JLL Partners

Advisory Business JLL Partners, LLC and its affiliates (“JLL” or the “Firm”), a Delaware corporation, is a private equity firm which makes control investments in middle market companies. The Firm was formed in 2016 as the successor firm to JLL Partners Inc., which was founded in 1988. Based in New York City, JLL focuses on investments in the healthcare, industrials and business services. JLL serves as the investment adviser for, and provides discretionary investment advisory services to, private funds that are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”) and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”) (each, a “Fund” and, collectively, the “Funds”). JLL also provides discretionary investment advisory services to co-investment special purpose vehicles established to invest alongside a fund in a single portfolio company (each, a “Co-Investment Fund” and collectively with the Funds, the “Funds” unless the context otherwise requires). In limited circumstances, as more fully described in Item 7, below, the Firm also permits certain limited partners and third parties to co-invest alongside a Fund directly into a portfolio company. Unlike the Co-Investment Funds mentioned above, such direct co-investments are not considered Funds or clients of JLL. Each Fund is affiliated with a general partner (“General Partner”) with authority to make investment decisions on behalf of the Funds. The General Partners are subject to the Investment Advisers Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Advisers Act”), pursuant to JLL’s registration in accordance with SEC guidance. The applicable General Partner retains investment discretion and limited partners in the Funds do not participate in the control or management of the Funds. While the General Partners maintain ultimate authority over the respective Funds, JLL has been designated the role of investment adviser. For purposes of this Brochure, references to JLL shall include the General Partners, unless the context otherwise requires. For more information about the Funds and General Partners, please see JLL’s Form ADV Part 1, Schedule D, Section 7.A. and Section 7.B.(1). The Firm shares advisory personnel with JLL Partners FCH, Inc. and its affiliates (collectively, “JLL Partners FCH”), formerly a “relying adviser” to JLL Partners Inc and currently a registered investment adviser. JLL Partners FCH provides investment advisory services to a pooled investment vehicle that is exempt from registration under the 1940 Act and whose securities are not registered under the Securities Act. JLL and JLL Partners FCH have entered into a nondiscretionary management agreement whereby JLL manages JLL Partners FCH fund and its sole remaining portfolio company. Advisory Services The primary focus of the Firm’s investment advisory activity is researching and advising on private equity investments, including leveraged acquisitions and recapitalizations, investments in growth companies, turnarounds and traditional buyouts in a wide variety of industries (generally referred to herein as “portfolio companies” or “portfolio investments”). Investments typically take the form

of privately negotiated investment instruments, including unregistered equity from both U.S. and non-U.S. issuers. Although the primary focus of each Fund is on private equity investments, the Firm is permitted to recommend other types of investments consistent with the respective Fund’s investment strategy and objectives, such as investments in publicly traded securities. JLL’s investment advice and authority for each Fund is tailored to the investment objectives of that Fund; JLL does not tailor its advisory services to the individual needs of limited partners in its Funds (referred to herein as “limited partner” or “investor”). The Fund investment objectives are described in and governed by, as applicable, the private placement memorandum, limited partnership agreement, subscription agreements, investment advisory agreements, side letter agreements, limited liability company agreement and other governing documents of the relevant Fund (collectively, “Governing Documents”) and limited partners determine the suitability of an investment in a Fund based on, among other things, the Governing Documents. The Firm does not seek nor require limited partner approval regarding each investment decision. Fund limited partners generally cannot impose restrictions on investing in certain securities or types of securities, other than through side letter agreements. Limited partners in the Funds participate in the overall investment program for the applicable Fund and generally cannot be excused from a particular investment except in certain circumstances pursuant to the terms of the applicable Governing Documents. In accordance with industry common practice, JLL has entered into side letters or similar agreements with certain limited partners including those who make substantial commitments of capital or were early-stage limited partners in the Funds, or for other reasons in the sole discretion of JLL, in each case that have the effect of establishing rights under, or altering or supplementing, a Fund’s Governing Documents. Examples of side letters entered into include provisions whereby limited partners have expressed an interest in participating in coinvestment opportunities, limited partner advisory committee representation, certain fee arrangements, notification provisions, reporting requirements and “most favored nations” provisions, among others. These rights, benefits or privileges are not always made available to all limited partners, nor are they required to be disclosed to all limited partners, consistent with the Governing Documents and general market practice. Side letters are negotiated at the time of the relevant limited partner’s capital commitment, and once invested in a Fund, limited partners generally cannot impose additional investment guidelines or restrictions on such Fund. There can be no assurance that the side letter rights granted to one or more limited partners will not in certain cases disadvantage other limited partners. JLL does not participate in wrap fee programs. Ownership Structure JLL is owned by Francisco Rodriguez, Daniel Agroskin and Kevin Hammond (the “Managing Partners”) and is controlled by the Managing Partners. Paul Levy is the Chief Executive of JLL Partners FCH. For more information about JLL’s owners and executive officers, see JLL’s Form ADV Part 1, Schedule A and Schedule B.

Regulatory Assets Under Management As of December 31, 2025, the Firm managed a total of $7.404 billion of regulatory assets under management of client assets, all of which is managed on a discretionary basis.

JLL and its affiliated General Partners receive fees and compensation in exchange for advisory services provided to the Funds, including management fees, carried interest, additional compensation in connection with management services performed for the portfolio companies of the Funds and reimbursements from portfolio companies for certain expenses advanced on their behalf. The Funds are also responsible for bearing certain expenses as detailed below and in each Fund’s Governing Documents. Differences exist from Fund to Fund, and certain Funds do not charge certain fees, compensation or expenses that other Funds charge or charge them in different amounts. The following is a general description of fees, compensation and expenses of the Funds. Limited partners should refer to the Governing Documents of the applicable Fund for a complete understanding of how JLL is compensated for its advisory services; the information contained herein is a summary only and is qualified in its entirety by such documents. Management Fees As compensation for investment advisory services rendered to the Funds, the Firm receives from each Fund an annual management fee (“Management Fee”) payable quarterly in advance. Management fees that are paid during the commitment period of such Funds generally are based on aggregate capital commitments of the limited partners and are then asset-based or a combination of asset-based and reserved capital thereafter. The amount of Management Fees generally will not correspond with fluctuations in the net asset value of individual investments, aggregate investments in a portfolio company or of a Fund, including following the stepdown date, and will be reduced in connection with any write-downs below cost, including in the case of investments that have been permanently written off. Permanent write-down determinations are made in the discretion of the valuation committee in accordance with the relevant Governing Documents and the Firm’s valuation policy. In most circumstances, the post step-down Management Fee base will include capitalized transactionspecific fees and expenses of unrealized investments, including transaction fees charged by JLL in connection with the investment, which poses a conflict of interest in that the inclusion of such fees and expenses results in a higher Management Fee than if such transaction fees and expenses were not capitalized into the asset base. Management Fees are paid by the Funds on behalf of the limited partners by (i) requiring limited partners to make capital contributions in respect of such fees, or (ii) withholding the amount of such fees from investment proceeds that would otherwise be distributable to the limited partners of such Fund. In the event that a Fund terminates its advisory contract with JLL in accordance with such Fund’s Governing Documents, any pre-paid Management Fees will generally be prorated for the period during which the Firm has served as investment adviser to such Fund and a refund will be issued for any remaining days in such period.

The General Partners are permitted, in their sole discretion, to reduce or waive all or a portion of the Management Fee. Management Fees can differ from one Fund to another as well as among limited partners in the same Fund. Such differences can arise from the size of a limited partner’s commitment to a Fund, provisions of side letter agreements or other negotiated terms. Management Fees are generally waived for JLL employees investing in a Fund (either as direct limited partners or through a General Partner), affiliates, Strategic Advisors and Operations Group members and their respective families investing in a Fund (although in each case, these limited partners generally pay their pro rata share of certain Fund expenses). Similarly, limited partners in a Co-Investment Fund generally pay a reduced Management Fee or none at all on the coinvestment portion of their investment (although such co-investors generally pay Management Fees on the main Fund portion of their investment, if applicable, and pay their pro rata share of certain expenses as described more fully below). As per the provisions of the Governing Documents, JLL is permitted to waive, defer, or reduce all or a portion of the Management Fee payable by a Fund in full or partial satisfaction of any obligation of a General Partner and certain employees to invest in and alongside such Fund. Certain waived portions of the Management Fee are treated by the Governing Documents as deemed capital contributions by the relevant General Partner, which is effectively invested in the relevant Fund on the General Partner’s behalf and operates to reduce the amount of capital the applicable General Partner would otherwise be required to contribute to the Fund. Limited partner capital contributions are generally accelerated due to waived, deferred, or reduced Management Fees and/or the timing of receipt of fees subject to offsets, and Fund limited partners could thus receive less than the full benefit of such reductions or offsets (e.g., during periods when JLL no longer receives Management Fees and receives compensation that would otherwise be subject to offset, JLL, depending on certain elections made by Fund limited partners, can be entitled to retain such compensation without remitting any such amounts to the applicable Fund or its investments). Management Fees will generally be reduced by, as applicable: (i) the amount of fees paid by a Fund to entities or persons acting as a placement agent in connection with the offer and sale of interests in such Fund; (ii) costs incurred by JLL and paid by a Fund in connection with the organization of such Fund that exceed a limit as specified in such Fund’s Governing Documents; (iii) certain supplemental fees and compensation with respect to portfolio companies, including (a) origination fees, transaction fees, break-up fees, portfolio monitoring fees, consulting fees and other similar advisory fees received by JLL, a General Partner or any of their respective affiliates or their respective officers, directors or employees in connection with the consummation, holding or disposition of a portfolio investment or the termination of a proposed but unconsummated investment or other similar fees received from a company that subsequently becomes a portfolio company within six months of the receipt of such fees and (b) all such fees paid, granted or otherwise conveyed for services as members of boards of directors of portfolio companies that are received by JLL, a General Partner or any of their respective affiliates or their respective officers, directors or employees (together, “Fee Income”); and (iv) Management Fee waivers. The receipt of Fee Income is offset against the Management Fee paid by a Fund net of any expenses incurred in connection with any consummated or unconsummated transaction incurred in generating such fees and allocated to a Fund (and offset against the Management Fee) only to the extent of the Fund’s relative ownership (or anticipated ownership) of such investment or potential investment

as set forth in the Governing Documents. Accordingly, a Fund will only benefit from the Management Fee reduction described above with respect to its allocable portion of any Fee Income and not the portion allocable to any other investor (which could include other Funds, CoInvestment Funds, co-investors, service providers, lenders, third parties, current or former portfolio company management or employees, sellers that have rolled their interest or reinvested proceeds in the portfolio company and/or others) that holds an economic interest in (or, in the case of a transaction not consummated, would have held an economic interest in) the applicable investment. Further, any such reduction of a Fund’s Management Fee is only applicable to the extent a Management Fee is payable by a Fund currently or in the future. In the event a Fund or Co-Investment Fund does not pay a Management Fee (including when a Fund is no longer taking a Management Fee) or does not have a Management Fee reduction provision, JLL will retain the credited offset portion of Fee Income allocable to these Funds or third parties without reduction. Receiving an allocable amount of Fee Income that does not offset the Management Fee results in a smaller amount of Fee Income offsetting such Fund’s Management Fees and gives JLL an incentive to maximize such amounts and to make and structure and potentially syndicate investments that could generate such amounts. For clarity, the following fees and expenses do not offset Management Fees, in each case as applicable: (i) any fees or compensation received by or on behalf of the Operations Group members and Strategic Advisors; (ii) reimbursements from a portfolio company, including reimbursements for any JLL employee who is seconded to a portfolio company; (iii) profits interests paid to a JLL employee who is seconded to a portfolio company, regardless of when the interests or amounts crystalize or vest; (iv) fees or expenses borne by a Fund; (v) broken deal expenses; (vi) profits interests or compensation to an affiliate, Strategic Advisor or Operations Group member that was entered into prior to such person becoming an affiliate, Strategic Advisor or Operations Group member, regardless of when the interests, compensation or amounts crystallize or vest; (vii) fees paid to third parties (and not to JLL or its employees) who JLL appoints to the board of a portfolio company; (viii) fees received from a co-investor or Co-Investment Fund; or (ix) portfolio company fees paid by a former portfolio company to a JLL employee or former employee who remains on the company’s board of directors or is otherwise engaged with the company following the Fund’s disposition of its investment in the company. JLL generally has discretion over whether to charge Fee Income to a portfolio company and, if so, the rate, timing, method and/or amount of such compensation, as well as to charge such amounts at varying levels in a portfolio company’s holding or operating structure. The amount of such Fee Income is paid by the Funds (directly, or indirectly by the portfolio companies) and are determined by JLL on a transaction by transaction basis, subject to the terms set forth in each Fund’s Governing Documents. In general, Fee Income are not typically negotiated with portfolio companies on an arm’s-length basis and such Fee Income could adversely affect a portfolio company’s financial performance. In most circumstances, such compensation is not reviewed or approved by an independent third party. There can be no assurance that the amount of fees charged will be proportional to the amount of work performed on behalf of a portfolio company. On occasion, in certain circumstances (such as a portfolio company’s liquidity needs or otherwise) JLL determines in its discretion to waive, defer or renegotiate, in whole or in part, the amount of Fee Income received from a portfolio company. JLL endeavors to require the payment of such

Read the rest in the brochure

Methods of Analysis and Investment Strategies. JLL has maintained a consistent investment philosophy and process throughout its history, which it has further enhanced through the addition of functional capabilities throughout the years. The transformational growth that JLL seeks to effectuate requires the Firm to devote a significant amount of time, resources, and thoughtfulness throughout the life of an investment. JLL’s efforts to identify and drive business transformation rests upon four interrelated elements of its strategy: the Firm’s deep sector experience, rigorous approach to deal generation, enduring value discipline, and multifaceted value creation methodology. With the Firm’s investment strategy, process, and professionals all working in unison towards achieving business transformation and growth, JLL seeks to generate attractive risk-adjusted returns for its limited partners. JLL’s three targeted industries – healthcare, industrials, and business services – represent meaningful segments of the economy that JLL believes benefit from favorable long-term dynamics within the United States economy. Within each, the Firm develops multiple highly specific investment themes in targeted sub-sectors through extensive primary research, which it then actively pursues often over the course of several years. JLL believes that the breadth and diversification of the three core industries make fruitful grounds for finding actionable acquisition opportunities and developing new investment themes over time. Material Risks Investing in securities involves a substantial degree of risk and is suitable only for those investors who have the financial sophistication and expertise to evaluate the merits and risks of an investment in a Fund and for which such Fund does not represent a complete investment program. A Fund may lose all or a substantial portion of its investments, and investors in the Funds must be prepared to bear the risk of loss of their investments in the Funds. There can be no assurance that the investment objective of any Fund will be achieved, that a Fund will otherwise be able to successfully carry out its investment program, or that an investor will receive a return of its capital contributed to any Fund. The discussion below enumerates certain risk factors that apply generally to an investment in any Fund. Prior to making an investment in a Fund, investors should carefully review the applicable offering documents for a more complete description of the risk factors and conflicts of interest relating to such Fund. General Economic Conditions Changes in general global, regional and/or U.S. economic and geopolitical conditions may affect a Fund’s activities. Interest rates, general levels of economic activity, availability and terms of credit, inflation rates, economic uncertainty/volatility, changes in laws (including laws relating to taxation of portfolio investments), regulatory interventions and changes in regulations, changes in fiscal policies, trade barriers, currency exchange rates and controls, commodity prices and national and international political circumstances (including wars, terrorist acts, natural disasters or security operations), among other things, may affect the price of securities and participation by other

investors in the financial markets may affect the market in which a Fund makes portfolio investments or the value and number of portfolio investments made by a Fund or considered for prospective investment. Material changes and fluctuations in the economic environment, particularly of the type experienced in the years following 2008 and the bank distress, including the receivership of Silicon Valley Bank and Signature Bank in early 2023, that caused significant dislocations, illiquidity and volatility in the wider global economy, and the market changes that have resulted and may continue to result from the spread of the novel coronavirus (“COVID-19”), and wars and international conflicts, such as the Israeli-Palestinian conflict and the ongoing military conflict between Russia and Ukraine, may affect a Fund’s ability to make portfolio investments and the value of portfolio investments held by a Fund or a Fund’s ability to dispose of portfolio investments. The short-term and the longer-term impact of these or similar events are uncertain, but they could continue to have a material effect on general economic conditions, consumer and business confidence and market liquidity. Any economic downturn resulting from a recurrence of such marketplace events and/or continued volatility in the financial markets could adversely affect the financial resources of portfolio investments. Investments can be expected to be sensitive to the performance of the overall economy. Moreover, a serious pandemic, natural disaster, armed conflict, threats of terrorism, terrorist attacks and the impact of military or other action could severely disrupt global, national and/or regional economies. A resulting negative impact on economic fundamentals and consumer and business confidence may negatively impact market value, increase market volatility and reduce liquidity, all of which could have an adverse effect on the performance of portfolio investments, a Fund’s returns and a Fund’s ability to make and/or dispose of portfolio investments. No assurance can be given as to the effect of these events on a Fund’s portfolio investments or investment objectives. Leveraged Portfolio Investments Certain of the portfolio investments in which the Funds invest are expected to be leveraged. While an investment in a leveraged portfolio company offers the opportunity for increased capital appreciation, and although JLL will seek to use leverage in a manner it believes is appropriate under the then-circumstances, such an investment will be subject to increased exposure to adverse economic factors such as a significant rise in interest rates, a severe downturn in the economy or deterioration in the condition of such portfolio investment, and such portfolio investment may be subject to restrictive financial and operating covenants. This leverage may result in more serious adverse consequences to such portfolio investments (including their overall profitability or solvency) in the event these factors or events occur than would be the case for less leveraged investments. This could impair such portfolio investment’s ability to finance its future operations and capital needs and result in restrictive financial and operating covenants. As a result, such portfolio investment’s flexibility to respond to changing business and economic conditions may be limited. If such a portfolio investment is unable to generate sufficient cash flow to meet principal and/or interest payments on its indebtedness or make regular dividend payments, such portfolio investment may default on its loan agreements or be forced into bankruptcy, resulting in a restructuring of such portfolio investment’s capital structure or liquidation, in which case the value of a Fund’s investment in such portfolio company could be significantly reduced or even eliminated.

Further, an adverse economic change could result in some lenders imposing more stringent restrictions on the terms of credit or a general reduction in the amount of credit available in the markets in which a Fund will seek to invest. Any negative impact from the tightening of, or adverse changes in, the credit markets may result in: (a) an inability to finance the acquisition of investments on favorable terms, if at all; (b) increased financing costs; or (c) financing with increasingly restrictive covenants. Such changes in turn may negatively impact the performance of a Fund’s investment in portfolio companies. To the extent there is a lack of readily available and reasonably priced debt financing available to potential purchasers at the time a Fund is ready to dispose of an investment, such circumstances could materially and negatively affect the number of potential purchasers and the prices purchasers are willing to pay a Fund. Borrowing Subject to certain limitations set forth in the Governing Documents, the Funds intend, from time to time, to borrow at the Fund-level or at a subsidiary of the Fund on a secured or unsecured basis in connection with the consummation of an investment for any other purpose related to the business and operations of a Fund or where its General Partner determines that such borrowing is necessary in connection with the operations of a portfolio investment; provided that, any such borrowing shall be repaid within 12 months following date of the applicable borrowing. It is expected that indebtedness will be secured primarily by the unfunded capital commitments of the limited partners or a Fund’s other assets. In connection therewith, a General Partner may pledge its right to make capital calls and collect the unfunded capital commitments and the limited partners may be required to confirm the terms of their capital commitments, to provide financial information and to execute other documents as may be required by debt providers to a Fund. Limited partners whose unfunded capital commitments have been pledged may be called upon to fund their entire unfunded capital commitments to repay indebtedness and the failure of other limited partners to honor their capital commitments may result in a limited partner’s payments exceeding its pro rata share of the indebtedness that has been obtained by a Fund. A limited partner may also be required to fund amounts to repay subscription-based credit facility borrowings incurred in connection with an investment even if such limited partner did not participate in the relevant investment in connection with which such borrowings were incurred. In addition, the extent to which a Fund incurs borrowings may have certain consequences to the limited partners, including, but not limited to (a) use of cash flow (including capital contributions) for debt service and related costs and expenses, rather than for additional investments, distributions or other purposes; or (b) increased interest expense if interest rate levels were to increase. In the event a Fund incurs indebtedness, the preferred return accruing in respect of limited partners will be less than otherwise would have been the case in the absence of such indebtedness. As a result, a General Partner may be entitled (i) to receive Carried Interest earlier than it otherwise would have and (ii) in certain circumstances, to receive Carried Interest in amounts greater than it otherwise would have, in each case had a Fund not incurred such indebtedness and, instead, had required the limited partners to make additional capital contributions. Conflicts of interest also have the potential to arise to the extent that a subscription line is used to make an investment that is later sold in part to co-investors (including one or more co-investing funds), as to the extent co-investors are not required to act as guarantors under the relevant facility

Read the rest in the brochure

The Firm provides investment advisory services to the Funds. Investment advice is provided directly to the Funds, subject to the direction and control of the General Partner of the applicable Fund, and not individually to the limited partners of such Fund. Investors in Funds include high net worth individuals, banks, pension and profit-sharing plans, sovereign wealth funds, trusts, estates, charitable organizations, university endowments, corporations, limited partnerships and limited liability companies or other business entities. Investments in the Funds are subject to applicable eligibility requirements as set forth in the Confidential Private Placement Memorandum. Each investor in a Fund must be an “accredited investor” as defined in Regulation D under Securities Act and a “qualified purchaser” as defined in the 1940 Act. JLL offers co-investment opportunities for certain investors to invest alongside a Fund in certain Fund portfolio companies. As referenced in Item 4, above, co-investments have been structured either as (i) a separate Co-Investment Fund or (ii) a direct investment by certain investors into a portfolio investment or its holding or operating company. When structured as a Co-Investment Fund, JLL considers the investment to be a Fund client, identifies the Fund in its Form ADV Part 1, Schedule D, Section 7.B.(1), obtains an audit for the Fund, reserves the option to assess a Management Fee and Carried Interest on such Fund and includes the amount of assets of such CoInvestment Fund in the Firm’s regulatory assets under management. In the case of direct coinvestments, JLL does not consider the investment to be a Fund or a client, does not act as the investment manager to the co-investment portion of the investment, does not charge Management Fees or Carried Interest to the investment, does not have custody of the investment or include the amount of assets of the co-investment in the Firm’s regulatory assets under management. In such direct co-investment opportunities, JLL will perform management, advisory and other services for the portfolio companies in which these co-investors invest, generally at no cost to such co-investors except portfolio investment fees and expenses (which such fees and expenses are recorded at the portfolio investment). Opportunities to participate in co-investment transactions arise when JLL has the opportunity for an investment in an existing or prospective portfolio investment and JLL determines that (i) an investment requires additional capital, (ii) all or a portion of the applicable opportunity is not required to be offered to a Fund, (iii) the full investment opportunity is not appropriate for a Fund, whether due to concentration restrictions contained in the Fund’s Governing Documents or otherwise or (iv) JLL believes the Fund will benefit from the participation of the co-investor(s). Such determinations are based on the provisions of the applicable Governing Documents, side letter agreements, agreements with lenders and such other factors as JLL will consider in its sole discretion, including those specified in its policies on investment allocation and co-investments. Subject to any restrictions contained in the Governing Documents of the relevant Fund or any side letter or other terms negotiated with respect to such Fund, in general no investor has a right to

participate in any co-investment opportunity. JLL’s exercise of discretion in allocating coinvestment opportunities will not always result in proportional allocations among co-investors and such allocations can be more or less advantageous to some co-investors relative to other coinvestors. When co-investment opportunities are permitted, it is possible that the size of the investment opportunity otherwise available to the Fund will be less than it would otherwise have been without the inclusion of such co-investors. JLL will select the investors that are permitted to co-invest in a particular portfolio investment in its sole discretion based on various factors, including those detailed in its Governing Documents and as outlined in its internal policies and procedures. While one or more limited partners in the Funds are on occasion invited to co-invest in a Fund’s portfolio companies, JLL is authorized in its sole discretion to offer any or all of a co-investment opportunity to investors that are not limited partners in the Funds. Co-investment opportunities are made available to select Fund limited partners and third parties, including, without limitation, management or founders of the applicable portfolio investment, co-sponsors, strategic investors, lenders, investment bankers, deal sources (including finders and consultants), other sponsors (including other private equity or venture capital firms), service providers, Strategic Advisors, sector experts, Strategic Advisors, other persons or entities affiliated, associated or otherwise known to JLL or its personnel. Certain service providers, including lenders and individuals who source transactions, have in the past and are expected in the future to negotiate co-investment rights or co-investment priority rights as a component of their compensation in connection with the services provided. In certain cases, determinations to allocate such amounts or investment opportunities to vendors or service providers will be made prior to the determination of the availability of opportunity for other coinvestors, and as such generally will decrease the amount of co-investment opportunities available. JLL can cause some co-investors in a Co-Investment Fund to bear a Management Fee, Carried Interest or other fees while not imposing a Management Fee, Carried Interest or other fees (or imposing different fees) on other co-investors. In certain cases, co-investment opportunities can include opportunities to invest in Fund portfolio companies at a time when there is not a corresponding Fund investment or on different terms than a Fund investment. Some co-investors can be provided a board seat or observer rights at a JLL portfolio company. Such positions provide such persons with voting rights, access to information and potentially the ability to influence the operations and decision-making of the portfolio company that are not necessarily available to other investors. Although co-investments typically involve investment and disposal of interests in the applicable portfolio company at substantially the same time and on substantially the same terms as the Fund making the investment, co-investors are generally subject to different economic terms than the Fund. From time to time, for strategic and other reasons, a co-investor or Co-Investment Fund purchases a portion of an investment from a Fund after such Fund has consummated its investment in the portfolio company (also known as a post-closing sell-down or transfer). Any such purchase from a Fund by a co-investor or Co-Investment Fund generally occurs shortly after the Fund’s completion of the investment to avoid any changes in valuation of the investment; however, in certain instances, a post-closing sell-down or transfer could occur well after the Fund’s initial purchase. When co-investors purchase their interest from a Fund after the Fund has consummated the investment, the price paid by co-investors is typically determined by the Fund’s General

Partner in its sole discretion, which has the potential to result in a conflict of interest. The Funds will bear the risk that any co-investors acquiring an interest in an investment after the closing of such investment will acquire such interest on terms that do not reflect the then-current value of such investment. Where appropriate, and in JLL’s sole discretion, JLL reserves the right to charge interest on the purchase to the co-investor or co-invest vehicle (or otherwise equitably to adjust the purchase price under certain conditions), and to seek reimbursement to the relevant Fund for related costs. However, to the extent such amounts are not so charged or reimbursed, they generally will be borne by the relevant Fund. The price reimbursed to the Fund may not reflect the full cost incurred by the Fund in connection with the investment, any interest charge on the coinvestment amount, the cost of establishing the credit facility utilized to acquire the portfolio investment (if applicable) or the risk borne by the Fund in connection with purchasing and warehousing the investment. In either case, potential co-investors typically do not bear any transaction costs of investments that are not consummated and are not subject to the same risks to which a Fund is throughout the investment process. As fees paid by or on behalf of co-investors are not subject to a Management Fee offset and are thus retained by JLL, the opportunity to receive such fees presents a conflict of interest in that JLL could be incentivized to allocate a greater portion of an investment to a coinvestor than it would have otherwise allocated absent such an arrangement. JLL seeks to address any such potential conflict of interest by investing in accordance with its policies and procedures governing investment allocation and co-investments. In addition, to the extent that JLL engages in a secondary liquidity transaction in connection with an investment, co-investors will not necessarily receive the same liquidity options as limited partners in a Fund and may therefore be compelled to receive cash or continue to hold an interest in the investment, depending on the particular facts of the transaction. In the event JLL is not successful in offering a co-investment opportunity to potential co-investors, in whole or in part, it is possible that a Fund will consequently hold a greater concentration and have greater exposure in the related investment opportunity than was originally intended, which could make the Fund more susceptible to fluctuations in value resulting from adverse economic and/or business conditions with respect thereto and would result in a greater concentration of risk as a result. In addition, as a consequence of a failed co-investment syndication process or a coinvestment syndication on unattractive terms, a Fund would be required to (i) bear the entire portion of any break-up, topping or other fees, costs and expenses related to such investment (including the proportionate share of such amounts that were expected to have been borne by coinvestors), (ii) receive less-than-fair-market value for the syndicated portion of the investment and/or (iii) be diluted or realize lower than expected returns from such investment. To mitigate such risk, each investment is subject to concentration limits as described in the relevant Fund Governing Documents. Despite these concentration limits, it is possible an investment that is not syndicated to co-investors as originally anticipated could result in a significant impact to a Fund’s overall investment returns.

A carried interest allocation represents an adviser’s compensation based on a percentage of net profits of the funds it manages. Certain General Partners are entitled to receive a carried interest allocation on realized profits in the Funds equal to 20% of certain realized net profits (although some Funds charge a lower carried interest allocation) subject to an 8% annually compounded preferred return (or hurdle), in each case subject to reimbursement of all capital called to pay relevant Fund expenses, including Management Fees. Calculated based on cumulative realized gains and income only, Carried Interest is allocated to a General Partner as portfolio holdings are liquidated or otherwise monetized and is subject to a potential after-tax giveback if the respective General Partner has received excess cumulative distributions. Each Fund’s Carried Interest calculation, as well as the clawback provisions of each Fund, is further described in the relevant Fund’s Governing Documents received by each limited partner prior to investment in such Fund. These performance fee arrangements have been structured subject to Section 205(a)(1) of the Advisers Act in accordance with the available exemptions thereunder, including the exemption set forth in Rule 205-3. JLL seeks to ensure that limited partners in a Fund that are directly or

indirectly assessed a carried interest satisfy the qualifications of Rule 205-3 and have been advised of the terms of such performance-based fees and the associated risks. The General Partner of each Fund, in its sole discretion, is permitted to waive or reduce the amount of Carried Interest for certain Funds or limited partners in a Fund. Specifically, if principals and employees and their respective family members and/or Strategic Advisors are limited partners in a Fund, they will generally pay reduced Carried Interest or none at all. Similarly, limited partners in Co-Investment Funds generally pay a lower amount of Carried Interest on the co-investment portion of their investment. The fact that the Firm is compensated based on the performance of investments creates an incentive for the Firm to recommend investments to or make investments on behalf of clients that are riskier or more speculative than would be the case in the absence of a performance-based compensation arrangement. However, the Firm will provide its investment advisory services to each of its clients in accordance with the investment strategy disclosed in the Fund’s Governing Documents to help ensure that the Funds and their investors are aware of the investment strategy and the risks associated with the strategy. JLL generally considers performance-based compensation to better align its interests with those of its limited partners, particularly in instances where the Governing Documents include terms requiring clawback or giveback of performance-based compensation amounts at the end of the relevant Fund’s life or at certain interim intervals. JLL manages multiple Funds with similar investment strategies on a side-by-side basis. Management of multiple vehicles on a side-by-side basis has the potential to create conflicts of interest with regard to JLL’s allocation of investment opportunities, expenses, time and attention of advisory personnel and consideration for certain transactions. Although JLL generally makes new investments for a Fund with the same investment objectives only after a predecessor Fund is substantially invested or committed as more fully described in the applicable Fund’s Governing Documents, management of side-by-side Funds can create an incentive for the Firm or its personnel to favor a Fund in which JLL or an affiliate has a greater financial interest. To the extent that JLL manages Funds with varying Carried Interest terms (including amount, timing, waterfall conditions or other terms) and/or JLL personnel are assigned different percentages of Carried Interest in different Funds, JLL and such personnel are subject to potential conflicts of interest to the extent they are involved in identifying investment opportunities as appropriate for a Fund from which they are entitled to receive a higher Carried Interest percentage. To help minimize such conflicts of interest, JLL allocates investment opportunities which satisfy the investment parameters of more than one Fund in accordance with JLL’s policies and procedures regarding investment allocation and the applicable Governing Documents and taking into consideration certain factors, as determined in the Firm’s sole discretion, which include, but are not limited to: the amount of available capital commitments of the applicable Fund(s); anticipated future capital requirements of an investment opportunity; life-cycle of the applicable Fund(s); expected time to obtain liquidity; legal, tax and regulatory considerations; and any other factors deemed relevant by JLL. JLL’s procedures are designed to ensure that all investment decisions are made in accordance with JLL’s fiduciary duties to its Funds and without consideration of JLL’s (or its affiliates’ or employees’) pecuniary interest. JLL will not allocate investment opportunities based in whole or in part on the relative fee structure or amount of fees

paid by any Fund or Co-Investment Fund or the profitability of any Fund. Investment allocation decisions are determined by the investment committee.

As described above in Item 4, above, JLL is affiliated with JLL Partners FCH, a registered investment adviser. The officers and employees of JLL have responsibilities with respect to the JLL Partners FCH fund. Conflicts of interest can arise in allocating time, services or functions between the JLL Funds and the JLL Partners FCH fund. JLL has a relationship with Water Street Healthcare Partners, LLC (“Water Street”), a registered investment adviser. Water Street manages a supply chain and purchasing group of full time employees on their payroll. The group provides supply chain and purchasing assessment and negotiation services (e.g. pooling FedEx small parcel volume) for the Water Street portfolio companies as well as for the portfolio companies of JLL and another company. The total costs incurred are split evenly across the three participants. Further, JLL receives a portion of management fees from Pegasus WSJLL Fund L.P., a continuation fund managed by Water Street. Water Street manages this fund and is its general partner; the vehicle is not a client of JLL and is recorded on Water Street’s Form ADV and excluded from JLL’s. Also as described above in Item 4, JLL is affiliated with the Funds’ General which are subject to the Advisers Act pursuant to JLL’s registration. These General Partners together with JLL operate as a single advisory business and serve as the General Partner, affiliate or managing members of private investment funds and other pooled vehicles and share common owners, officers, consultants, Strategic Advisors, Operations Group members or persons occupying similar positions. These General Partners do not have employees of their own.

Trading Code of Ethics and Employee Personal Trading The Firm recognizes and believes that high ethical standards are essential for its success and to maintain the confidence of its clients and their investors. The Firm believes its interests are best served by adherence to the principle that clients’ interests come first. The Firm’s personnel are required to act in accordance with the implied contractual covenants of good faith and fair dealing in respect of their dealings with clients. The Firm’s personnel must also comply with all federal securities laws. Each General Partner is responsible for identifying, reviewing, and resolving potential and actual conflicts of interest between the Firm and the Funds. In addition, whenever necessary, conflicts of interest are also identified, reviewed and resolved by the senior management of the Firm. All of the Firm’s employees have a duty to report any material potential or actual conflicts of interest to the Firm’s Chief Compliance Officer, who review and resolve all material conflicts of interest. The Firm has adopted a Code of Ethics policy for its employees. The Policy describes employees’ standard of conduct and fiduciary duties and limits personal trading by its employees and their immediate family/household members in a wide range of securities, including common and preferred stock, debt instruments, securities that are convertible or exchangeable for equity or debt securities, and derivative instruments. Employees must report accounts that they or their

immediate family member maintain that hold securities covered by the policy and, if they directly or indirectly influence or control trading in the account, they must, with limited exceptions, preclear covered securities transactions and link their brokerage accounts to the Firm’s compliance software or have copies of trade confirmations and periodic account statements sent by their broker to the compliance department, in each case in order for the compliance department to monitor employee trading activity. Trading by employees and their immediate family/household members is prohibited in securities on restricted lists and confidential watch lists, and additional steps are taken to ensure that employees and their immediate family/household members do not purchase or sell securities that may create a conflict of interest with the Funds. Employees are required to certify their compliance with the Code of Ethics upon hire and on an annual basis. Employees who violate the Code of Ethics may be subject to remedial actions, including, but not limited to, censure, fines, suspension or dismissal. Employees are also required to promptly report any violations of the Code of Ethics of which they become aware. The principals and employees of JLL will occasionally carry on investment activities for their own account and for family members, and in connection therewith, can potentially give advice and recommend securities which differs from advice given to, or securities recommended or bought for, the Funds, even if their investment objectives are the same or similar. In addition, consistent with the Governing Documents, principals and employees are permitted to buy securities in transactions offered to, but rejected by, the Funds or that are outside the investment mandate of the Funds. All such employee private investments are subject to pre-approval and/or review by the Chief Compliance Officer. A copy of the Code of Ethics is available upon request to JLL’s Compliance Department at the address or telephone number listed on the cover page of this Brochure. Participation or Interest in Client Transactions Certain JLL employees and their family members have invested in the Funds either through the General Partner and/or as Fund limited partners. As mentioned in Item 5 and Item 6, above, JLL generally reduces all or a portion of the Management Fee and Carried Interest related to investments held by such persons. JLL does not believe this arrangement presents any material conflict of interest since the General Partners’ interests are aligned with the interests of limited partners in the Funds. Section 206(3) of the Advisers Act generally prohibits investment advisers from engaging in principal, cross and agency cross transactions without the appropriate disclosure and consent. JLL will only enter into a principal, cross or agency cross transaction with the appropriate disclosure and consent. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account, knowingly buys from or sells a security to an advisory client. This applies to any affiliates or controlling persons of the adviser (i.e., an owner, employee or affiliate of the adviser, such as a General Partner). Cross trades between funds can also be deemed to be principal transactions if the adviser (and/or its affiliates, owners or controlling persons) own, in the

aggregate, 25% or more of either fund. In the context of JLL’s business, a principal transaction would most likely refer to the practice of warehousing an investment for the formation of a future fund. Cross transactions occur when an adviser or an affiliate arranges a transaction (i.e., acts as broker) between two or more funds or accounts that are managed by that same adviser or an affiliate. An adviser is not “acting as a broker” if the adviser receives no compensation (other than the advisory fee earned in the ordinary course of managing the assets) for effecting the transaction and therefore is not considered to be conducting a cross transaction under Section 206(3) of the Advisers Act. In the context of JLL’s business, a cross transaction would occur when selling a portfolio company, investment or other asset from one Fund to another. Agency cross transactions occur when an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer, which is not appliable to JLL. Any of these transactions create conflicts of interest because, by not exposing such transactions to market forces, it is possible a Fund will not receive the best price otherwise possible, or JLL might have an incentive to improve the performance of one Fund by selling underperforming assets to another Fund in order, for example, to earn fees. These conflicts are heightened to the extent the relevant securities are illiquid or do not have a readily ascertainable value, and there generally can be no assurance that the price at which such transactions are entered into represent what would ultimately be the underlying investment’s fair value. In the event JLL were to recommend a principal transaction or cross transaction, it would only be after: (i) the Firm has determined the transaction to be in the best interest of participating clients; (ii) the transaction is permitted by the relevant Governing Documents; (iii) proper disclosure is given to the relevant General Partner, advisory committee or limited partners, as appropriate; (iv) consent is obtained from the appropriate parties; and (v) the Firm ensures that best execution is achieved for the transaction.

While JLL generally focuses on securities transactions in private companies and purchases and sells such companies through privately negotiated transactions, the Funds are permitted to engage broker-dealers and investment bankers to perform various services for the Funds and portfolio companies, such as assisting in the purchase or sale of a private portfolio company, assisting in the purchase or sale of shares of securities of a public portfolio company or purchasing or selling publicly traded securities. JLL has sole discretion over the purchase and sale of investments (including the size of such transactions) and the broker-dealer or investment banker, if any, to be used to effect transactions for the Funds. In executing transactions, JLL will seek best execution of the transaction. Best execution is a qualitative assessment that takes into account the full range and quality of a broker-dealer or investment banker’s services and is satisfied by obtaining the most advantageous overall terms for the Fund(s) when weighing all factors relevant to the transaction. Best execution is therefore not necessarily determined by lowest possible commission rates. Whether for private or public securities transactions, JLL selects a broker-dealer or investment banker based on JLL’s judgment regarding a variety of factors, including but not limited to: JLL’s prior experience in working with the broker-dealer or investment banker; the broker-dealer or

investment banker’s execution capability, financial responsibility, reputation and expertise within the industry; the broker-dealer or investment banker’s responsiveness to the Firm; the brokerdealer or investment banker’s expertise in dealing with investments that are restrictive or illiquid in nature; the type and size of the transaction involved; the value of any research services providers; and the commission rates, among other factors. Although JLL generally seeks competitive commission rates, it will not necessarily pay the lowest commission or commission equivalent, especially in private securities transactions that rely heavily on the specialty services or experience of a broker-dealer or investment banker that operate outside of a competitive bidding environment. Transactions that involve such specialized services on the part of the broker-dealer or investment banker can thereby entail higher commissions, or their equivalents, than would be the case with other transactions requiring more routine services. JLL does not receive research or other soft dollar benefits in connection with securities transactions for the Funds, does not receive limited partner referrals in connection with selecting or recommending broker-dealers for the Funds and does not engage in directed brokerage. In the event JLL were to aggregate the purchase or sale of securities for client accounts, it would do so on a pro rata basis.

As described in Item 5, above, JLL receives Fee Income from the portfolio companies held by the Funds. These fees are paid pursuant to separate agreements entered into with the portfolio companies (management services agreements) to provide certain services that JLL believes will ultimately enhance the value of the companies and benefit the Funds and their limited partners. In cases where a management team is not in place at the time the management services agreement is executed, a JLL employee will sign the agreement on behalf of both counterparties. Therefore, a conflict of interest exists in the Portfolio Fee negotiation process since there is no involvement of an independent representative of the relevant portfolio company. These types of fee arrangements present potential conflicts of interest and provide JLL with an incentive to recommend investments based on compensation received rather than the best interests of the Funds. To help mitigate this potential conflict of interest, an allocable portion of such benefits received by JLL or its employees (but not Operations Group members) in connection with the provision of such services are offset against Management Fees payable by the Funds, to the extent described above in Item 5 and as detailed in each Fund’s Governing Documents. The receipt of such fees and any conflicts of interest associated therewith are detailed in each Fund’s Governing Documents and are described in this Brochure, in each case as presented to limited partners prior to investment in a Fund. Other than as described above, JLL does not receive any monetary compensation or any other economic benefit from a non-client for the provision of investment advisory services to a client. When raising capital for a new Fund, JLL typically engages the services of a placement agent for the sale of Fund units. Placement agent fees are payable by the Funds and offset dollar-for-dollar against the Management Fee, although related expenses incurred pursuant to the relevant placement agent or similar agreement, including but not limited to placement agent travel, meal and entertainment expenses, typically are borne by the relevant Fund as part of its organizational expenses. This arrangement presents a conflict of interest in that the placement agent receives direct and/or indirect compensation as a result of their endorsement of JLL, which incentivizes the placement agent and its associated persons to recommend an investment with a Fund.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s or investor’s evaluation of the Firm or the integrity of the Firm’s management. Neither JLL nor any of its officers, directors, members, partners or employees, have been involved in any legal or disciplinary events in the past 10 years that would require disclosure in response to this Item.

Oversight and Monitoring The portfolio investments of each Fund are continuously reviewed by a team of investment professionals. The team generally includes Managing Directors and other investment professionals of the Firm. The Firm closely monitors the portfolio companies of the Funds and generally maintains an ongoing oversight position in such portfolio companies. Reporting Investors in the Funds will typically receive, among other things, a copy of audited financial statements of the relevant Fund within 75 days after the fiscal year end of such Fund. In addition, investors in each Fund will typically receive unaudited quarterly summary financial information regarding such Fund within 45 days after each financial quarter. Investors in the Funds also receive regular reporting updates through quarterly letters, investor meetings and other materials provided on the secure investor intranet. The Funds also provide detailed capital call and distribution statements and hold an annual meeting or call for the limited partners as well. Additionally, not all limited partners conduct due diligence or monitor their investments in vehicles such as the Funds in the same manner. For example, in the course of conducting due diligence, limited partners periodically request information pertaining to JLL’s investments and track record. JLL responds to these requests, and in answering such requests, provides information that is not always made available to other limited partners who have not requested such information. As it pertains to existing limited partners, upon request or pursuant to contractual obligations, such as representation on a Fund advisory committee or through a negotiated side letter or similar agreement, certain limited partners receive additional information and reporting that other limited partners do not receive. As a result, certain limited partners will have more

information about a Fund than other limited partners (and it is possible such limited partners will take action upon such information). Where limited partners are co-investors in a portfolio company, they are likely to receive more detailed information concerning that portfolio company than other limited partners that are not co-investors.

JLL is deemed to have custody of the Funds’ assets because the General Partners are not operationally independent from JLL: each Fund’s General Partner generally has full discretion and control over Fund investments and cash, including the ability to deduct fees from Fund accounts. In order to comply with Rule 206(4)-2 (the “Custody Rule”), it is the Firm’s policy to cause each Fund to distribute annually audited financial statements, prepared in accordance with GAAP and audited by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, to Fund investors no later than

75 days after the end of each fiscal year. In addition, upon the final liquidation of any such Fund, the Firm will obtain a final audit and distribute audited financial statements prepared in accordance with GAAP with respect to such Fund to all investors promptly after completion of the audit. Limited partners are encouraged to carefully review such financial statements. JLL does not accept physical custody of Fund assets (other than certain privately offered securities to the extent permitted by the Advisers Act). Called capital is directly deposited or wired into the relevant Fund’s bank account maintained with a qualified custodian and public securities are held with broker-dealers or transfer agents who act as custodians for such securities. JLL receives monthly statements from each of its qualified custodians on behalf of the Funds. For more information about the Funds’ qualified custodians, please see Form ADV Part 1, Schedule D, Section 7.B.(1).

JLL is retained on a fully discretionary basis and is authorized to determine and direct the execution of portfolio transactions pursuant to the terms of each Fund’s Governing Documents. To become a limited partner in a Fund, an investor must execute, among other documents, a subscription agreement and a limited partnership agreement (or similar agreement) with a Fund. Such documents generally contain a power of attorney that grants JLL or the applicable Fund’s General Partner certain powers related to the orderly administration of the affairs of the Fund. Once an investor executes these documents, with limited exceptions discussed elsewhere in this Brochure, JLL is not required to contact such limited partner prior to transacting business in a Fund. Generally, JLL’s only restrictions with respect to managing a Fund, such as, but not limited to, the type of securities in which a Fund invests, will be contained in the relevant Fund’s Governing Documents. However, a limited partner can seek to impose limitations on JLL’s authority through a side letter agreement, and the Firm and/or the relevant General Partner can choose to accept reasonable limitations or restrictions at its discretion. All limitations and restrictions placed upon JLL’s investment authority with respect to a limited partner’s investment must be presented to JLL and the relevant Fund’s General Partner in writing and agreed to by all applicable parties.

By virtue of the applicable Governing Documents, JLL has the authority to vote proxy statements on behalf of the Funds. However, given the nature of JLL’s advisory business, the Funds seldom hold public securities; the majority of “proxies” received by JLL are written shareholder consents or similar instruments for private companies owned by the Funds. Specifically, from time to time, portfolio companies request JLL (usually through the General Partner of the applicable Fund) to consent to certain issues pertaining to the portfolio company’s business and requiring equity owner approval. In these cases, JLL considers factors that could affect the value of the investment and will act in the manner that it believes maximizes the value of its investment in portfolio companies. JLL has adopted proxy voting policies and procedures pursuant to Advisers Act Rule 206(4)-6. JLL’s proxy voting policy seeks to ensure that it votes proxies in the best interest of the Funds with a goal towards maximizing overall value. Pursuant to its policy, JLL will generally vote in

accordance with management’s recommendations unless JLL determines that voting in such a manner is in conflict with the best interests of the Fund’s limited partners. JLL generally believe its interests are aligned with those of the Funds’ limited partners through the principals’ beneficial ownership interests in the Funds. However, in the event that there is a conflict of interest in voting proxies, JLL’s proxy voting policy provides that the Firm can address the conflict using several alternatives, including by seeking the approval or concurrence of an advisory committee on the proposed proxy vote, or through other alternatives as set forth in JLL’s proxy voting policy. Limited partners in the Funds cannot direct how JLL votes proxies or shareholder consents, nor is JLL required to seek limited partner approval or direction when voting proxies or when giving consent on any matter requiring the consent of shareholders. Firm principals and affiliated or unaffiliated third parties appointed by JLL sit on the boards of portfolio companies and, as such, exercise authority with respect to various issues faced by the portfolio companies. JLL does not consider service on portfolio company boards by the aforementioned persons or their receipt of nominal board fees, if any, to create a material conflict of interest in voting proxies with respect to such companies. The General Partners intend to vote proxies or similar corporate actions in the best interests of the applicable Fund, taking into account such factors as they deem relevant in its sole discretion. JLL will provide a copy of its proxy voting policy to limited partners upon request to the Chief Compliance Officer at the information included on the cover of this Brochure. Limited partners can also obtain information from the Firm, free of charge, about how JLL voted any previous proxies, if any.

The Firm has no financial commitment(s) that impairs its ability to meet contractual and fiduciary commitments to its clients and has not been the subject of a bankruptcy proceeding. The Firm is not required to attach a balance sheet because it does not require or solicit the payment of fees six months or more in advance. Item 19. Requirements for State-Registered Advisers