Interval Partners, LP

A. General Description of Advisory Firm Interval Partners, LP (“Interval”, “we”, “our” or “us”) is a Delaware limited partnership with its principal place of business in New York, NY. Interval is principally owned by Gregg Moskowitz, Raymond Fernandez, Anil Stevens, Elise Di Vincenzo Crumbine, and Edward Gilliss. Interval Partners (GP), LLC is the general partner of Interval Partners, LP and is principally owned by Gregg Moskowitz, Raymond Fernandez, Anil Stevens, Elise Di Vincenzo Crumbine, and Edward Gilliss. Interval is registered with the SEC as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”).

B. Description of Advisory Services Interval provides investment advice on a discretionary basis. Interval and its affiliates serve as the management companies and general partners for pooled investment vehicles (the “Funds”), and also manage, as a sub-advisor, investment accounts of other private funds, which are referred to as “separately managed accounts” (and, together with the Funds, are referred to herein as “Client” or “Clients”). We generally invest and trade on behalf of our Clients in a wide variety of securities and financial instruments, domestic and foreign, of all kinds and descriptions, whether publicly traded or privately placed. Interval encourages each Fund investor, and prospective investor to review the offering materials of the Fund(s), which identify certain conflicts of interest and specific risks. Offering materials are provided to Fund investors and qualified prospective investors in conjunction with an investment or offer to invest in a Fund. C. Availability of Customized Services for Individual Clients Interval generally permits separately managed accounts to impose restrictions on their accounts with respect to: (1) the specific types of investments or asset classes that will or will not be permitted in their account; (2) the nature of the issuers of investments that we will or will not purchase for their account (e.g. specific industries, sectors); (3) the risk profile of the account as a whole; or (4) other investment restrictions deemed appropriate for the accounts. Where Interval serves as the investment adviser to a Fund, investment objectives, and any investment restrictions are described in the relevant offering materials for the Fund. D. Wrap Fee Programs Interval currently does not participate in wrap fee programs. E. Regulatory Assets Under Management As of December 31, 2025, we managed approximately $9,392,255,002 of regulatory assets under management on a discretionary basis. Currently, we do not manage any assets on a non-discretionary basis.

Our fees and compensation are described in the governing documents (e.g., offering memorandum, investment management agreements, limited partnership agreements) of each Client. Investors in our

pooled investment vehicles are “qualified purchasers” (as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “1940 Act”). With respect to certain Funds that we manage, management fees are generally calculated based on the net asset value before incentive allocation of the Client’s account quarterly in advance, and such fees are generally deducted by us from such accounts. If a new Client account is established during a quarter or a Client makes an addition to its account during a quarter, the investment management fee will be charged as of the effective date of the contribution based on the value of the assets as of the applicable date and will be prorated for the number of months remaining in the quarter. Management fees may be waived, reduced or discounted in our discretion with respect to one or more investors without consent of the other investors. Generally, management fees are not refundable. The calculation and payment of management fees for other private investment funds which are separately managed accounts that we manage are governed by the investment management agreements with the owners of such accounts. Depending on the arrangement with the separately managed account Client, we may send a calculation to the Client with the projected management fees for the Client’s approval, or the Client (e.g. Client’s custodian or administrator) calculates the management fees, which we then confirm. Such fees are approved and paid by the owners of the applicable accounts. With respect to certain Funds that we manage, performance-based allocations are generally based on a percentage of the capital appreciation of Client assets and upon withdrawals/redemptions by investors and such fees are generally deducted from such accounts. Performance-based fees may be waived, reduced or discounted in our discretion with respect to one or more investors without consent of the other investors. The calculation and payment of performance fees for other private investment funds, which are separately managed accounts that we manage, are governed by the investment management agreements with the owners of such accounts. Depending on the arrangement with the Client, either we send a calculation to the Client with the projected performance fees for the Client’s approval or the Client (e.g. Client’s custodian or administrator) calculates the performance fees, which we then confirm. Such fees are approved and paid by the owners of the applicable accounts. Clients that are private investment funds, which are pooled investment vehicles that we manage, generally bear their operating and other expenses, including, but not limited to, management fees; fees of their administrators; director’s fees and fees payable to the members of any applicable advisory committee; investment expenses (e.g., expenses which we reasonably determine to be related to the investment of the private investment fund’s assets, including, without limitation, brokerage commissions, expenses relating to short sales, clearing and settlement charges, custodial fees, bank service fees and interest expense and the cost of investigating actual or potential investments); the cost (including, but not limited to, any related consulting, hardware and maintenance expenses) of: trade execution and management systems, compliance, risk and portfolio systems and reports, integration and data transfer connectivity costs to and from third party systems, products and services relating to research concerning the private investment fund’s investments or potential investments; including, without limitation, the following: (a) professional fees (including, without limitation, advisory fees) relating to investments, (b) the costs of obtaining thirdparty research products and services (including, without limitation, the cost of research reports relating to securities, issuers, market segments or geographic regions, the costs of portfolio modeling and analyses, the costs of computerized financial databases (e.g., Bloomberg), pricing and quotation services), and (c) the costs of subscriptions or publications regarding investments; expenses related to registration and compliance obligations (including filings) by Interval as required by regulatory authorities; legal expenses; accounting expenses; auditing and tax preparation expenses; directors and officers insurance for Interval;

organizational expenses and expenses relating to the initial offer and sale of the interests in private investment fund; other similar expenses related to the private investment funds; and extraordinary expenses. In certain circumstances, some of the expenses borne by a Client account may also benefit other accounts managed by us. However, in such circumstances, the Client account bearing such expenses will not incur any additional expenses in excess of the expenses that it would have otherwise paid if the Investment Manager did not manage such other accounts. (See Item 12 “Brokerage Practices” below.) Interval encourages Clients, and prospective Clients to review the applicable Private Offering Memorandum (including, without limitation, the “Risk Factors” section), as applicable, for additional disclosure regarding the fees and expenses, rights of withdrawal or other matters pertaining to the Funds. The fees that are charged to separately managed accounts are determined on a case-by-case basis and are governed by the investment management agreement with the owners of such accounts. Interval may invest a portion of certain Clients’ capital in money market funds and/or exchange-traded-funds or private investment funds and accounts. In addition to the fees and expenses discussed above, investors will indirectly incur similar fees and expenses for investments in such money market funds, exchange-tradedfunds or other private investment funds and accounts, as these funds and accounts in turn pay similar fees to their investment managers and other service providers. To the extent we allocate Client assets to a private investment fund that we or our affiliates manage, such Clients will not be charged any management fees or performance-based fees or allocations from such private investment funds.

Summaries of investment objectives, principal investment strategies, and material risks provided below are necessarily limited, and are presented for general information purposes in accordance with regulatory requirements. Consequently, these summaries are in all instances qualified and superseded by the descriptions of objectives, strategies and risks, portfolio reports, and other communications that are provided to each Client in connection with the creation and maintenance of the Client’s own account. Methods of Analysis and Investment Strategies Generally Our general investment objective is to attain attractive risk-adjusted returns through investments in equity securities and other equity related instruments. We focus primarily on investments in U.S. listed companies; however, we also invest outside of the U.S. The portfolio will include investment opportunities where we feel strongly about a company’s management, service or product cycle, forecasted financial earnings and cash flow, as well as other various factors most of which are described below or in the offering documents. Additionally, our Clients’ portfolios will consist of short positions where we feel consensus financial estimates are unattainable, a price dislocation exists based on an overzealous investor set-up or simply as a hedge against some of our long positions or such other factors we deem important in our discretion. Our investment approach combines a predominantly fundamental research process, along with a keen focus on portfolio management. As part of our fundamental approach to investment selection, we perform a number of tasks that may include the following: Idea Generation:

Identify and prioritize key metrics, trends and inflection points through use of our financial modeling tools.

Monitor earnings releases, company transcripts, 10Ks, 10Qs and other research reports for changes in key financial metrics.

Identify new product cycles or emerging macroeconomic themes and the companies that benefit from them.

Identify margin expansion stories, change in management teams and new market entries.

Closely monitor macro-economic data and industry sector reports to identify potential acceleration or deceleration in demand trends and potential investment themes.

Attend sell-side industry conferences to monitor real-time updates and hear the longer-term investment case.

Gauge overreaction caused by disappointing performance or from investor set-up that could create attractive entry points.

Rigorous evaluation of company and industry metrics to identify and prioritize trends and inflection points through use of our proprietary financial models.

Research Process:

Forecast future earnings potential with financial modeling tools and proprietary earnings models

Read company earnings transcripts and investment presentations

Learn the set-up: read sell-side research and speak to sell-side analysts to investigate both the bull and bear case

Prepare financial models based on internal assumptions and test them against sell-side models to determine extent of variant view on earnings power

Monitor macro-economic developments that could change the thesis

Monitor peer company results that could signal change in trend for the investment idea or could impact stock price of our investment

Monitor trends of companies through analysis of monthly and quarterly financial statements, regulatory reports, conference presentations, and company interactions

Compare internal research versus various sell-side assumptions, projections and other research data

Continuously challenge the thesis and search for weaknesses

Investment Selection:

Conclude there is a variant view and a reasonable time frame for realization

Entry point and sizing of position are based on some of the following: identifying whether investments are short-term or long-term, conviction level, timing of catalyst, technical analysis, macro backdrop, liquidity, street sentiment, upside/downside to price target and degree of potential upside within the context of downside risk and volatility

Continue to conduct rigorous research on an active investment

In addition to an extensive research process, this approach is married with other factors such as the technical make-up of the related security, composition of the current portfolio and the investment team’s overall view of the market prior to making an investment decision. We perform daily monitoring of liquidity, sector exposures, and position sizes along with other risk management tools. Investment information and market conditions change daily requiring constant monitoring of Client portfolios. We do not intend to invest in companies for the purpose of exercising management or control. As a general matter, we may invest in the securities of non-U.S. companies, including non-U.S. securities, and foreign currencies, both in connection with the purchase or sale of non-U.S. securities and as a hedge against the currency risk associated with such non-U.S. securities investments. We may also invest in private placements of unregistered securities, including, but not limited to, private investments in public equities or “PIPEs.” We utilize leverage in our Clients’ portfolios to take advantage of market opportunities. The use of leverage enables us to increase our buying power. Depending on the investment strategy, significant leverage could be utilized. Investors and potential investors should be aware of the risks and expenses in connection with our use of leverage as discussed in governing documents. We may purchase and write options on stocks, other securities held in a Client’s portfolio, currencies or market indices, thereby allowing our Clients to leverage their returns from specific securities. Options may also be used to hedge against, or profit from, sudden fluctuations in markets. At times, we may maintain higher levels of cash and cash equivalents in a Client’s portfolio than necessary to meet short-term cash needs, and we may invest in longer-term debt instruments. We may also invest in domestic government securities, corporate bonds (both investment-grade and high-yield), forward contracts and derivative instruments, including swaps and currency instruments, and exchange-traded-funds. There are no limitations on the types of securities or other instruments in which the Funds may take positions, the types of positions it may take or the concentration of its investments. Investing in securities involves risk of loss that Clients and investors should be prepared to bear. Certain Risks Associated with Methods of Analysis and Investment Strategies The following is a list of certain material risks associated with Interval’s significant methods of analysis and investment strategies. Investors in the private investment funds managed by Interval should refer to the applicable fund’s confidential private offering memorandum for a description of additional risks associated with an investment in such private investment fund. Investment and Trading Risks. All securities investments risk the loss of capital. We believe that our investment programs and research techniques will moderate this risk through a careful selection of securities and other financial instruments. No guarantee or representation is made that our investment programs will be successful or that our Clients will not incur losses. We may utilize investment techniques including, but not limited to, trading in put and call options and other derivatives, the use of leverage, and short sales, which in practice can, in certain circumstances, increase the adverse impact to which a Client account may be subject. In addition, in certain transactions, our Clients may not be “hedged” against market fluctuations or, in reorganization or liquidation situations, may not accurately value the assets of the subject company or the degree of legal and regulatory risk associated with investments in the securities of companies in such situations. This can result in losses, even if the proposed transaction is consummated.

We will attempt to assess the foregoing risk factors, and others, in determining the extent of the position we will take in the relevant securities and the price we are willing to pay for such securities. However, such risks cannot be eliminated. Short Sales. A short sale involves the sale of a security that a Client does not own in the expectation of purchasing the same security (or a security exchangeable therefore) at a later date at a lower price. To make delivery to the buyer, we must borrow the security for our Client accounts and such Clients are obligated to return the security to the lender, which is accomplished by a later purchase of the security by such Client accounts. When a Client makes a short sale in the United States, it must leave the proceeds thereof with the broker and it must also deposit with the broker an amount of cash or U.S. government or other securities sufficient under current margin regulations to collateralize its obligation to replace the borrowed securities that have been sold. If short sales are affected on a foreign exchange, such transactions will be governed by local law. A short sale involves the risk of a theoretically unlimited increase in the market price of the security that would result in a theoretically unlimited loss to a Client account. The extent to which we will engage in short sales for our Clients will depend upon our trading strategy and perception of market direction and the value of individual securities. We may engage in short sales on behalf of a Client as a hedge against potential market declines and/or based on its fundamental analysis of the subject issuers. Leverage. Leverage is the use of borrowed funds for investment. Such borrowed funds would generally be obtained by using securities a Client owns as collateral. Leverage may also be obtained through other means including the use of derivative instruments. To the extent we purchase securities with borrowed funds for a Client account, such account’s net assets will tend to increase or decrease at a greater rate than if borrowed funds are not used. If the interest expense on borrowings were to exceed the net return on the portfolio securities purchased with borrowed funds, the use of leverage would result in a lower rate of return than if the account were not leveraged. If the amount of borrowings which a Client account may have outstanding at any one time is large in relation to its capital, fluctuations in the market value of such account’s portfolio will have a disproportionately large effect in relation to its capital and the possibilities for profit and the risk of loss will therefore be increased. Any investment gains made with the additional monies borrowed will generally cause the value of a Client’s assets to rise more rapidly than would otherwise be the case. Conversely, if the investment performance of the additional monies fails to cover their cost, the value of the Client’s assets will generally decline faster than would otherwise be the case. Depending on the investment strategy, significant leverage could be utilized to take advantage of market opportunities. The amount of any borrowing may also be limited by regulations imposed by the Federal Reserve Board or by the availability and cost of credit. If, due to market fluctuations or other reasons, the value of a Client’s assets should fall below required regulatory levels, we will be required to reduce such Client’s debt by selling securities in its long portfolio. Small and Medium Capitalization Companies. We invest a portion of our Clients’ assets in the securities of companies with small to medium-sized market capitalizations. While we believe such securities often provide significant potential for appreciation, the securities of certain companies, particularly smallercapitalization companies, involve higher risks in some respects than do investments in securities of larger companies. For example, prices of small-capitalization and even medium-capitalization securities are often more volatile than prices of large-capitalization securities and the risk of bankruptcy or insolvency of many smaller companies (with the attendant losses to investors) is higher than for larger, “blue-chip” companies. In addition, due to thin trading in the securities of some small-capitalization companies, an investment in those companies may be illiquid. Investments in Unregistered Securities. We may invest in unregistered securities, including investments in new and early stage companies, or companies undergoing operational or financial restructuring, which may

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As noted in Item 4 above, Interval and its affiliates provide services to private investment vehicles through the Funds and separately managed accounts. Certain Funds require a minimum initial investment, which may generally be waived in our sole discretion. In order to invest in the Funds, an investor must meet additional requirements set by the SEC. These requirements are discussed fully in the Funds offering documents.

Redemption provisions for the advisory contracts generally are as follows: (1) Investors in the Funds typically may request to redeem their investment on either a quarterly basis after providing the requisite advanced notice or on a quarterly basis after providing the requisite advanced notice following the first anniversary of that investment, unless such notice or redemption period is waived in whole or in part by the General Partner in its discretion; and (2) termination provisions for advisory contracts for separately managed accounts will vary based on each Client’s agreement. The beneficial owners of separately managed accounts generally receive additional information (including portfolio composition information) and have more favorable liquidity rights than investors in the Funds or other Client accounts. Fees charged to the separately managed accounts may be more favorable than the fees for comparable Fund investments. The opportunity to open a separately managed account is not available to all prospective clients and is generally subject to minimum asset levels, amongst other factors as determined by Interval.

We are entitled to receive annual performance-based fees or allocations from the private investment funds and separately managed accounts we manage, which are based on a percentage of the capital appreciation of Client assets. The terms of the performance-based fees and allocations may differ among the various private investment funds and the separately managed accounts we manage. This may result in a conflict of interest when we allocate opportunities among these accounts because we will have an incentive to favor accounts that have higher performance-based fees and allocations. To avoid such a conflict of interest, we follow internal procedures in allocating investment opportunities among such accounts, which do not take into account the performance-based fees and allocations to which such accounts are subject (see Item 12 - “Allocation of Investment Opportunities” below). The performance-based fees and allocations we receive may also create an incentive for us to effect transactions in securities that are riskier or more speculative than would be the case in the absence of such performance-based fees and allocations. As the management fees and performance-based fees and allocations are based directly on the net asset value before incentive allocation of the Client accounts, we have a conflict of interest in valuing the assets held in the accounts. We will follow internal valuation policies and consult with the third-party administrator to the accounts in order to mitigate this risk.

Management of Affiliated Investment Funds We manage a number of pooled investment vehicles which are deemed to be our related persons. These vehicles include Interval Fund, L.P., Interval Offshore Fund, Ltd., Interval Master Fund, L.P., Roadmap Fund, LP, Roadmap Master Fund, L.P., Tabata Fund, L.P., Tabata Master Fund, L.P., Stormborn Offshore Fund, Ltd., Stormborn Master Fund, L.P., Recurrent Fund, L.P., and Recurrent Master Fund, L.P. (collectively, the “Affiliated Funds”). The management of multiple pooled investment vehicles may result in conflicts of interests when our related persons and we allocate time and investment opportunities among the Affiliated Funds and other Clients. In addition, the compensation earned by us and our related persons from each of the Affiliated Funds may differ from one another and other Clients. Our related persons and we will generally follow internal procedures in allocating trades among such Affiliated Funds and other Clients (see Item 12 -

“Allocation of Investment Opportunities” below). Subject to applicable law, we may effect transactions (generally for rebalancing purposes and to correct misallocations of trades) among Client accounts (including the Affiliated Funds) in which one Client account will purchase securities from, or sell securities to, another Client account (including Affiliated Funds in which our related persons or we may have a significant interest). This may result in a conflict of interest because a potential transaction may result in benefits to one transacting party that may be greater than the benefits to the other transacting party. In order to mitigate such conflicts, we would effect such transactions only when we believe that such transactions are in the best interests of the applicable Clients. Such transactions shall be effected for cash consideration, generally at the closing price of the particular security, and no brokerage commission or transfer fee shall be paid to us or our related persons in connection with any such transaction. Our principals (and/or other related persons) may have a greater portion of their personal assets invested in certain of the Affiliated Funds than in the others. As a result, we may have a conflict of interest in allocating investment opportunities among the Affiliated Funds and our other Clients. We follow internal procedures in allocating investment opportunities among Affiliated Funds and our other Clients. (See Item 12 “Allocation of Investment Opportunities” below.) Affiliated Management Companies Interval Capital, LLC, a Delaware limited liability company, is principally owned by Gregg Moskowitz and Raymond Fernandez; Interval Capital II, LLC, a Delaware limited liability company, is principally owned by Gregg Moskowitz and Raymond Fernandez; Roadmap Partners, LLC, a Delaware limited liability company, is principally owned by Anil Stevens, Gregg Moskowitz, and Raymond Fernandez; Stormborn Capital (GP), LLC, a Delaware limited liability company, is principally owned by Elise Di Vincenzo Crumbine and Raymond Fernandez; and Recurrent Partners (GP), LLC, a Delaware limited liability company, is principally owned by Edward Gilliss and Raymond Fernandez. These entities each serve as the general partner to one or more of the private investment funds managed by us. There are no material conflicts of interest resulting from the relationship between us and these other investment advisers other than any conflicts described herein. We may also allocate a portion of a Client’s capital to private investment funds and other accounts in which our affiliates and we manage (see Item 5 “Fees and Compensation” above).

Code of Ethics Generally Interval is committed to conducting its business in accordance with all applicable laws and regulations in an ethical and professional manner. We have adopted a Code of Ethics (the “Code”), and each employee is responsible for reading, understanding, and complying with the policies and procedures contained in the Code. In addition, we recognize that we have a fiduciary duty to our Clients and other accounts we manage, and that all of our employees must conduct their business on our behalf in a manner that enables us to fulfill this fiduciary duty. In this regard, we have developed policies and procedures in our Code of Ethics that are premised on fundamental principles of openness, integrity, honesty and trust. In addition, among other things, the Code governs the personal investment transactions by our employees, our policies with respect to gifts and entertainment, compliance with applicable federal securities laws, the manner in which violations of our Code are to be reported, and certain other outside activities of our employees. We will provide a copy of our Code to any Client or prospective client upon request. Participation or Interest in Client Transactions and Transactions between Client Accounts Our principals and other management persons have significant personal investments in these funds. In addition, our affiliates and we receive performance-based fees and allocations from these funds.

Subject to applicable law, we may effect transactions between Client accounts (generally for rebalancing purposes and to correct misallocations of trades) whereby one Client account will purchase securities from or sell securities to another Client account (see Item 10 above). In the event that we effect a cross trade between an account in which we, or our controlling persons, own more than twenty five percent (25%) and another Client account, such transaction may be deemed to be a principal transaction under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Such transactions may create a conflict of interest for us because we may put our, or our control persons’, interests in such accounts before the interests of our Clients in the other account. To mitigate this conflict of interest, we monitor the interests of our principals, their immediate family members and their affiliates in our Client accounts, and we will not affect any cross trades between accounts if we believe that such trade would result in a principal transaction unless: 1) We believe that such transaction is in the best interest of the Clients participating in the transaction; and 2) We obtain the consent of the applicable Clients as required by the Advisers Act. Personal Securities Trading by Interval Personnel Our employees are not permitted to make personal investments without the prior approval of the Chief Compliance Officer or his designee, other than investments in personal and family real estate, money market funds, currency, cryptocurrency (i.e., Bitcoin), municipal, government, or high quality fixed income securities, registered closed-end and open-ended mutual funds, Exchange Traded Funds or any other NonReportable Securities as designated by Interval. An employee must seek written approval from the Chief Compliance Officer if he/she wishes to close out an Exchange Traded Fund position within the restricted holding period of the original execution of the trade. The “Restricted Holding Period” for all Exchange Traded Fund transactions is thirty calendar days. Our employees, principals, and other related persons may buy or sell for their own accounts securities that are also recommended to, or purchased or sold for, Client accounts. This practice may create a conflict of interest. To address this conflict, personal securities transactions are subject to the Firm’s Code of Ethics, including pre-clearance requirements, holding period requirements, and ongoing compliance monitoring. Timing of Transactions for Client Accounts and Affiliated Funds We may buy or sell securities for one Client at the same time that our related persons or we buy or sell the same security for one or more other Clients (including the Affiliated Funds that are our related persons). This will typically happen when more than one Client is capable of purchasing or selling a particular security based on investment objectives, available cash and other factors. This may create a conflict of interest if one account may benefit from making the trade before or after the other account. We will generally aggregate trades, subject to best execution to avoid any such conflict of interest (see Item 12 - “Aggregation of Orders”). Investor Agreements and Affiliated Investors Interval and its affiliates enter into agreements with Clients that allow for different terms of investment in a Fund than the terms applicable to other Fund investors. As a result, certain Fund investors may receive additional benefits that other investors in the same Fund will not receive. In general, Interval will not notify Fund investors when it enters into these agreements. Affiliated investors (e.g. partners, principals, and employees) who invest in the Funds will generally have better terms than other investors will in those Funds. Disclosure of Portfolio and Other Information We will sometimes provide portfolio holding information to entities or third-party service providers that

have been retained by certain Fund investors to evaluate portfolio risk, facilitate the filing of class action claims, or for various other purposes. Interval provides this information in its sole discretion and reserves the right to cease providing information at any time. Interval makes reasonable efforts to preserve the confidentiality of the information it provides, such as by entering into non-disclosure agreements, but Interval cannot ensure that the entities to which it provides information will fulfill their confidentiality obligations. During the due diligence process, Fund investors and prospective Fund investors will request information related to both their investments and Interval and its affiliates. Interval may respond to these requests, and may provide information that is generally not made available to other Fund investors. When Interval provides this information, it will do so without an obligation to inform other Fund investors or to update any such information provided.

Selection of Brokers We have complete discretion to determine, subject to each Client’s disclosed investment objectives, policies and strategies, the securities to be purchased or sold and in what amounts, the broker and other financial intermediaries used in effecting the transactions for our Clients, and the commission rates to be paid for such transactions. We select the brokers and other financial intermediaries used to effect transactions on behalf of our Clients. We are not required to, and currently do not, solicit competitive bids to seek the lowest available commission or transaction cost. In selecting brokers to effect portfolio transactions, we may cause a Client to enter into arrangements pursuant to which the Client pays transaction costs in an amount greater than would be incurred if another broker were used. The transactions executed by a Client may be cleared through, and the Client’s investment instruments may be held by, a number of financial institutions we select on terms negotiated with each such financial institution individually. Subject to our agreement with each Client, we generally use a variety of financial institutions both to take advantage of differing expertise and capabilities and to avoid, due to credit concerns, having all investment instruments concentrated at one firm. We do not consider the receipt of investor referrals when selecting broker-dealers to execute transactions. General Brokerage Practices We seek to place portfolio transactions for Client accounts to broker-dealers on the basis of the best execution Interval believes is available (i.e. execution in a manner that the Client received the most favorable execution services under the circumstances, which may not be the lowest cost option available). We consider a variety of factors in selecting broker-dealers, such as, but not limited to: the ability of the brokers to effect the transactions, the brokers’ facilities, reliability and financial responsibility and the provision or payment (i.e. financing) of the costs of property or services (e.g., short-term custodial services, research services, news and quotation services, publications, and other services and facilities), overall cost of the trade, desired timing of the transaction, price, confidentiality of trading activity, access to underwritten offerings and secondary markets, provision of research and research-related services, including access to company management and idea generation and market insight, willingness to execute difficult transactions and ability to commit capital, availability of stocks to borrow, quality and timeliness of market information provided, block trading and block positioning capabilities. Accordingly, if we determine in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the brokerage and products or services provided by such broker and/or its affiliates, we may pay commissions to such broker in an amount greater than the amount another broker might charge. Clients should expect that their portfolio transactions will generate brokerage commissions and other costs all of which is borne by the Funds and separately managed accounts. Unless we receive instructions from a separately managed account Client to use a specific broker-dealer, we have complete discretion to decide which broker-dealers or other counterparties to use executing transactions for Clients. We do not currently

engage in direct brokerage arrangements on behalf of Clients. Certain separately managed account Clients may not have clearing, custodial or financing arrangements (e.g. securities lending agreements, margin financing, ISDA agreements) with all counterparties that have relationships with the Funds. While Interval attempts to negotiate similar arrangements on behalf of all of the Funds and managed accounts Clients, there can be no assurance that such arrangements will be the same across all Clients. Accordingly, certain Fund and managed account Clients may be subject to higher fees (e.g. clearing, custodial, and financing). Brokers-dealers sometimes suggest a level of business they would like to receive in return for the various services they provide. While we may budget for these, we will not commit to provide any level of brokerage business to any broker, and actual brokerage business received by any broker may be less than the suggested allocations, but can exceed the suggestions, because total brokerage is allocated on the basis of many considerations including those described above. Our prime broker(s) provide us with front and back office services, including trading, securities lending, clearing, reporting, and settlement for securities, and talent recruiting, among others. Subject to applicable law, our prime brokers may also provide us with capital introduction services. On at least a semi-annual basis, the Brokerage Committee (which includes the Chief Compliance Officer and other senior personnel) evaluates the execution performance of the broker-dealers we use to execute Client transactions. The Brokerage Committee maintains a list of approved broker-dealers and evaluates, and seeks to resolve, any conflicts of interest in selecting brokers to execute Client transactions. Research and Other Soft Dollar Benefits Soft dollar arrangements generally arise when an investment adviser obtains products and services, other than securities execution, from a broker in return for directing Client securities transactions to the broker. To obtain soft dollar benefit, we may cause Clients to pay brokerage commission rates higher than those charged by other broker-dealers. Interval does not seek to allocate soft dollar benefits to each Client in proportion to the amount of commission that each Client has generated. Soft dollar arrangements pose a conflict of interest for us in that such arrangements allow us to pay with Client commissions. When we use Client brokerage commissions (or markups or markdowns) to obtain research or other products or services, we receive a benefit because we do not have to produce or pay for the research, products or services. We may have an incentive to select a broker based on our interest in receiving the research or other products or services offered by such broker. When engaging in soft dollar transactions, we comply with the safe harbor requirements of Section 28(e) of the Securities Exchange Act of 1934, as amended. Under this provision, in exercising our discretionary authority to select or arrange for the selection of brokers for execution of transactions for our Clients, and, subject to our duty to obtain best execution, we may consider the value of research and brokerage products and services (collectively, “Research”) provided by such brokers. Research may include, among other things, proprietary research from brokers, which may be written or oral. Research products may include, among other things, computer databases and quotation services, in each case, to access research or which provide research directly. Research services may include, among other things, research concerning market, economic and financial data; a particular aspect of economics or on the economy in general; statistical information; pricing data and availability of securities; financial publications; electronic market quotations; performance measurement services; analyses concerning specific securities, companies, industries or sectors; market, economic and financial studies and forecasts; appraisal services; and invitations to attend conferences or meetings with management or industry consultants. Accordingly, if we determine in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the brokerage and products or services provided by such broker, a Client may pay commissions to such broker in an amount greater than the amount another broker might charge.

In accordance with Section 28(e), research obtained by the use of commissions arising from an account’s portfolio transactions may be used by Interval or its affiliates in its other investment activities and to service other accounts. Therefore, the account(s) that generated the commissions used to obtain the research may not, in any particular instance, be the direct or indirect beneficiary of the research provided. Under Section 28(e), research or brokerage services obtained with soft dollars generated by an account may be used by Interval to service other accounts, or Clients other than that account, if any. Where a product or service obtained with Client commission dollars provides both research and nonresearch assistance to us, we will follow internal procedures to make a reasonable allocation of the cost that may be paid for with Client commission dollars. We execute securities transactions on behalf of Client accounts with broker-dealers that provide us with access to proprietary research reports (such as standard investment research and credit reports). To our knowledge, these services are generally made available to all institutional investors doing business with such broker-dealers. These bundled services are made available to us on an unsolicited basis and without regard to the rates of commissions charged or paid by Client accounts or the volume of business that we direct to such broker-dealers. Allocation of Investment Opportunities We generally allocate investment opportunities by strategy so that each security held by the accounts we manage within those strategies, is held on a pari passu basis and we may allocate securities among Client accounts on a different basis depending on the strategy or strategies selected by the Client. In such cases, we will seek to allocate such opportunity among our Client accounts in a manner that we deem to be fair and equitable under the circumstances existing at such time. The factors we may consider in making such determination include, but are not limited to, the relative amounts of capital in each Client account available for new investments of the type at issue; our perception of the appropriate risk/reward ratio for each Client account; the intended trading strategy and applicable trading guidelines or restrictions of each Client account; the liquidity of each Client account at the time of investment and thereafter; the overall portfolio composition of each Client account; and applicable legal, regulatory and/or tax considerations. New issues (as defined by FINRA rule 5130) are normally allocated to Client accounts as set forth above, including taking into consideration the regulatory status of a Client as a "restricted person" under FINRA rules. Aggregation of Orders When buying and selling securities for the Funds and separately managed accounts within each strategy, we will generally aggregate multiple transactions into one order so that as many eligible Clients may participate equally over time on a fair and equitable basis, in terms of best execution, efficiency and terms under the circumstances. Aggregation opportunities for us generally arise when more than one Client within a strategy is capable of purchasing or selling a particular security based on investment objectives, available cash and other factors. In such event, securities purchased or sold will generally be allocated among Client accounts within the strategy on an average price basis. When an aggregated order is only partially filled, we will allocate the investment opportunity as described in Item 12, above. Additionally, there may arise certain instances which necessitate the aggregation of transactions for more than one Client across strategies. In such cases, the securities purchased or sold will generally be allocated pro-rata among the participating Client accounts. We may also aggregate subsequent orders within the same strategy for the same security entered during the same day with any previously filled orders. This determination may take into consideration changes in the market price of the security and differences in allocations among accounts.

To address conflicts of interest, a Brokerage Committee meets on at least a semi-annual basis to review items such as new issue allocations, the research and execution services provided by brokers and soft dollar services, among others. Trade Error Policy Subject to applicable law, Interval’s trade error policy includes reimbursing the applicable Client account(s) for net losses that occur because of trade errors resulting from Interval’s gross negligence or willful misconduct, except as may otherwise be the case for any separately managed accounts in accordance with the applicable investment management agreements. We may correct misallocations of trades among Client accounts by re-allocating the applicable trade using the intended allocation methodology. If an erroneous allocation cannot be corrected prior to or after settlement, we may, if appropriate and subject to applicable law, correct such erroneous allocation by affecting a cross trade between Client accounts at the price at which the initial trade was affected.

Interval has in the past and may in the future enter into arrangements with marketing representatives, selling agents or other third parties in connection with the introduction of investors to the Funds. While these arrangements may create an incentive for Interval to maintain relationships with such parties, Interval is not required to direct any volume of business in return for these services. Any decision by an investor to invest in a Fund managed by Interval is made independently by such investor. We may execute Client transactions with prime brokers that sponsor events, meetings or other communications between potential investors and Interval and its affiliates. These capital introduction services are provided incidental to other brokerage services. Interval and its affiliates are not compelled to engage broker-dealers that sponsor these capital introduction programs in order to participate in these events. We do not cause Clients to execute transactions, pay higher commission or other transaction costs in connection with these programs or services. In addition, we enter into soft dollar arrangements with brokers pursuant to which we obtain certain research and brokerage products and services in return for directing Client securities transactions to the broker (see Item 12 - “Selection of Brokers”). The availability of capital introduction opportunities is not a determinative factor in the selection of broker-dealers for Client transactions. We compensate third-party solicitors for Client referrals. For their referral services, these persons may receive compensation in the form of cash payments or a percentage of the management fee and/or performance-based fee or allocation that an affiliate or we receive from the applicable Client with respect to the referred investors. We bear the cost of these fees and, therefore, these fees do not result in any additional charges to any Clients, unless the Client (or investor) agrees otherwise in its applicable written agreement with us or the solicitor.

There are no legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of Interval’s advisory business or the integrity of Interval’s management.

Client portfolios are reviewed daily, and their performance analyzed, by one of our investment professionals, which, depending on the strategy, generally includes, but not limited to, Gregg Moskowitz, Anil Stevens, Elise Di Vincenzo Crumbine, Edward Gilliss, Jeff Schleppy, as well as other Interval personnel. Client portfolios are also reviewed by members of our operations team to monitor compliance with the applicable trading mandate and any applicable risk and/or operating guidelines. Client investments are evaluated based on performance, company fundamentals, news and press releases, analyst reports, general market conditions and such other considerations, as we deem appropriate. We may, in our discretion, furnish investors in the private investment funds we manage with periodic written unaudited performance report. On an annual basis, where applicable, investors receive a copy of the relevant fund’s annual audited financial statements and, where applicable, a statement of taxable income (form K-1). We may provide certain investors access to more frequent and/or more detailed information regarding the private investment funds’ securities positions, performance, finances, and management and/or other information about the private investment funds or us (including, notification of the commencement of certain disciplinary actions, legal proceedings, investigations or similar matters against a fund, us and/or our personnel, or of redemptions from a fund by us and/or our personnel), possibly enabling such investors to better assess the prospects and performance of the funds. In addition, private investment funds, which are separately managed accounts, may have full, real-time transparency as to all transactions and holdings in such account, giving them the ability to better assess the future prospects of a portfolio that is substantially similar to the portfolios of the private investment funds managed by us. The investors in such separately managed accounts have the right to withdraw all or a portion of their capital from such managed accounts on shorter notice and/or with more frequency than the terms applicable to an investment in the private investment funds we manage. Electronic Delivery of Documents We and certain of our service providers often use email addresses provided by investors for communication purposes. Among other things, these communications may include required disclosures. Any investor who wishes to receive communications by mail, rather than by email, should notify us in writing.

Under Rule 206(4)-2 of the Advisers Act (the “Custody Rule”), Interval and its affiliated entities (e.g., Interval Capital, LLC, Interval Capital II, LLC, Roadmap Partners (GP), LLC, Stormborn Capital (GP), LLC, and Recurrent Partners, LLC) may be deemed to have custody of the assets of certain Funds. Each Fund’s assets are held at a qualified custodian (such as prime brokers, banks, and other broker-dealers) to the extent required by the Custody Rule. For purposes of the Custody Rule, Interval does not have custody with respect to the separately managed accounts. The owners of the separately managed accounts may receive account statements from the custodians for such accounts, and are urged to compare those statements with any reports or statements that we provide.

We have discretionary authority to manage securities accounts on behalf of our Clients pursuant to our written agreements with them. The investors in the private investment funds managed by us generally may not place any limits on our authority beyond the limitations set forth in the offering and governing documents of such private investment funds. On a case-by-case basis, owners of the separately managed accounts we manage may negotiate certain risk and/or operating guidelines or other restrictions that we will adhere to when exercising our discretionary authority over such accounts.

We generally have voting discretion over securities held in Clients’ accounts. Clients are generally not able to direct their votes in a particular situation. However, we have previously agreed to allow certain separately managed accounts that we manage to direct our vote in a particular solicitation in certain instances, and may agree to do so again in the future in our discretion (any such requests should be directed to our Chief Compliance Officer). We will exercise our discretion in the best interests of each particular Client, which may result in different voting results for proxies for the same issuer. In fulfilling our obligations to our Clients, we will act in a prudent and diligent manner. We have adopted a proxy voting policy and procedures, which is summarized below.

We have engaged a third-party independent proxy voting service (the “Proxy Service”) to vote proxies for our Clients. The Proxy Service provides proxy analysis and voting recommendations, vote execution, and reports indicating how individual votes have been cast. We have instructed the Proxy Service to execute proxies in accordance with the recommendations unless instructed otherwise by us. If Interval determines that it may have, or it is perceived to have, a conflict of interest when voting proxies, Interval believes that voting in accordance with its proxy voting policies and procedures is in the best interests of its Clients. Upon the request by a Fund or separately managed account that we manage, we will disclose to such Client how we voted securities owned by such Client. The Funds and owners of the separately managed accounts, managed by us, may also contact the Chief Compliance Officer via e-mail or telephone to obtain information on how we voted their proxies, and to request a copy of our proxy voting policy procedures.

Currently, Interval is not aware of any financial condition that is reasonably likely to impact its ability to meet its contractual commitments to its Clients.