, but not limited to, account size, historic relationship with HKAM, the potential for future business prospects, the scope and complexity of the advisory services provided (e.g., service level and reporting requirements). The Firm reserves the right to negotiate different fees with clients, which may be higher or lower than those reflected herein. Certain investors, including employees or owners of the Firm, may negotiate lower fees or be entitled to different terms and conditions than those of other investors. Fee minimums may apply. Additional Fees and Expenses In addition to fees paid to HKAM for management of an account, investors are also subject to certain fees and expenses charged by, and paid directly to, third parties including broker-dealers and/or custodian banks, whether or not securities are being purchased, sold or held in client accounts. HKAM does not receive, directly or indirectly, any of these fees charged to client accounts. They are paid to broker-dealers, custodians, mutual funds or other financial institutions that are responsible for holding or transacting in securities held in client accounts. These fees include, but are not limited to: brokerage commissions, transaction fees, exchange fees, SEC fees, advisory fees and administrative fees charged by mutual fund companies and exchange-traded funds (“ETFs”), custodial fees, transfer taxes, wire transfer and electronic fund processing fees, and commissions or mark-ups/mark-downs on security transactions. Custodial fees are negotiated between the client and the respective custodian. HKAM does not recommend custodians to its clients, nor is HKAM involved in the negotiation of custodian relationships. Supervised persons (defined as any officers, partners, directors or other persons occupying a similar status or performing similar functions, or employee, or other person who provides investment advice on the Firm’s behalf and is subject to the Firm’s supervision and control) are not compensated on the sale of securities or other investment products; however, as noted in Item 10 (Other Financial Industry Activities and Affiliations) of this Brochure, KBD Securities, LLC (“KBD”), an affiliate of the Firm, has a contractual arrangement with the Firm for the payment of fees relating to the referral of investors to the Firm. Similarly, the Firm has contractual agreements with other third-party marketers as described in Item 10 of this Brochure. Any fees paid to KBD, other third-party marketers, or HKAM sales and marketing employees are paid directly by the Firm and are not paid by clients. KBD is a broker-dealer registered with the SEC and a member of the Financial Industry Regulatory Authority (“FINRA”).

Material, Significant, or Unusual Risks Relating to Investment Strategies HKAM authors research reports for numerous institutional clients and is involved in the creation and maintenance of rule-based indices. As a result, the Firm may restrict the trading in client and employee accounts of certain securities for a period of time consistent with the Firm’s compliance policies and procedures. These restrictions may adversely affect certain funds’ and accounts’ ability to implement their investment strategy. For instance, certain funds and accounts may be delayed in purchasing a security at a lower price during such restricted period and may not be able to sell a security as quickly as it might otherwise have wanted to if such restriction were not in effect. The Firm utilizes a restricted list and has adopted policies and procedures thereunder to detect and mitigate or prevent potential conflicts of interest. Investment Objectives The investment objectives of the funds and accounts managed by HKAM are set forth in, among other things, the respective Prospectus, Offering Documents, or investment advisory agreements applicable to the particular fund or account. Method of Analysis HKAM conducts its own proprietary in-house research consisting primarily of a qualitative and quantitative, bottom-up, value-oriented analysis of a wide universe of companies operating in the U.S. and abroad. Accounts are managed primarily by investing, trading and dealing in public securities of all kinds and descriptions, including, but not limited to, equity, debt, convertible securities, preferred stock, options, warrants, trade claims, and monetary instruments. HKAM, on behalf of its client, may also invest in arbitrage and special situations, both long and short securities positions, option arbitrage, commodities, digital currencies, international arbitrage and other financial instruments. Risks Investing in securities involves risk of loss that clients should be prepared to bear. All investments risk the loss of invested capital and the performance of investments is not guaranteed. Certain investment techniques, such as short sales, synthetic short sales, investments in illiquid investments and limited diversification, in some circumstances, may create heightened risks. Short selling the securities of an issuer may subject clients to unlimited loss. Additionally, short selling is subject to certain restrictions imposed by various national and regional securities exchanges, which restrictions could have a negative impact on the Firm’s clients. Synthetic short selling, the practice of purchasing a security normally a candidate for a short sale and simultaneously selling “call” options and purchasing “put” options on the same underlying security, may also present increased risks of loss. At times the markets for some securities, including securities chosen by the Firm, may have or develop limited liquidity and depth. This lack of depth may have a material impact on the level and volatility of security prices and the liquidity of the investments made by the Firm on behalf of its clients. The Firm may invest an account in such a way that it is concentrated in a limited number of holdings. A portfolio with fewer positions could be expected to have greater volatility from individual security price changes than would a portfolio holding a larger number of positions. The Firm may also choose to invest in smaller or medium sized capitalization companies of a less seasoned nature than large capitalization companies. As smaller and medium sized companies may face significant factors preventing them from competing against larger, better known companies, investments in “small cap” or “mid cap” securities often involve significantly greater risks than investments in larger capitalization companies. The Firm may invest in options, which present unique risks. Should interest rates or exchange rates or the prices of securities or financial indices move in an unexpected or unanticipated manner, the Firm’s clients may not achieve the desired benefit of the options and derivatives and may realize a loss. Such strategies may subject clients to greater fluctuations in value than would an investment in the underlying securities.

The Firm may manage certain accounts with borrowed money to purchase securities, otherwise known as using leverage or borrowing on margin. Although such practice may allow for greater capital appreciation, it also increases the client’s exposure to capital risk and higher current expenses. Moreover, if the assets under management are insufficient to pay the principal of, and interest on, the debt when due, the clients could sustain a total loss of their investment. Additionally, when the Firm purchases securities on margin, because the Firm has only paid for a portion of the instrument’s face value and has borrowed the remainder, a relatively small price movement may result in substantial losses. Trading on margin will also result in interest charges. The Firm is registered and regulated by a variety of federal, regional and state regulators, including the SEC. Registered investment advisers are subject to extensive regulation, including the requirements imposed by the Advisers Act. To the extent the Firm’s registration is suspended, cancelled or otherwise revoked, its clients may be adversely affected. In addition, the Firm manages certain private funds that are not registered as investment companies under the Investment Company Act or any other similar state laws. Registered investment companies are subject to extensive regulation. Investors, therefore, will not be accorded the protective measures provided by such regulation. As always, past performance of any of the Firm’s investment products does not represent or guarantee future results. The success of any investment activity is influenced by general economic conditions, which may affect the level and volatility of interest rates and the extent and timing of investor participation in the markets for both equity and interest rate sensitive securities. Unexpected volatility or illiquidity in the markets in which the Firm directly or indirectly holds positions could impair the Firm’s ability to carry out its business and could cause losses to its clients. Common and Preferred Stock; Convertible Securities Common stocks are units of ownership of a corporation. Preferred stocks are stocks that often pay dividends at a specific rate and have a preference over common stocks in dividend payments and liquidation of assets. Some preferred stocks may be convertible into common stock. Convertible securities are securities that may be converted into or exchanged for a specified amount of common stock of the same or different issuer within a particular period of time at a specified price or formula. Debt Securities The Firm, on behalf of the accounts it manages, may invest in convertible and non-convertible debt obligations without regard to rating, and as a result, may purchase or hold securities in the lowest rating categories. Debt securities in the lowest investment grade categories are considered to be below investment grade securities that may not have adequate capacity to pay principal or that otherwise generally lack the characteristics of desirable investments. As compared to debt securities with higher ratings, these “high risk” securities are vulnerable to nonpayment and depend to a larger degree upon favorable business, financial and economic conditions for the obligor to meet its financial commitment on the obligation. Additionally, the fixed-income securities in which the Firm may invest are generally subject to interest rate risk, credit risk, market risk and call risk. Interest Rate Risk There is a risk that when interest rates increase, fixed-income securities held by an account will decline in value. Long-term fixed-income securities will normally have more price volatility because of this risk than short-term fixed-income securities. Credit Risk This risk relates to the ability of the issuer to meet interest and principal payments, as they become due. The ratings given a security by rating services such as Moody’s Investors Service, Inc. (“Moody’s”) and Standard & Poor’s Rating Service (“S&P”) generally provide a useful guide as to such credit risk. The lower the rating given a security by such rating service, the greater the credit risk such rating service perceives to exist with respect to such security.

Increasing the amount of portfolio assets invested in unrated or lower-grade securities, while intended to increase the yield produced by those assets, will also increase the credit risk to which those assets are subject. Market Risk All accounts are affected by changes in the economy and swings in investment markets. These can occur within or outside the U.S. or worldwide, and may affect only particular companies or industries. Call Risk The risk that an issuer will exercise its right to pay principal on an obligation held by an account (such as an assetbacked security) earlier than expected. This may happen when there is a decline in interest rates. Under these circumstances, an account may be unable to recoup all of its initial investment and will also suffer from having to reinvest in lower yielding securities. When-Issued and Delayed Delivery Transactions The Firm, on behalf of the accounts it manages, may purchase short-term obligations on a when-issued or delayed delivery basis. These transactions are arrangements in which the portfolios purchase securities with payment and delivery scheduled for a future time. The seller’s failure to complete these transactions may cause the accounts to miss a price or yield considered advantageous. Settlement dates may be a month or more after entering into these transactions and the market values of the securities purchased may vary from the purchase prices. The accounts may dispose of a commitment prior to settlement if the Firm deems it appropriate to do so. In addition, each account may enter into transactions to sell its purchase commitments to third parties at current market values and simultaneously acquire other commitments to purchase similar securities at later dates. An account may realize short-term profits or losses upon the sale of such commitments. These transactions are made to secure what is considered to be an advantageous price or yield for an account. No fees or other expenses, other than normal transaction costs, are incurred. However, liquid assets of the account sufficient to make payment for the securities to be purchased are segregated on the account’s records at the trade date. These assets are marked to market daily and are maintained until the transaction is settled. Digital Currencies / Cryptocurrencies The Firm, on behalf of the accounts it manages, may invest in digital currencies or products that track or otherwise have exposure to digital currencies. The value of a particular digital currency is determined by the supply of and demand for the digital currency in the global market in which it trades, which consists of transactions on electronic exchanges which are not currently regulated by any U.S. regulator. Pricing on electronic digital currency exchanges and other venues can be volatile and can adversely affect the value of the digital currency being transacted. Currently, there is relatively small use of digital currencies in the retail and commercial marketplace in comparison to the relatively large use by speculators, thus contributing to price volatility that could adversely affect a portfolio’s direct or indirect investments in digital currencies. Also, transactions in digital currencies are irrevocable, and stolen or incorrectly transferred digital currencies may be irretrievable. As a result, any incorrectly executed digital currency transactions could adversely affect the value of a portfolio’s direct or indirect investment in such digital currency. To the extent a portfolio has exposure to one or more digital currencies through a fund sponsored or managed by a third-party, it is possible that shares of such third-party fund trade at a premium or discount to its net asset value. In this way, the value of the third-party fund may increase or decrease while the underlying digital currency it is tracking performs differently. Custody Issues Related to Digital Currencies / Cryptocurrencies Cryptocurrencies (also referred to as digital assets) represent a relatively new asset class. As such, the regulatory landscape continues to evolve over time. Moreover, unlike more traditional assets, ownership of cryptocurrencies is evidenced on each cryptocurrencies’ blockchain network. In certain instances, private funds managed by the

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HKAM provides investment advice to a wide variety of clients, including but not limited to pension and profitsharing plans, Taft-Hartley plans, public funds, endowments and foundations, supranational entities, governmentsponsored entities, educational and healthcare facilities and other corporate entities, as well as to high-net-worth clients through model delivery, dual-contract, and wrap fee programs. In addition, HKAM provides investment advisory services to the following types of clients: 1.

Kinetics Mutual Funds, Inc. a series of U.S. open-end investment companies registered under the Investment Company Act;

2.

U.S. open-end investment companies registered under the Investment Company Act where the Firm serves as sub-adviser;

3.

U.S. exchange traded funds registered under the Investment Company Act;

4.

A U.S. closed-end investment company registered under the Investment Company Act;

5.

A European UCIT, listed on the Euronext Amsterdam Stock Exchange and Euronext Dublin Stock Exchange;

6.

Institutional and retail separate accounts, which are offered directly by the Firm, through third party financial intermediaries, and through model delivery platforms; and

7.

Private investment funds that are appropriate for institutional and high net worth investors.

Investors in these products are required to adhere to the criteria established in the applicable Offering Documents, prospectus, or similar offering document or investment management agreement for purposes of maintaining an account with the Firm. Minimum Investment Amounts Kinetics Mutual Funds, Inc. KMF is set up in a master/feeder structure, except for one fund that is not part of the master/feeder structure. Kinetics Portfolio Trust, a statutory trust organized pursuant to a Declaration of Trust under the laws of the State of Delaware, was established in 2000 and is comprised of a series of mutual funds, certain of which are nondiversified, and others of which are diversified. KMF is a Maryland corporation established in 1999 that is comprised of open-end management investment companies. Each fund is a feeder fund that invests all of its investable assets in a corresponding “master” portfolio. The minimum investment for all but the institutional classes of KMF is $2,500. Institutional class minimums are $1,000,000. Minimums may be waived under certain circumstances as outlined in the prospectus. The Renn Fund, Inc. The Renn Fund trades on the New York Stock Exchange and as such there is no minimum investment amount attributable to the fund. Exchange Traded Funds There is no minimum investment amount for the ETFs.

Separately Managed Accounts The minimum account size for an SMA is generally $500,000; however, the Firm may allow a lesser amount in its sole discretion. Notwithstanding the minimum account sizes referenced under Item 5 (Fees and Compensation), the requirements for opening and maintaining a separate accounts varies based on the account’s applicable investment management agreement. All such minimum investment size requirements listed herein vary and may be negotiated on a case-by-case basis. Private Funds Investors in the private funds are required to adhere to the criteria established in each private funds’ Offering Documents. The minimum investment for the private funds varies whereby most funds require an investment of greater than $250,000; however, for certain funds, the investment minimum is $25,000. Regardless of the stated minimum, the Firm has the right to allow a lesser amount.

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The Firm generally charges its clients a management fee and certain clients may also pay the Firm a performance fee, with the exception of certain owners and employees of the Firm, as described in Item 5 of this Brochure. Performance-based or incentive fee arrangements may create an incentive for HKAM to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Such fee arrangements may also create an incentive to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. The Firm employs strict compliance policies designed to ensure that all accounts are treated fairly, that no account is favored over another, and to prevent the differentials in fee structure from influencing the allocation of investment opportunities among clients. To mitigate such conflicts of interest or potential conflicts of interest, the Firm has adopted policies and procedures, including, among others, a Code of Ethics (the “Code”) and a Trade Aggregation and Allocation Policy (the “Trade Policy”), further described in this Brochure under Item 12 (Brokerage Practices). The Firm’s Chief Compliance Officer (“CCO”) is responsible for implementing the Firm’s compliance program, the policies and procedures of which are reasonably designed to monitor, detect and prevent conflicts of interest. The CCO, or his designee, reviews trade allocations on a periodic basis to ensure adherence to the Firm’s Trade Policy (further described under Item 12 of this Brochure). Only certain sophisticated clients that meet minimum net worth and financial standards are permitted to invest in products that charge performance fees. Performance fee products may also employ more complex investment strategies that are not appropriate for all investors.

Broker-Dealer Registration Status Certain persons of the Firm are registered with FINRA through the Firm’s affiliated broker-dealers, KBD and KFD. KBD and KFD are broker-dealers registered with the SEC and are members of FINRA and are wholly owned subsidiaries of HKHC. The broker-dealers do not accept client money, maintain custody of client assets, execute trades, provide clearing services or engage in proprietary trading. KBD serves to support the promotion and sales by wholesalers of the investment products managed by the Firm. KFD serves as the principal underwriter and distributor to KMF. KFD is also classified as the broker of record for investors that subscribe to KMF directly and do not invest through a financial intermediary. As such, KFD may receive sales charges, distribution fees, service fees and other types of payments from KMFs, as may be applicable based on the terms of KMF’s prospectuses. Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Adviser Registration Status Neither HKAM nor any of its management persons are registered as a futures commission merchant commodity pool operator, or commodity trading adviser. Material Advisory Relationships The Firm and the Firm’s management persons have relationships or arrangements that may be material to the Firm’s advisory business or to investors in the products managed by the Firm. This includes relationships with brokerdealers, investment advisers, pooled investment vehicles, and investment companies. Specifically, the Firm or its management persons have relationships with the following entities: •

Horizon Kinetics Holding Corporation (OTC: HKHC) is a publicly traded company and the parent company to HKAM.

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Horizon Kinetics LLC (“HK”) is a parent company to HKAM and a wholly owned subsidiary of HKHC.

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Kinetics Funds Distributor LLC (“KFD”), and a wholly owned subsidiary of HKHC and an affiliated SECregistered broker-dealer and member of FINRA that serves as the principal underwriter and distributor for KMF.

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KBD Securities, LLC (“KBD”), and a wholly owned subsidiary of HKHC and an affiliated SEC-registered broker-dealer and member of FINRA that serves to support the promotion and sales by wholesalers of the investment products managed by the Firm, which include KMFs, separately managed accounts, and private funds.

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Kinetics Mutual Funds, Inc. (“KMF”), a series of U.S. investment companies registered with the SEC that are managed by the Firm.

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The Renn Fund, Inc., a closed-end investment company registered with the SEC that is managed by the Firm.

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Exchange Traded Funds, including the Horizon Kinetics Inflation Beneficiaries ETF, Horizon Kinetics Blockchain Development ETF, Horizon Kinetics Energy and Remediation ETF, Horizon Kinetics Medical ETF, Horizon Kinetics SPAC Active ETF, Horizon Kinetics Japan Owner Operator ETF, and Horizon Kinetics Texas ETF, are managed by the Firm and are part of a multiple series trust overseen and administered by US Bancorp Fund Services LLC, a subsidiary of U.S Bank, N.A..

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A European UCIT fund that is managed by HKAM and listed on the Euronext Amsterdam Stock Exchange and Euronext Dublin Stock Exchange.

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Ryan Heritage, LLP is a registered investment adviser that is sub-advisor to the Horizon Kinetics SPAC Active ETF, an exchange traded fund that is managed by the Firm.

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MSRH, LLC, an affiliated exempt reporting adviser that is managed by individuals employed by the Firm, serves as investment manager and general partner for two U.S. private funds.

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FRMO Corp., a publicly-traded corporation that is partially owned and controlled by certain management persons of HKHC and which generates revenue from a percentage of earnings from the Firm. FRMO is also a minority shareholder of HKHC. FRMO is treated as an “Access Person” under the Firm’s Code of Ethics (the “Code”), such that it is subject to the terms of the Code, which include, but not limited to restrictions on trading.

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Certain executives of the Firm are senior executives and Board Members of Winland Holdings Corporation (“WELX”), a publicly traded company.

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Consensus Mining and Seigniorage Corporation (“CMSG”) is a cryptocurrency mining company created with strategic partnerships in hosting, repair and management that enable it to operate with minimal overhead and a conservative capital structure that allows for flexible and patient capital allocation. HKHC, through a contractual arrangement, provides management services to CMSG. In addition, certain personnel of the Firm are officers and members of the board of CMSG.

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Miami International Holdings, Inc.(“MIAX”) is a publicly traded company and substantial investment in certain client accounts and funds. MIAX is also a large holding in the accounts of employees of the Firm. Mr. Eric Sites, an employee of the Firm, is a member of the Board of Directors of MIAX.

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Texas Pacific Land Corporation (“TPL”) is a publicly traded company and major holding across the Firm, including in the majority of client accounts and funds. TPL is also a large holding in the accounts of employees of the Firm. Peter Doyle, co-founder, Co-Chief Executive Officer and a Senior Portfolio Manager of the Firm, is a member of the Board of Directors of TPL.

Additionally, from time to time, HKAM enters into arrangements with affiliated and unaffiliated third parties, including KBD, who refer business to the Firm. HKAM may pay cash compensation to these third parties, where such compensation is based on a specified percentage of the investment management fees received by HKAM from accounts obtained through the third party. Such third parties generally include marketers, broker-dealers and consultants. Persons who become clients of HKAM through these arrangements do not pay an additional fee because of HKAM’s agreement with the third party. Any such arrangements will comply with Rule 206(4)-3 of the Advisers Act. Material Conflicts of Interest The Firm’s portfolio managers are responsible for managing numerous client accounts and funds (collectively “portfolios”). A portfolio manager may manage a separate account or other pooled investment vehicle that may have a materially higher or lower fee arrangement than another portfolio or that may have a performance fee arrangement. The side-by-side management of these accounts may raise potential conflicts of interest relating to cross trading, the allocation of investment opportunities and the aggregation and allocation of trades. In addition, while portfolio managers generally only manage accounts with similar investment strategies, it is possible that due to varying investment restrictions among accounts and for other reasons certain investments could be made for some accounts and not others or conflicting investment positions could be taken among accounts. The Firm has a fiduciary responsibility to manage all client accounts in a fair and equitable manner. The Firm seeks to provide best execution of all securities transactions and aggregates and then allocates securities to client accounts in a fair and

timely manner. To this end, the Firm has developed compliance policies and procedures that seek to mitigate and manage the potential conflicts of interest that may arise from side-by-side management of accounts, which include its allocation and aggregation policies. The Firm and certain of its management personnel have relationships or arrangements that may be material to the advisory business of the Adviser or to investors in the products and accounts managed by the Firm and that present potential or actual conflicts of interest. Mr. Peter Doyle, a co-founder, Co-Chief Executive Officer, and Senior Portfolio Manager of the Firm, is a member of the Board of Directors of Texas Pacific Land Corporation (“TPL”), a publicly traded company. TPL is a large holding in many portfolios managed by the Firm and is also a large holding in the accounts of employees of the Firm, including that of Mr. Doyle. Mr. Eric Sites, an employee of the Firm, is a member of the Board of Directors of Miami International Holdings, Inc. (“MIAX”). MIAX is a large holding in many of the portfolios managed by the Firm and is also a large holding in the accounts of employees of the Firm. The Firm seeks to address these potential conflicts of interest through the adoption of various policies and procedures, which include both electronic and physical safeguards. As a result of Mr. Doyle being a member of the Board of Directors of TPL he does not have any trading authority over shares of TPL in client accounts or funds. All trading decisions for TPL have been delegated to another member of the portfolio’s investment team. To the extent the Firm’s policies and procedures prevent the Firm from trading in certain securities (e.g., TPL or MIAX stock or the stock of a company that has a material business relationship with TPL or MIAX) for a portfolio during certain periods of time, the portfolio and its performance could be negatively impacted. Furthermore, Firm personnel, including personnel who are or may be involved in the management of the portfolios, have personal investments in TPL and/or MIAX stock or the stock of a company that has a material business relationship with TPL and/or MIAX. These personal investments may also present potential or actual conflicts of interest. The Firm has adopted a Code of Ethics governing the manner in which employees may engage in personal securities transactions. The Code of Ethics requires employees to periodically report their personal holdings and to pre-clear personal securities transactions. The personal holding information and pre-clearance requests are reviewed by the Firm’s compliance personnel. As part of, and only for the duration of Mr. Doyle’s appointment to the Board of Directors of TPL, the Firm entered into a Board Representation Agreement, the details of which might limit its ability to take certain actions with respect to TPL. Those include, among other things, agreeing not to, directly or indirectly, outside of the boardroom (i) disparage TPL or its current or former directors; (ii) nominate any person for election to the company’s board of directors; (iii) participate in a solicitation to elect or remove directors; (iv) initiate a stockholder proposal or other business before a stockholder meeting; (v) participate in a solicitation of proxies relating to a stockholder proposal; or (vi) participate in a “withhold” campaign at a stockholder meeting. Further, the Firm agreed, during the term of Mr. Doyle’s appointment to the Board of Directors of TPL, not to make any proposals outside of the boardroom that (i) change the number or term of directors or fill any vacancies on the board of directors; (ii) change the capitalization, dividend or share repurchase policy of TPL; (iii) change TPL’s business, operations, strategy, management, governance, corporate structure, or other affairs of TPL; (iv) are related to an “extraordinary transaction” as such term is defined in the Board Representations Agreement; (v) cause a class of securities to be delisted on a securities exchange; (vi) case a class of equity securities to become eligible for termination of registration. Nothing in the Board Representation Agreement prohibits the Firm from suggesting or proposing any action whatsoever in any meeting of the Board of Directors or from disclosing the Firm’s vote as stockholders with respect to any stockholder meeting. The Firm is also not a party to any voting agreement relating to TPL, such that may vote proxies relating to TPL in the manner it determines best regardless of whether such voting is consistent or inconsistent with proposals being recommended by the Board of Directors. Because the Firm has discretion over a substantial percentage of the outstanding shares of TPL and MIAX, it may be deemed to be an affiliate of TPL and MIAX. As a result, the Firm might be restricted from selling TPL or MIAX on behalf of client accounts.

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Code of Ethics The Firm has adopted a written Code of Ethics (the “Code”), which adheres to the requirements under Rule 204A1 of the Investment Company Act and which applies to each supervised person (defined in the Code as an “Access Person”) of the Firm. The Code requires that Supervised Persons / Access Persons of the Firm behave with the highest standards of business conduct and that they abide by the provisions of the Advisers Act and other applicable laws and regulations as well as their fiduciary duty to the Firm’s clients. The Code includes provisions relating to the confidentiality of client information, a prohibition on insider trading, disclosure of conflicts or potential conflicts of interest, 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 employees at HKAM must acknowledge the terms of the Code annually and as amended. Sanctions may apply to any employee who breaches the provisions of the Code, including: verbal admonishment, written warning, written memorandum to the employee’s personnel file, fines and/or reversals of the transaction in question with profits donated to charity, partial or full restriction on personal trading for a set period of time, and/or suspension or termination of employment. You may obtain a copy of the Firm’s Code upon request using the contact information on the cover of this Brochure. Access Persons of the Firm are allowed to trade securities, some of which may be purchased in client accounts creating a potential conflict of interest. An Access Person of the Firm that seeks to purchase or sell a security for their personal account, or for an account over which they have investment discretion must obtain pre-clearance from the Firm’s CCO or his designee prior to executing the trade. In general, employees seeking to trade in securities that are being transacted in client accounts are limited in the amount of shares they may trade, based on the Firm’s Code of Ethics. Authorizations by the CCO or his designee remain effective only for the day on which approval was granted. Under the Code, certain types of securities transactions have been designated as exempt from pre-clearance. Employee trading is continually monitored in order to ensure compliance with the Firm’s Code and applicable federal securities laws, as well as to reasonably prevent conflicts of interest between the Firm and its clients. For certain accounts, including but not limited to accounts in where an employee has investment discretion, accounts held in the name of an employee’s spouse, and corporate accounts in which the employee owns greater than 10%, employees must attest to their trading activity quarterly, and, on an annual basis must certify compliance with the Code, disclose any conflicts or potential conflicts, and attest to a list of their personal brokerage accounts and holdings. The Firm also has a written statement of policy and procedures relating to the prevention of misuse of material, non-public information as required by Section 204A of the Adviser’s Act. In addition, the Firm has adopted policies and procedures related to employee trading in the stock of HKHC, the parent company of HKAM. Participation or Interest in Client Transactions If an Access Person (as defined in the Code) acquires material non-public information as a result of a special or confidential relationship with a client or others, the Code requires that he or she shall not communicate the information (other than within the relationship) or otherwise take investment action on the basis of such information. If an Access Person is not in a special or confidential relationship with a client or others, he or she shall not communicate or act on material, non-public information if he or she knows, or should have known, that such information that was disclosed to him or her would result in a breach of duty or misappropriation of information. Any Access Person who receives information that is known or reasonably known to be material, nonpublic information must communicate that information to the Firm’s CCO without otherwise discussing the information with his or her co-workers. The Access Person is then required to refrain from trading on the information or from discussing the information inside or outside the Firm until the CCO decides the information either is not material or has been made public. As noted under Item 10 of this Brochure - Other Financial Industry Activities and Affiliations – Messrs. Doyle and Sites are members of the Boards of Directors of TPL and MIAX, respectively. To address the potential misuse

of material non-public information (“MNPI”) resulting from a portfolio manager (“PM”) joining the board of directors (“Board”) of a publicly traded company, the Firm has adopted a series of physical and electronic controls. Mr. Doyle is prohibited from exercising investment discretion in client accounts with respect to the securities of TPL and Mr. Sites is prohibited from exercising investment discretion in client accounts with respect to the securities of MIAX. In each instance, another member of the investment team has been delegated trading authority for such securities. As it relates to personal trading, all trades by Messrs. Doyle and Sites as it relates to TPL and MIAX, respectively, will be made either pursuant to a Rule 10b5-1 Plan, adopted and approved by the company, or will be made during an “open window” pursuant to the policies adopted by the company. In addition, consistent with the Firm’s Code, all personal trading must also be submitted and pre-cleared by the Legal and Compliance Department. Moreover, the Firm prohibits Messrs. Doyle and Sites from working in open areas in close proximity to other employees and segregates its electronic filing system folders by designating access only to those who require such access. Documents containing MNPI are maintained in specific electronic folders only accessible by the Legal and Compliance Department or other individuals they approve of in writing. Members of the Legal and Compliance Department also review a portion of all incoming and outgoing emails, including those containing certain key words intended to identify the disclosure of MNPI. Additionally, each Messrs. Doyle and Sites are provided with periodic training specific to identifying and preventing the disclosure of MNPI, and they complete attestations relating to the same. The Legal and Compliance Department also reviews the Firm’s daily trade blotter, which shows all trading across the Firm, to ensure no unusual trading activity has occurred. The foregoing policies and procedures are designed to supplement the existing controls the Firm already employs to identify, detect and prevent any instances of misuse of MNPI, which includes, among other things (i) annual compliance, cybersecurity and information security training; (ii) periodic confirmation of receipt and adherence to the Firm’s Code; (iii) annual questionnaires relating to conflicts of interest and bad actor attestations; (iv) disclosure and approval of gifts and entertainment; (v) pre-clearance of all personal trading; (vi) disclosure and approval of outside business activity; and (vii) review of all client trading through the Firm’s pre- and post-trade portfolio compliance system. HKAM anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it may cause accounts managed by HKAM, and/or may recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which HKAM, its affiliates and/or clients, directly or indirectly, have a position of interest. Additionally, officers, directors and employees of HKAM may trade for their own accounts in securities which are recommended to and/or purchased for HKAM’s clients. HKAM’s Code is designed to assure that the personal securities transactions, activities and interests of the employees of HKHC will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. In instances where a portfolio manager of the Firm is a member of the Board of Directors of a public company, the Firm has enacted policies and procedures to prevent trading on non-public information, which include, but is not limited to, requiring another portfolio manager to make trading decisions in the subject company’s securities. The Firm’s CCO has the general duty of administration and implementation of the Firm’s Code. The CCO is responsible for the maintenance of records relating to the Firm’s Code and shall maintain records of employee transactions to facilitate comparison between such records and records of the Firm’s client transactions as are necessary to determine whether there may have been conflicting transactions. HKAM’s clients or prospective clients may request a copy of the Firm's Code of Ethics by contacting HKAM’s CCO using the contact information located on the cover page of this Brochure.

Brokerage Discretion The brokerage for separate account clients can be either “directed” or “free to trade” depending on the manner in which the account is established and the parameters, if any, of the financial intermediary responsible for establishing the account (e.g., a platform sponsor). “Directed” brokerage refers to the practice whereby clients instruct HKAM to execute through specific broker-dealers. An account is “free to trade” when HKAM has discretion as to the broker-dealer through which to execute transactions. Unless otherwise specifically indicated, HKAM regards accounts as having “directed” brokerage such that the Firm will only execute trades through the custodian for the account. In certain instances, the Firm may be required to “trade away” and execute directed trades through the non-account custodian if the custodian is unable to process trades in a particular security. When this occurs, the Firm memorializes details related to the transaction, including the reason for transacting away. Brokerage transactions for separate accounts established through an intermediary with bundled (or wrap) fee arrangements generally are “directed” to the program sponsor. This is due to the all-inclusive fee structure of the product. Accordingly, HKAM’s brokerage discretion is limited; trades executed with the program sponsor include such commissions in the Client’s bundled fee arrangement with that sponsor. HKAM may trade away from the program sponsor when the sponsor does not have the capability to effect transactions in a particular security or when otherwise consistent with best execution. Commissions and other expenses incurred in connection with any transactions executed away from the program sponsor are paid by the client. However, these costs are always considered in the determination to trade away from the program sponsor, and HKAM will negotiate commissions to effect these transactions taking into account its duty to achieve best execution for its clients. Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions For separate accounts established directly with the Firm, HKAM generally retains brokerage discretion. It is both the policy and fiduciary duty of the Firm to seek best execution with respect to each transaction, other than directed brokerage arrangements, defined as those in which a client directs the Firm to utilize a specific broker. In purchasing and selling portfolio securities for discretionary client accounts, the Firm will seek to obtain execution at the most favorable net prices (on an overall basis) through its list of approved brokers and dealers. The Firm may aggregate purchase or sale orders for clients, as the Firm may be able to obtain lower commission costs on a per-share and per-dollar basis, because large orders tend to have lower execution costs. In general, the Firm will allocate securities under aggregate orders on a pro-rata basis at the average execution price, unless the Firm determines that a different method of allocation, whether by reason of average price considerations, similar securities in the same amounts, available capital, or other factors, suggest a more equitable method of allocation. Cost is only one factor in assessing best execution. The Firm also looks at the size and difficulty of the order, the reliability, integrity, financial condition and general execution and operational capabilities of the broker/dealer, the broker-dealers’ expertise in particular markets, as well as other matters relevant to the selection of a broker or dealer for a client account. Accordingly, transactions may not always be executed at the lowest available price or commission. On a quarterly basis, HKAM’s Brokerage and Pricing Committee (the “Brokerage Committee”) evaluates, among other things, the performance of the executing brokerage firms, with the assistance of third-party execution evaluation firms for best execution. Directed Brokerage Although the Firm does not recommend, request, or require clients to engage in directed brokerage transactions, some clients may request or require that HKAM direct brokerage to particular broker-dealers. Clients that request or require directed brokerage arrangements are encouraged to make such designations subject to the principles of best execution. Commissions and other expenses incurred in connection with any transactions executed away from the program sponsor are paid by the client. These arrangements differ from those in which trades are “directed” to the program sponsor. Specifying or restricting broker-dealers may be inconsistent with obtaining best overall execution for a client transaction. Clients are further advised that such directed brokerage transactions may not necessarily result in the best execution possible and may incur higher brokerage costs. Where a client directs or restricts the use of a

particular broker-dealer, or broker-dealers, HKAM may not be in a position where it can negotiate commissions or obtain volume discounts, and, therefore, the best price may not be achieved, and/or such transactions may result in higher commission costs to the client, which may negatively affect that client’s account performance. In addition, clients who direct HKAM to use a particular broker-dealer or restrict HKAM from using a particular broker-dealer may be prevented from participating in allocations of certain limited-availability securities. Moreover, if a request for a directed brokerage transaction is made with respect to an account subject to ERISA, ERISA requirements must be met in order for the Firm to accept such direction, including a representation that such directed brokerage transaction is in the sole interest and benefit of the ERISA plan itself. The Firm’s Brokerage Committee periodically evaluates the execution quality and commission rates, among other factors, for each broker and dealer utilized by the Firm. The Brokerage Committee also utilizes reports by independent vendors, which compares the Firm’s trading to that of its peers. Research and Other Soft Dollar Benefits HKAM does not engage in soft-dollar arrangements. Brokerage for Client Referrals The Firm does not select or recommend brokers based on referrals of clients from such broker-dealers or other third parties associated with the broker-dealer. Agency Cross Transactions The Firm may engage in agency cross transactions whereby a security is sold from one account advised by HKAM and bought for another account managed by the Firm. This may be done, for example, to prevent potential harm that may result in selling a potentially illiquid security into a disorderly market. HKAM will effect such transactions only when it deems such transaction to be in the best interests of both client accounts, in accordance with applicable laws (including Section 206 of the Advisers Act and Rule 17a-7 under the Investment Company Act), and consistent with policies and procedures adopted by HKAM or its clients, including mutual funds and private funds, advised or sub-advised by HKAM. Principal Transactions To the extent the Firm engages in principal transactions, it will do so in accordance with Section 206(3) of the Advisers Act. Order Aggregation; Trade Allocation HKAM’s Trade Policy outlines, among other things, when and if an order is aggregated across custodian relationships and how partially filled orders are allocated. HKAM will generally allocate partially filled orders on a pro-rata basis at the average execution price, unless HKAM determines that a different method of allocation is more appropriate, whether by, among other things, reason of average pricing considerations, similar securities in the same accounts, available capital, estimated cost to clients, or liquidity. HKAM utilizes a trade rotation methodology for sequencing the execution of trades for a given security that will occur across multiple custodians/brokers. Investment company and private funds, along with custom, non-directed and institutional accounts will generally be included in this rotation schedule. An automated randomizer function is applied to ensure the objectivity of any such trades and to ensure that all accounts are treated fairly with respect to the allocation of investment opportunities. HKAM, in limited instances, may utilize other methodologies for allocating investment opportunities, provided they ensure fair and equitable treatment over time. HKAM’s trade rotation may have the effect of producing a variance in the execution prices of the same security on the same day. Additionally, certain portfolio managers manage performance fee accounts alongside accounts that do not pay a performance fee. Since there are different fee structures, the potential exists to favor a performance fee account over non-performance fee accounts. However, favoring one Client over another would be inconsistent with HKAM’s fiduciary duty to its clients. Accordingly, HKAM’s Trade Policy is designed to ensure that no client is favored over another.

Conflicts of Interest Created by Contemporaneous Trading At times, HKAM recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that the Firm buys or sells the same securities for itself or for an account related to the Firm. HKAM recognizes this potential conflict or appearance thereof and has instituted policies and procedures to mitigate such conflicts. There is an inherent conflict of interest between our fiduciary duty of best execution for our clients and the apparent self-interest of trading in the same securities in employee accounts and/or HKAM’s proprietary trading accounts. HKAM’s Code and Trade Policy is designed to detect and prevent such conflicts. Reference is also made to the description of controls under Item 11 of this Brochure - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.

From time to time, HKAM enters into written arrangements with unaffiliated third parties and affiliated entities (“Solicitors”) for their assistance in referring business to the Firm. HKAM may pay cash compensation to such Solicitors in accordance with Rule 206(4)-3 of the Advisers Act. Such compensation varies but may be equal to a specified percentage of the investment management fees received by HKAM from clients obtained through the Solicitor or may be a fixed fee. Such Solicitors generally include marketers, broker-dealers and consultants. Persons who become clients of HKAM through these arrangements do not pay an additional fee because of HKAM’s agreement with the Solicitor; all fees are paid directly by HKAM and the arrangements comply with Rule 206(4)-3 of the Advisers Act. Further, investors in the funds managed by HKAM may be employed by unaffiliated broker-dealers that execute the funds’ trades and may shares in commissions in that capacity. Participation in Fidelity Wealth Advisor Solutions®. HKAM participates in certain investment programs, including but not limited to, the Fidelity Wealth Advisor Solutions® program (the “WAS Program”), through which HKAM receives referrals from Fidelity Personal and Workplace Advisors LLC (“FPWA”), a registered investment adviser and Fidelity Investments company. HKAM is independent and not affiliated with FPWA or any Fidelity Investments company. FPWA does not supervise or control HKAM, and FPWA has no responsibility or oversight for HKAM’s provision of investment management or other advisory services. Under the WAS Program, FPWA acts as solicitor for HKAM, and HKAM pays referral fees to FPWA for each referral received based on HKAM’s assets under management attributable to each client referred by FPWA or members of each client’s household. The WAS Program is designed to help investors find an independent investment adviser, and any referral from FPWA to HKAM does not constitute a recommendation or endorsements by FPWA of HKAM’s particular investment management services or strategies. Specifically, HKAM pays the following amounts to FPWA for referrals: for referrals made prior to April 1, 2017, an annual percentage of 0.20% of any and all assets in client accounts; for referrals made after April 1, 2017, the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identified as “fixed income” assets by FPWA and (ii) an annual percentage of 0.25% of all other assets held in client accounts. For referrals made prior to April 1, 2017, these fees are payable for a maximum of seven years. Fees with respect to referrals made after that date are not subject to the seven-year limitation. In addition, HKAM has agreed to pay FPWA a minimum annual fee amount in connection with its participation in the WAS Program. These referral fees are paid by HKAM and not the client. To receive referrals from the WAS Program, HKAM must meet certain minimum participation criteria, but HKAM may have been selected for participation in the WAS Program as a result of its other business relationships with FPWA and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its participation in the WAS Program, HKAM may have a potential conflict of interest with respect to its decision to use certain affiliates of FPWA, including FBS, for execution, custody and clearing for client accounts, and HKAM may have a potential incentive to suggest the use of FBS and its affiliates to its advisory clients, whether or not those clients were referred to HKAM as part of the WAS Program. Under an agreement with FPWA, HKAM has agreed that it will not charge clients more than the standard range of advisory fees disclosed in this Form ADV Part 2A Brochure to cover solicitation fees paid to FPWA as part of the WAS Program. Pursuant to these arrangements, HKAM has agreed not to solicit clients to transfer their brokerage accounts from affiliates of FPWA or establish brokerage accounts at other custodians for referred clients other than when HKAM’s fiduciary duties would so require, and HKAM has agreed to pay FPWA a one-time fee equal to 0.75% of the assets in a client account that is transferred from FPWA’s affiliates to another custodian; therefore, HKAM may have an incentive to suggest that referred clients and their household members maintain custody of their accounts with affiliates of FPWA. However, participation in the WAS Program does not limit HKAM’s duty to select brokers on the basis of best execution.

There are no legal or disciplinary events to report.

The Firm provides investment services that it believes are considered prudent and appropriate based on the nature of the accounts and the Firm’s understanding of the client’s written investment strategy and criteria. Client accounts are reviewed periodically, taking into account relevant fundamental data pertaining to each of the holdings, as well as the appropriateness of the current asset allocation. Company events, such as earnings reports, management changes, or other important corporate announcements, may trigger a review of a particular holding. Exogenous events, such as fund liquidations or subscriptions and a change in market conditions may also prompt an account review. Such reviews will be conducted, either jointly or individually, by the portfolio manager(s) and may be performed daily, weekly, or monthly as portfolio managers deem appropriate or as otherwise required. All reviews will be governed by normal professional standards with regard to security selection and asset allocation, with particular emphasis upon the stated goals and objectives in each of the accounts’ Prospectus, SAI, offering memorandum or investment advisory agreement, as applicable. Client Reporting The Firm does not send statements to investors. That function is fulfilled by the custodian or brokerage firm selected by the client, or in the case of the private funds managed by the Firm, the fund’s administrator. Model delivery and wrap account clients receive statements directly from the sponsor of the program. The Firm makes available, through its website (www.horizonkinetics.com and www.kineticsfundscom) monthly and/or quarterly newsletters containing commentaries from the Firm’s investment team as well as important information about the Firm and its strategies and/or products. Recipients may request to discontinue receiving such information at any time. The Firm may also send investors performance reports from internal systems, proprietary reports or other presentations, upon request.

The Firm does not hold client cash or securities; however, regulators may deem the Firm to have custody of client assets by virtue of, among other things, its (or its affiliates’) ability to direct the transfer of assets in the private funds. The cash and securities of the private funds are held in custody at a qualified custodian, and clients are sent account statements directly from such custodian on a quarterly or more frequent basis. Certain other (nonsecurities) assets of the private funds may be maintained in safe deposit boxes with a qualified custodian. Clients are urged to carefully read such account statements. To the extent the Firm sends account statements to Clients, Clients are urged to compare such account statements from the custodian to the statements they may receive from the Firm. The Firm’s clients are responsible for determining and maintaining custody arrangements for their accounts.

HKAM generally manages accounts on a discretionary basis (e.g., without client consultation regarding the securities that are bought/sold for the account and the quantity of securities to be bought and sold). In certain instances, clients may seek to limit HKAM’s discretionary authority in making these determinations by imposing investment guidelines, investment restrictions, or account objectives that may otherwise preclude the account from owning certain securities. HKAM reserves the right to not accept or to cease managing any account whose clientimposed limitations materially impact the ability of the Firm to manage the account. Additionally, HKAM manages a small number of accounts on a non-discretionary basis, whereby the client instructs HKAM as to the securities and quantity of securities to be bought and sold within their account. Prior to accepting authority for the management of client accounts, the Firm requires a written investment advisory agreement between the client and the Firm. A written investment advisory agreement between the client and the Firm is also required for the management of non-discretionary accounts.

HKAM generally is granted the authority to vote proxies. HKAM has adopted and implemented policies and procedures that it believes are reasonably designed to ensure that proxies are voted in the best interest of clients. HKAM’s policy is to vote proxy proposals, amendments, consents or resolutions relating to advisory client securities, including interests in private funds, if any (collectively, "proxies"), in a manner that serves the best interests of the funds and accounts managed by HKAM, as determined in its sole discretion, taking into account that one of the key factors HKAM considers when determining the desirability of investing in a particular company is the quality and depth of its management. With that in mind, HKAM recognizes that a company’s management is entrusted with the day-to-day operations of the company, as well as its long-term direction and strategic planning, subject to the oversight of the company’s board of directors. HKAM has engaged Institutional Shareholder Services (“ISS”), to facilitate the voting of client proxies. Additionally, ISS provides research on proxy proposals and vote recommendations based on written guidelines. HKAM, as a general matter, accepts vote recommendations from ISS, though HKAM retains the right to determine the vote on a particular proxy issue. To the extent ISS has a conflict with respect to a particular proposal it will notify HKAM so that the Firm can independently determine how to vote. There may be instances, including those in which ISS recommends a vote consistent with management, in which HKAM may decide to vote contrary to ISS’ recommendation if it is determined to be in the best interests of the clients. The rationale for any such departure will be memorialized in writing by the CCO or his designee. A copy of HKAM’s Proxy Voting Policy is available upon request. Clients may also contact HKAM to receive more information about how the Firm voted proxies on their behalf. To the extent the Firm does not have authority to vote proxies pertaining to its clients’ accounts. The client will receive proxy proposals directly from their respective custodians.

Balance Sheet The Firm has not attached a balance sheet for its most recent fiscal year because it does not require or solicit prepayment of more than $1,200.00 in fees per client, six months or more in advance. Financial Conditions Likely to Impair Firm’s Operations The Firm is not aware of any financial conditions that are likely to impair its ability to meet its contractual commitments to its clients. Bankruptcy Filings The Firm has not been the subject of any bankruptcy petitions at any time in the past ten years, or prior to that period.