Laurion Capital Management LP

Laurion Capital Management LP provides investment advisory services to pooled investment vehicles operating as private investment funds (i.e., hedge funds). Laurion was founded in 2005 and is primarily owned by Benjamin A. Smith and Janaka Sheehan Maduraperuma. As of December 31, 2025, Laurion had $3.833 billion in client assets under management. All of these assets are managed on a discretionary basis. We act as investment adviser to the following funds: • • •

Laurion Capital Ltd. (the “Offshore Fund”); Laurion Capital LP (the “Onshore Fund”); and Laurion Capital Master Fund Ltd. (the “Master Fund”, and together with the Offshore Fund and the Onshore Fund, the “Funds”).

The Offshore Fund and the Onshore Fund invest all their investable assets through a “master feeder” structure in the Master Fund. As described in Item 10 below, affiliated entities act as general partner to Laurion and the Onshore Fund. The Master Fund is a global multi-disciplinary fund that focuses on a wide range of strategies that include relative value, market neutral and absolute return. These strategies typically seek to analyze common sense structural and behavioral inefficiencies in the markets then employ discretionary and quantitative trading strategies to capture these opportunities. The Master Fund seeks to generate attractive returns with low correlation to traditional markets. Please see Item 8 of this brochure for a more detailed description of our investment strategy and method of analysis. From time to time, we may create and act as investment adviser to other private investment funds or separate accounts. In this brochure, any reference to “Client” means the Funds, and any other Laurion advisory client, not to investors within the Funds (the “Investors”). We do not tailor our advisory services to the individual needs of Investors and do not allow Investors to impose restrictions on investing in any securities. Each person should consult its own advisor to determine the suitability of an investment in one of the Funds. All discussions of the Funds in this brochure, including, among other things, their investments, strategies, fees and other costs, conflicts of interest and relevant material risks, are qualified in their entirety by reference to each Fund’s respective confidential offering memorandum (if any) and governing documents (referred to collectively as the “Offering Documents”).

Each Fund is indirectly subject to management fee and performance compensation terms (an “incentive allocation”) in accordance with each Fund’s Offering Documents. Each Fund indirectly bears a management fee of up to two percent (2%) per year of the market value of the Fund’s net assets, as measured at the end of each fiscal quarter and payable quarterly in advance. Management fees are prorated for capital contributions and withdrawals made at times other than the start or end of a calendar quarter, as applicable.

The Laurion affiliate that also serves as general partner of the Onshore Fund is eligible to receive an incentive allocation based on the net capital appreciation of a Fund’s market value. The incentive allocation consists of up to 20% of net capital appreciation for each fiscal year subject to a high water mark, and is reallocated by the Master Fund to the Laurion affiliate at the end of each fiscal year. The fees for the Funds are not negotiable. However, Laurion, the affiliated general partner, and the Board of Directors, in their sole discretion, may waive, reduce or otherwise modify the management fee and incentive allocation for any Investor, including affiliates and employees of Laurion, members of their immediate families, and trusts or other entities formed for their benefit. In addition, as enumerated in each Fund’s Offering Documents, the Funds may issue other classes of shares or enter into agreements with certain Investors, which may differ from the interests offered to other shareholders or limited partners in terms of, among other things, the incentive allocation and management fee. In addition to our investment management fees and incentive allocation, Investors indirectly bear the operating expenses of the Funds as set forth in the Offering Documents. These may include, among others, investment expenses (e.g., expenses related to the research, due diligence and monitoring of actual and prospective investments (whether or not investments are consummated)); and the consummation of investments, including the following: third-party investment sourcing fees; consulting and other professional fees (including consulting and licensing fees paid to vendors who generate or gather trading ideas, trading models or model portfolios); fees and expenses related to obtaining research and market data (including any information technology hardware, software or other technology incorporated into the cost of obtaining research and market data, and expenses related to obtaining, processing and analyzing "big data" or "alternative data"); travel, lodging and meal expenses; brokerage, including brokerage commissions and other trading expenses, and prime brokerage and futures commission merchant fees, commissions and expenses; expenses relating to reorganizations, restructurings and workouts; expenses relating to short sales; clearing and settlement charges; custodial fees and expenses; bank service fees; interest expenses and fees related to financings or refinancings; fees and expenses of proxy research and voting services; and fees and expenses of third-party professionals, including consultants, investment bankers, valuation service providers, attorneys and accountants; operational expenses, including the following: fees and expenses relating to information technology hardware, software or other technology (including costs of software licensing, implementation, data management and recovery services and custom development, servers and data lines) used to research investments, evaluate and manage risk, facilitate valuations, facilitate accounting functions, facilitate compliance with the rules of any selfregulatory organization or applicable law (including reporting obligations), facilitate and manage the order execution of securities by the Master Fund or any trading vehicle or otherwise manage the Master Fund or any trading vehicle, such as portfolio management systems, risk management systems and order management systems; fees and expenses of third-party risk management products, models and services; third-party administrative fees and expenses (including treasury and collateral management services); the costs of any litigation or investigation involving activities of the Master Fund or any trading vehicle; third-party audit and tax preparation expenses; insurance expenses, including premiums for cybersecurity insurance and liability insurance covering Laurion and its partners, managers, officers, employees and agents, each member of the Funds’ board of directors; fees and expenses (including director registration fees) of the Master Fund's and any trading vehicle's directors and officers (including any third-party AML Officers); costs of preparing and distributing reports and notices; taxes; expenses relating to the offer and sale of shares; expenses incurred negotiating and complying with provisions of any side letter agreement; legal expenses; regulatory, licensing, filing or registration expenses, and/or taxes, including, among others, expenses in connection with compliance and regulatory filings relating to the Funds and the investments, fees and expenses of service providers providing services related thereto (including fees and the expenses associated with preparation and filing of our Form 13F, Form 13H, Form PF,

CPO-PQR, Section 13 filings, Section 16 filings and Form N-PX, if and as applicable, and any other similar regulatory filings in any other U.S. or non-U.S. jurisdiction); expenses related to the maintenance of the Funds’ registered office; corporate licensing; extraordinary expenses and other similar expenses related to the Funds (including, among others, indemnification expenses; fees and expenses incurred in connection with any tax audit by any taxing authority, including any related administrative settlement and judicial review; and fees and expenses incurred in connection with the reorganization, dissolution, winding up or termination of the Funds); and artificial intelligence-related expenses in connection with any of the above. Each Fund sets forth its specific fee structure (including how it charges fees) in their respective Offering Documents. The expenses incurred by each Fund are described in more detail in each Fund’s Offering Documents. Therefore, this is not an exhaustive list of each Fund’s respective expenses. Please see Item 12 of this brochure for more information on the Master Fund’s brokerage and transaction costs. The Funds have, and may in the future, enter into side letters or similar agreements with certain Investors which may have the effect of establishing rights, terms or conditions (including, among others, reductions in management fees and performance based compensation, additional transparency or other preferential terms) for such Investors that are more favorable than the rights, terms and conditions established in favor of other Investors in that Fund. Neither Laurion nor any of our employees receives any transaction-based compensation for the sale of securities or other investment products, including securities of the Funds.

Loss Investment Strategies:

The Master Fund seeks to profit from a global multi-disciplinary approach that uses a variety of trading strategies, including, among others, volatility trading strategies, relative value strategies, event-driven strategies, discretionary and macro-style trading strategies and model-based strategies. The Master Fund may add investment strategies over time. The Master Fund invests in a broad array of securities and derivatives under a range of different market scenarios, making use of these and other strategies. The Master Fund typically uses a substantial amount of leverage in its investment program. This takes the form of trading on margin, investing in derivative instruments that are inherently leveraged, and entering into other forms of direct or indirect borrowing. The Master Fund effects its investment program principally by utilizing a range of equity and nonequity securities, hybrid securities, derivative instruments, and other financial instruments. These include, among others, U.S. and non-U.S. stock and equity-related securities, options, futures, forward contracts, warrants, exchange-traded funds, index-based securities, swaps and other derivative instruments, currencies, commodities, U.S. government securities, money market funds, commercial paper, certificates of deposit and other cash equivalents. The Master Fund may invest in securities that are subject to legal or other restrictions on transfer or for which no liquid market exists. The Master Fund may invest through one or more subsidiaries (“Trading Subsidiaries”) for certain of its investments for tax, regulatory or other reasons.

Methods of Analysis:

Volatility trading strategies look to exploit mispricings in volatility. Strategies employed could include, among others, dispersion and relative value volatility. Products traded in volatility trading could include, among others, listed and over-the-counter derivatives, correlation swaps, variance swaps, equity swaps and credit default swaps. In addition, if a derivative is being used, its underlying asset (e.g., stock, FX, commodity, etc.) could also be used as a hedge. Proprietary models are one of the tools employed by the Master Fund to find trading opportunities. Relative value, discretionary and macro-style trading strategies focus on opportunities in and between global equities, fixed income, futures and commodities and these markets’ derivatives. We pursue fundamental and perceived technical trading opportunities across merger arbitrage, eventdriven, corporate action, and rebalancing opportunities globally. Our approach combines qualitative insights into the structural inefficiencies in various asset classes and their derivatives with quantitative models that we believe aid in identifying trading opportunities. We believe that relative mispricing across and within various asset classes, combined with supply-demand imbalances, results in trading opportunities. We may have trades that include multiple positions (often times these trades include positions that have both long and short exposure), or individual trades that have either long or short exposure in various asset classes and their underlying instruments. Relative value, discretionary and macro opportunities include both single-asset and cross-asset trades. A single-asset trade involves creating a position or portfolio of positions on the same underlying asset. In contrast, a cross-asset trade generally involves taking offsetting positions on different assets. We invest using both single-asset and cross-asset transactions. Model-based trading strategies, when active, are implemented predominantly by computer driven programs. These strategies are based on systematic and qualitative analysis of common-sense insights into market behavior. We focus on capturing likely market inefficiencies based on our market experience and understanding, and then aim to quantify those observations. From this research,

models are created to either implement and execute strategies or aid our trading decisions. Where appropriate, we back-test systematic signals. We monitor the performance of each signal and the Master Fund’s portfolio. We seek to enhance, refine and/or expand our set of strategies and models over time. These strategies may have mean-reverting, trend following, fundamental or technical elements and may have a rapid portfolio turnover, with daily trades in excess of the Master Fund’s portfolio size. These strategies may also have longer-term positions that are held for months. The model-based strategies are global in nature, and could include positions across various asset classes and instruments in emerging market securities in addition to the major developed markets in North America, Europe and Asia. We trade global equity, fixed income, commodities and foreign exchange and related derivatives, and any other instruments we deem appropriate in order to execute the Master Fund's investment objectives. Our goal is to continue to extend our global multi-disciplinary trading approach. Laurion reserves the right to alter or modify our investment programs or to invest in additional strategies where we conclude that such alterations or modifications are consistent with the Master Fund’s investment objective, subject to what we consider an acceptable level of risk.

Risk Management:

Laurion's risk management approach attempts to measure risk, allocate capital based on expected risk-reward and reduce material draw-downs by managing risk concentrations and factors. Laurion measures risk in several integrated ways. Portfolio risk monitoring and management is designed to be multi-faceted and may include analysis of gross and net exposures, sensitivity measures, leverage and Value at Risk. For example, we estimate equity exposure by a covariance matrix as well as calculating equity exposure to various factors. For options and options related positions, Laurion estimates and analyzes the option risks caused by changes in implied volatility using a multi-factor volatility risk model, and uses Monte-Carlo simulations, among other tools relevant to options risk. Additionally, the portfolio is shocked by simulating various event scenarios (e.g., market crash and rise in implied volatility). The risk capital allocated to each strategy is determined by Laurion’s founding partners. Risk is allocated taking into account both the expected return of the strategy and the risk associated with such strategy. In addition, consideration is given to the correlation between strategies.

Risk of Loss:

The Master Fund’s investment program is speculative and entails substantial risks, including the risk that the entire amount invested may be lost. It is designed for sophisticated investors who fully understand and are capable of bearing the risk of investment in the respective Fund. Market risks are inherent in all securities to varying degrees. The practices of utilizing leverage, short selling and engaging in futures, forwards and options transactions, which the Master Fund employs, can, in certain circumstances, increase the adverse impact to which the Master Fund’s investment portfolio may be subject. No assurance can be given that the Master Fund's investment objective will be realized or that Investors will receive a return of their investment. Investors should carefully consider the risks involved in an investment in the Funds. The descriptions contained below are a brief overview of material market risks related to our investment strategies; however, it is not intended to serve as an exhaustive list or a comprehensive description of all risks and conflicts that may arise in connection with the management and operation of the Funds.

Additional or new risks not addressed below may affect the Funds. Investors should review the Funds’ Offering Documents to understand the risks and potential conflicts of interest. Investors should also consult their own legal, tax and financial advisers about the risks of an investment in the Funds. Catastrophe Risks The Master Fund may be subject to the risk of loss arising from direct or indirect exposure to various catastrophic events, including the following: hurricanes, earthquakes and other natural disasters (which may be caused, or enhanced in frequency and severity, by climate change factors); war, terrorism and other armed conflicts; social or political unrest; cyberterrorism; major or prolonged power outages or network interruptions; and public health crises, including infectious disease outbreaks, epidemics and pandemics. To the extent that any such event occurs and has a material effect on global financial markets or specific markets or issuers in which the Master Fund invests (or has a material negative impact on the operations of Laurion or the Master Fund’s service providers), the risks of loss can be substantial and could have a material adverse effect on the Master Fund and investors’ investments therein. Furthermore, any such event may also adversely impact one or more individual investors’ financial condition, which could result in substantial withdrawal requests by such investors as a result of their individual liquidity situations and irrespective of the Master Fund’s performance. Banking Relationships Laurion and the Master Fund will hold cash and, with respect to the Master Fund, other assets in accounts with one or more banks, custodians or depository or credit institutions (collectively, "Banking Institutions"), which may include both U.S. and non-U.S. Banking Institutions from time to time. The Master Fund may also enter into credit facilities and have other relationships with Banking Institutions as contemplated in other governing documents. The distress, impairment, or failure of, or a lack of investor or customer confidence in, any of such Banking Institutions may limit the ability of each of Laurion and the Master Fund to access, transfer or otherwise deal with its assets, draw upon a credit facility, or rely upon any of such other relationships, in a timely manner or at all, and may result in other market volatility and disruption, including by affecting other Banking Institutions. All of the foregoing could have a negative impact on the Funds. For example, in such a scenario, the Master Fund could be forced to delay or forgo an investment or a distribution, including in connection with a redemption, or generate cash to fund such investment or distribution from other sources (including by disposing of other investments or making other borrowings) in a manner that it would not have otherwise considered desirable. Furthermore, in the event of the failure of a Banking Institution, access to a depository account with that institution could be restricted and U.S. Federal Deposit Insurance Corporation ("FDIC") protection may not be available for balances in excess of amounts insured by the FDIC (and similar considerations may apply to Banking Institutions in other jurisdictions not subject to FDIC protection). In such a case, Laurion or the Master Fund, as applicable, may not recover all or a portion of such excess uninsured amounts and could instead have an unsecured or other type of impaired claim against the Banking Institution (alongside other unsecured or impaired creditors). Laurion does not expect to be in a position to reliably identify in advance all potential solvency or stress concerns with respect to its or the Master Fund's banking relationships, and there can be no assurance that Laurion or the Master Fund will be able to easily establish alternative relationships with and transfer assets to other Banking Institutions in the event a Banking Institution comes under stress or fails. Climate Change-Related Risks The environmental effects of climate change, including rising temperatures, extreme weather, fires, flooding, erratic weather fluctuations, agricultural failures and displacement and destabilization of human populations, could have materially adverse effects on the securities held by the Master Fund. Laurion believes that such risks may increase over time, although the time period over which these consequences might unfold is difficult to predict.

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Laurion provides investment management services to privately offered pooled investment vehicles. Investors in the Funds are financially sophisticated, individual and institutional investors that may include endowments, corporations, family offices, banks, pension and profit sharing plans, government plans, trusts, estates, other business entities, and private investment funds (i.e., fund of funds). The minimum investment size varies by Fund and is negotiable. Fund interests are offered to a limited number of individual or institutional investors that qualify as “qualified purchasers” as defined by the Investment Company Act of 1940, as amended, and meet certain other eligibility requirements described in each Fund’s Offering Documents.

As described in Item 5 above, the Laurion affiliate that also serves as general partner of the Onshore Fund is eligible to receive performance based compensation from the Funds. Each Fund’s incentive allocation arrangement is described in detail in the respective Fund’s Offering Documents. Performance based compensation creates a potential conflict of interest because Laurion may have an incentive to make investments that are riskier or more speculative than would be the case in the absence of the performance based compensation. In addition, the performance on which performance based compensation is calculated will include unrealized appreciation of investments that may not ultimately be realized.

Laurion serves as the investment manager to the Funds. We have business relationships with the following affiliated entities: • •

Laurion Capital GP, LLC is our general partner. Laurion Capital Partners LLC is the general partner of the Onshore Fund. Partners LLC also serves as the manager to the Master Fund.

Laurion Capital

Transactions and Personal Trading We have adopted a Code of Ethics which recognizes our fiduciary duty to act in the best interests of the Funds. We adopted the Code of Ethics to, among other things: (1) prevent any improper personal trading; (2) identify any conflicts of interest; and (3) provide a means to address any actual or potential conflicts of interest. Our Code of Ethics requires our employees to pre-clear certain transactions in their personal accounts with our Chief Compliance Officer or his designee, subject to certain exceptions for securities such as, among others, money market funds, open-end mutual funds and exchange traded funds. Generally we will not approve a trade if we determine that the transaction is likely to have an adverse economic impact on any of the Funds. For certain transactions, employees are subject to a 30 day holding period. We have adopted procedures, in accordance with internal and SEC requirements, to monitor adherence to our personal trading policy. These procedures include: • • • • •

distributing our Code of Ethics to all employees upon hire; providing training to all employees upon hire and periodically thereafter; requiring all new employees to submit an initial holdings report, and to provide annual updates thereafter; requiring all employees to submit quarterly transaction reports and periodically provide duplicate copies of their brokerage statements; and requiring initial and annual certifications from all employees regarding compliance with the Code of Ethics.

We may purchase or sell for the accounts of the Master Fund securities in which we, our employees or affiliates have a position. As we describe above and further in our Code of Ethics, certain trades need to be pre-cleared with our Chief Compliance Officer (or his designee) who will only grant permission for the trade after determining that the transaction is not likely to have an adverse economic impact on any of the Funds. In addition, our employees may invest in the Funds. All clients and prospective clients may obtain a copy of our Code of Ethics by writing to our Chief Compliance Officer at Laurion Capital Management LP, 360 Madison Avenue, Suite 1900, New York, NY 10017.

Subject to each Fund’s established guidelines, limitations or restrictions (if any), we have the authority to determine for each Client: • • • •

Which securities are to be bought or sold; The total amount of securities to be bought or sold; Through which broker(s) or dealer(s) those securities are to be bought or sold; and The commission rates or spreads to be paid for each transaction.

Portfolio transactions for the Master Fund are allocated to brokers and dealers based on a number of factors, including price, the ability of the broker or dealer to effect the transactions, the brokers' and dealers' facilities, reliability and financial responsibility and in consideration of such brokers' and dealers' provision or payment of the costs of brokerage and research services that are of benefit to the Master Fund. We are not required to solicit competitive bids and do not have an obligation to seek the lowest available commission or price. Therefore, if we determine in good faith that the commissions or other compensation charged by a broker or dealer are reasonable in relation to the value of the brokerage, research and related products and services provided by such broker or dealer, the Master Fund may compensate such broker in an amount greater than the amount another broker or dealer might charge. Research products or services provided to us may include research reports on particular industries and companies, economic surveys and analyses, recommendations as to specific securities and other products and services providing lawful and appropriate assistance to us in the performance of our investment decision-making responsibilities. We do not have any formal arrangements in place to use client commission dollars, known as “soft dollars”, to pay for any products or services. However, we do receive research from brokers and dealers with whom we trade, and such research may be deemed soft dollar research. To the extent we are deemed to use soft dollars to pay for research products or services, such use will fall within the safe harbor created by Section 28(e) of the Securities Exchange Act of 1934, as amended. When we use brokerage commissions (or markups or markdowns) generated by a client to obtain research or other products or services, we receive a benefit because we do not have to produce or pay for these products or services. While we are obligated to seek best execution for each client, the fact that we can obtain or receive these products or services may create an incentive for us to select or recommend a particular broker-dealer based on our interests, to the exclusion of another brokerdealer that offers business terms that are also favorable to one or more clients. From time to time, brokers may assist the Funds in raising additional funds from investors. In addition, Laurion representatives may speak at conferences and programs sponsored by prime brokers for investors interested in investing in hedge funds. Through such "capital introduction" events, prospective investors of the Funds have the opportunity to meet with us. Neither Laurion nor the Funds directly compensate the prime brokers for organizing these events or for any investments ultimately made by prospective investors attending such events. However, such events and other services (including capital introduction services) provided by a prime broker may influence us in deciding whether to use such prime brokers in connection with brokerage, financing and other activities of the Master Fund.

Laurion does not compensate any third parties for client or investor referrals. We do not receive any other economic benefits from non-clients in connection with the provision of investment advice to clients.

Laurion and its employees have not been involved in any legal or disciplinary events in the past 10 years that would be material to an Investor’s evaluation of the Firm or its personnel.

The Master Fund’s portfolio is monitored on a regular basis by Benjamin A. Smith and Janaka Sheehan Maduraperuma to determine, among other things, risk and positioning. Investors receive account statements directly from an independent fund administrator on a monthly basis that contain unaudited performance data and an update of their accounts. We may supplement these statements with weekly and monthly performance estimates, reports provided during investor meetings or as requested by Investors. Investors will also receive annual audited financial statements prepared in accordance with generally accepted accounting principles and annual tax information.

All Master Fund securities are held by unaffiliated broker/dealers or banks, all of whom are qualified custodians, as that term is defined under the custody rule under the Investment Advisers Act. An investment adviser is deemed to have custody if it acts in any capacity that gives the adviser legal ownership of, or access to, client funds or securities. Therefore, Laurion is deemed to have custody of Master Fund assets because we or one of our affiliates either (1) acts as general partner of a Fund with the authority to dispose of funds and securities in the Funds’ accounts or (2) is deemed to have custody because of its ability to withdraw its fees directly from the Funds. Accordingly, we have developed procedures that ensure the safeguarding and protection of the Funds’ assets. Such procedures include, among other things, the separation of functions and dual signatory approvals for the distribution of Fund capital. In addition, the Funds are subject to an annual audit by an independent public accountant in accordance with U.S. Generally Accepted Accounting Principles, and the audited financial statements are distributed to each Investor within 120 days of the Funds’ fiscal year ends.

Laurion has discretionary authority to determine, without obtaining specific consent from the Funds or their limited partners/shareholders, the securities and the amounts to be bought or sold on behalf of the Master Fund. Any limitations on authority are included in each Fund’s Offering Documents.

Laurion has retained a proxy voting service to assist in the proxy voting process. The CCO manages Laurion’s relationship with the proxy voting service. Laurion will generally rely on the recommendations of the proxy voting service. The CCO ensures that proxy voting service votes all proxies according to this policy, and retains all required documentation associated with proxy voting. Laurion will generally abstain from voting proxies for which the proxy voting service does not provide a recommendation. In addition, Laurion may override the recommendation of the proxy voting service if we believe the matter subject to vote may be material to a Client’s account. Accordingly, we have adopted a Proxy Voting Policy, pursuant to Rule 206(4)-6 of the Advisers Act, designed to ensure that when we do vote proxies, we will vote prudently and solely in the economic interests of, and for the exclusive purpose of providing economic benefits to, Clients. Social, political, or other objectives unrelated to the value of the Client’s investments will not be considered. Because Laurion does not believe it is in the Client’s best economic interests, Laurion does not anticipate attempting to recall shares that have been lent or re-hypothecated in order to participate in proxy voting. Investors may obtain a copy of our Proxy Voting Policy or a record of our proxy votes free of charge by emailing or writing to Laurion at the addresses listed above. Participation in Recovery from Class Actions. When a recovery is achieved in a class action, the funds who owned shares in the company subject to the action have the option to either (i) optout of the class action and pursue their own remedy, or (ii) participate in the recovery achieved via the class action. Collecting the recovery involves the completion of a proof of claim form whichis submitted to a claims administrator. After the claims administrator receives all proof of claim forms, it dispenses the money from the settlement fund to those persons and entities with valid claims. Laurion utilizes a third-party service provider to identify, research, prepare, and file proof of claim forms in connection with settlements of securities class actions in which the Master Fund would appear to have the right to participate as a member of the plaintiff class. The service provider is compensated based on a percentage of the proceeds recovered from a class action filing. It shouldbe noted the Master Fund bears the cost (i.e., receive a reduced amount of the class action proceeds) of any service provider used for class action recovery services. Laurion credits any class action settlements received to current investors in the applicable Fund when the proceeds are received.

Laurion has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage client accounts.