Long Focus Capital Management, LLC

As of December 31, 2025, LFCM manages $2,436,534,455 of “Regulatory Assets Under Management” on a discretionary basis.

ITEM 5 – FEES AND COMPENSATION Item 5.A – Fees and Performance Allocations With respect to the Funds, LFCM is paid a management fee monthly equal to one-twelfth of 1.5% (1.5% per annum) of the net asset value of the capital balances of the investors in the Feeder Funds. Long Focus Capital Partners receives a special allocation based on investment performance (the “Performance Allocation”) at the end of each calendar year (and intra-year in association with redemptions from the Feeder Funds, if any, as explained in the Offering Documents) equal to 20% of the excess, if any, of the net asset value of each relevant class or series of Master Fund shares over the previous highest net asset value at which a Performance Allocation was made, adjusted to take into account redemptions from the Feeder Funds by Feeder Fund investors. The calculation of the Performance Allocation reflects both realized and unrealized gains and losses. Once made, a Performance Allocation will not be reversed, even if Feeder Fund investors experience losses in subsequent periods. The calculations for fees and performance allocations can be complex. Prospective and current investors are advised to review the Offering Documents for additional information, including more detail on the calculations. The Manager or LFCM may from time to time (whether granted through side letters or otherwise) permit certain Fund investors (including affiliated investors) to invest in a Feeder Fund on different terms than other investors in the Feeder Fund, including with respect to: (i) redemption rights; (ii) lower or no management fees and/or performance compensation; and (iii) such other provisions as LFCM or the Manager may specify. The establishment or existence of different terms for certain investors will not entitle any other investor or class of investors to the same or similar terms, and neither the Manager nor LFCM will be required to obtain the consent or approval of, or give notice to, any investor or class of investors in connection with those terms. With respect to other clients, the fees and other terms are negotiated with each client and incorporated into their Advisory Agreement. Item 5.B – How Fees and Performance Allocations Are Billed With respect to the Funds, the management fees payable to LFCM are accrued and paid monthly based on the net asset value of each investor’s capital on the last day of the month. The Funds’ administrator is engaged by the Funds to provide day-to-day administrative and bookkeeping services and in that capacity calculates the net asset value of the Funds and also the management fee. Upon LFCM’s verification of the net asset value and the management fee calculation, LFCM will request that the management fee payment is made from the assets of the Funds and the corresponding amounts booked against each investor’s capital or shareholder account. The Funds’ administrator will calculate the amount of the Performance Allocation, if any, following the determination of the net asset value. Upon LFCM’s verification of the calculation, the administrator will book the Performance Allocation to Long Focus Capital Partners’ shares of the Master Fund and the corresponding amounts against each investor’s capital or shareholder accounts. With respect to other clients, the negotiated fee terms will vary based on certain factors including but not limited to the size of the account, the complexity of the investment program based upon

the investment specific investment objectives, the level of monitoring, and account reporting requirements. Item 5.C – Other Fees and Expenses With respect to the Funds, each Fund pays all its expenses incurred in connection with the organization of the Fund and the continuing offering of its interests, as applicable. These expenses include, without limitation, legal fees, accounting fees, printing costs, government filing fees, and out-of-pocket expenses incurred by Long Focus Capital Partner and/or LFCM, as applicable, in connection with the offering. In addition, each of the Funds pays all of its ordinary and extraordinary expenses, including (i) brokerage fees and commissions and other transaction costs and investment-related expenses incurred in connection with the Fund’s investment and trading activities, including research expenses and the costs of any independent accountants or other experts or consultants engaged by LFCM in connection with making investments; (ii) custody charges; (iii) any interest, fees, and costs of Master Fund-related borrowings (including borrowings related to positions held on margin); (iv) routine operational costs such as legal, accounting, bookkeeping, licensing or subscription fees and related support expenses for order and execution and portfolio and risk management systems, auditing, consulting and other professional expenses, administration (including the costs and expenses of the Funds’ administrator, including additional fees for ancillary services), tax preparation expenses, all taxes (if any), costs and expenses related to regulatory compliance matters, and fees payable to governments or agencies; (v) its pro rata portion of any errors and omissions insurance (including E&O, D&O, cyber or any other form of insurance related to the Fund and its management and operations); (vi) exchange, board of trade or other trading or execution facility membership or participation expenses; (vii) market data, price quote data and other data, including, but not limited to, Bloomberg data, research data and alternate data, newswire and data processing expenses, cloud computing and cloud data storage fees and expenses, and connectivity charges; (viii) fees and costs payable in connection with preparing and mailing reports to the investors; (ix) compliance related expenses and fees and expenses associated with preparing and submitting regulatory filings (e.g., expenses relating to the preparation and filing of the Investment Adviser’s SEC Form PF (if required), CFTC Form CPO-PQR and NFA Form PQR and the expenses relating to LFCM’s registration as an alternative investment fund manager for purposes of and as defined in Directive 2011/61/EU of the European Parliament and of the Council of June 8, 2011 on Alternative Investment Fund Managers (AIFMD)); (x) all other ordinary and out-of-pocket expenses of the Funds; (xiii) all taxes (if any) imposed on the Funds (and that the Funds are required to withhold or pay with respect to any investors), and fees payable to governments or agencies; and (xi) other than as prohibited by ERISA, extraordinary expenses, e.g., litigation costs (including expenses incurred in connection with any settlement related to a portfolio investment), indemnification obligations (including indemnification of any person indemnified under the Funds’ operating agreements or any other agreements that the Funds are a party to), expenses of registering the Funds with any governmental agency under the requirements of any applicable law, and costs incurred in connection with a reorganization or restructuring of the Funds, if any. As an investor in the Master Fund, each Feeder Fund, and therefore each Feeder Fund investor, will bear its pro rata portion of the Master Fund’s operating expenses.

With respect to other clients, the expense terms are negotiated with each client and incorporated into its Advisory Agreement. However, generally, all clients will pay the brokerage costs of trading for their account and any custodial fees. Where there is an expense that is shared by more than one Fund, LFCM allocates such shared expenses among the applicable Funds: (i) pro rata based on each Fund’s capital; (ii) in proportion to the size of the investment made by each Fund through the Master Fund to which the expense relates; or (iii) in such other manner as LFCM considers fair and reasonable. Where there is an expense that is shared by the Funds and other clients, LFCM allocates such shared expenses among the applicable Funds and clients: (i) pro rata based on capital; or (ii) in such other manner as LFCM considers fair and reasonable. LFCM and Long Focus Capital Partners bear their own overhead expenses, such as rent, salaries of personnel, and utility costs. Item 5.D – Fees Charged in Advance Neither LFCM nor Long Focus Capital Partners charge fees in advance.

Neither LFCM nor Long Focus Capital Partners nor any of their officers and employees (collectively, “Supervised Persons”) accept compensation for the sale of securities or other investment products.

The investment objective of the Funds is to seek long-term capital appreciation. To achieve this objective, LFCM pursues opportunistic investments primarily in liquid global markets across geographic regions, investment time horizons and asset classes, including equities, fixed income, commodities, and currencies. With a focus on asymmetric risk/reward opportunities and the use of a global macro investment toolset, LFCM strives to generate investment returns despite challenging macroeconomic conditions. The investment objectives of the other clients are set forth in their respective Advisory Agreements. Investment Strategies The investment strategy provides a broad mandate to invest across asset classes, geographic regions, and investment time horizons. The asset classes of primary focus are, but are not limited to, equities, fixed income, commodities, and currencies. The geographic regions of primary focus are the G22 countries, although investments may be made in developing economies at LFCM’s discretion. Investment time horizons may range from several days or less for certain macro trades to several years for positions in certain equities and fixed income securities or other asset classes. LFCM, on behalf of its clients, may trade, buy, sell (including sell short), and otherwise acquire, hold, dispose of (using margin and other forms of leverage), and deal in financial instruments and other rights and interests in and relating to personal property including, without limitation, (i) U.S. and non-U.S. notes, bonds, debt instruments and other fixed income securities, (ii) U.S. and nonU.S. equity and equity-related securities, including, without limitation, new issues, convertible debt securities, equity indices, private placements of common and preferred stock, partnership interests, limited liability company interests and any other type of privately placed instrument, (iii) U.S. and non-U.S. currencies and related foreign exchange products, including without limitation, spot currency and cryptocurrency transactions and currency options and (iv) listed and over-thecounter commodities, financial futures (including, without limitation, single stock and index futures) and forward contracts (including, without limitation, contracts for future delivery with respect to securities, commodities, currencies and other financial instruments), securities futures contracts, swap contracts, currencies, and warrants, as well as listed and over-the-counter-options and other derivative instruments on all of the above securities and commodities, as well as such

other instruments or interests as LFCM deems appropriate which are referred to as securities, futures, forwards or derivatives (collectively, “Financial Instruments”). The fixed income securities in which LFCM may invest include, but are not limited to, bonds, debentures, structured notes, convertible securities, warrants, commercial paper, loan participations, Yankee (dollardenominated) debt securities, Brady Bonds, variable rate notes, Rule 144A securities, bank certificates of deposit, fixed time deposits and money market instruments. Such fixed income securities may be investment grade or rated below investment grade by a nationally recognized statistical rating organization (or deemed to be of comparable or higher quality by LFCM), senior or junior, secured or unsecured, zero coupon or inflation-linked. LFCM may deploy its clients’ assets in stages. As such, until investments of the type described above are made, which will be dependent upon LFCM’s judgment as driven by current and anticipated market conditions, LFCM may temporarily invest the clients’ available capital in shortterm securities or other Financial Instruments such as certificates of deposit, money market funds and/or other cash equivalents. Additionally, LFCM may tactically maintain a percentage of the clients’ portfolios in cash equivalents or other short-term investments, including U.S. government securities, money market funds, commercial paper or certificates of deposit, based on the current opportunity set. Any income from such investments will be reinvested by LFCM in accordance with its investment strategy. LFCM may also reduce exposures under certain market environments or in anticipation of such. In implementing the investment strategy, clients may borrow to leverage investments, fund withdrawals, and pay expenses. The clients may obtain leverage in any manner deemed appropriate by LFCM, including trading on margin, borrowing under credit facilities, and entering into derivative transactions that have the effect of providing the clients leveraged exposure to certain assets. The degree of leverage utilized is not limited to any predetermined level. Except as described in the Offering Documents and Advisory Agreements, there are no material limitations or restrictions on the trading and investment strategies and techniques to be utilized by LFCM, some of which may differ from time to time from those described therein. Methods of Analysis The investment process is driven primarily by valuation and is supported by fundamental research. These efforts are supplemented by technical analysis with an emphasis on trends in individual securities and macro markets. The process includes the analysis of the variables that can affect an investment’s relative attractiveness. For investments in stocks, options, and corporate bonds, the focus is on the overall quality of the company relative to its perceived intrinsic value and the overall quality of the people managing the company. For macro trades in commodities, currencies, and other macro markets, the strategy includes an evaluation of the macroeconomic and microeconomic imbalances and the variables that affect a market’s price. LFCM considers a range of news, reports, market data, and firsthand accounts including, but not limited to, (i) company-specific, industry-specific, and market-specific information and other information from public and private sources, (ii) exchange data and analysis supplied by data services, (iii) publicly-available information furnished by specific companies and information and projections provided by market research specialists and other consultants, and (iv) interaction with

company management teams, employees and other individuals familiar with specific companies or industries or markets. Material Risks of Investment Strategies LFCM has identified the following risks that clients may incur as a consequence of the investment strategies utilized by LFCM. Investing in securities involves a risk of loss that the clients should be prepared to bear. An investor should carefully consider these risks when investing in a Fund. Additional important information about some of the risk factors noted below for the Funds are set forth in the Offering Documents for each Fund. In addition, there are additional risk factors set forth in the Offering Documents for each Fund that are not related to a particular investment strategy. Material risks of investing with LFCM include, but are not limited to, the following: General Strategy Risks Equity Securities. LFCM may trade in equity securities, including listed and unlisted common stock, preferred stock and convertible securities. The value of equity securities may fluctuate in response to specific situations. Clients may suffer losses on investments in equity securities of issuers whose performance diverges from LFCM’s expectations or if equity markets generally move in a single direction and the clients’ equity portfolios fail in its goal to be hedged against such a move. LFCM may make investments in equity securities regardless of market capitalization. The securities of smaller companies may involve more risk and their prices may be subject to more volatility. Convergence Risk. LFCM may pursue relative value strategies by taking long positions in securities believed to be undervalued and short positions in securities believed to be overvalued. In the event that the perceived mispricings underlying LFCM’s trading positions were to fail to converge toward, or were to diverge further from, relationships expected by LFCM, the Fund may incur a loss. Fixed Income Investments. The value of fixed income Financial Instruments will change based on a number of factors including as the general levels of volatility and interest rates fluctuate. Investments in lower rated or unrated fixed income Financial Instruments, while generally providing greater opportunity for gain and income than investments in higher rated Financial Instruments, usually entail greater risk (including the possibility of default or bankruptcy of the issuers of these Financial Instruments). Concentration of Investments. Clients may hold relatively large positions as compared to their total capital. Consequently, a loss in or impairment of the liquidity of any such position could result in a proportionately higher reduction in the Net Asset Value or more restricted liquidity than if the clients’ capital had been spread among a wider number of instruments. Unlike many other investment funds which, as a matter of investment policy, diversify portfolio holdings so that no more than a fixed percentage of their assets are invested in any one issuer or industry or group of industries, the Master Fund does not have fixed guidelines for diversification. The Master Fund is not required to apply any diversification rules. Since a relatively high percentage of the Master Fund’s assets may be invested in a limited number of instruments, the Master Fund’s portfolio may be more susceptible to any single economic, political or regulatory occurrence, and may be more volatile, than the portfolio of a more diversified investment company. Interest Rate Risk. Clients are subject to interest rate risk. Generally, the value of fixed income securities will change inversely with changes in interest rates. As interest rates rise, the market value of fixed income securities tends to decrease. Conversely, as interest rates fall, the market value of fixed income securities

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LFCM’s clients are primarily the Funds. Investor eligibility requirements for each Feeder Fund, will be detailed in the Offering Documents, which specify that each investor must be an be an “Accredited Investor” as defined in Rule 501 of Regulation D under the Securities Act of 1933 and a “Qualified Purchaser” or a “Knowledgeable Employee” as defined in Section 2(a)(51) of the 1940 Act and Rule 3c-5 thereunder, respectively. Investors in the Funds must have (i) prior

investment experience; (ii) adequate means of providing for their current needs and personal contingencies; (iii) no need for liquidity in the investment; (iv) only committed investments in the Funds that are earmarked for long-term investment; (v) sufficient funds to afford a complete loss of principal; and (vi) carefully read and understood (either alone or in conjunction with a financial advisor) the Fund’s Memorandum. The minimum initial amount required to be invested in any Feeder Fund by an investor is $25,000,000, which may be waived at the discretion of Long Focus Capital Partners. Managed account clients may be individuals or entities. The minimum initial amount required to be invested is $5 million, which may be waived at the discretion of LFCM. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS

As described in Item 5, LFCM’s clients can be assessed a performance allocation creating an incentive for LFCM to recommend investments that are riskier than those that would be recommended under a different fee arrangement, as a percentage of an investment’s upside is captured but the potential downside of the investment is not proportionately suffered. To address this conflict of interest, LFCM has adopted policies and procedures that require LFCM to make investment decisions in the best interest of clients. Furthermore, the incentive to make risky investments may be tempered somewhat by the fact that losses will reduce the clients’ performance and, thus, LFCM’s performance-based compensation. In addition, certain of LFCM’s employees, officers, owners, such persons’ immediate family members living in the same household, and trusts and investment vehicles controlled by such persons (each of the foregoing, an “Affiliated Person”) have significant investments in the Feeder Funds and, therefore, are subject to the downside on the Funds’ investments, further moderating LFCM’s incentive to make risky investments.

LFCM does not recommend or select other investment advisers to the Funds. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Item 11.A – Code of Ethics LFCM has adopted a Code of Ethics (the “Code”) which sets forth the ethical and fiduciary principles and related compliance requirements under which LFCM operates and the procedures for implementing those principles. The Code includes provisions that govern fiduciary duties,

client opportunities, insider trading, personal trading, gifts and entertainment, outside business activities and confidentiality. The Code contains policies and procedures that, among other things:

Prohibit Supervised Persons from benefitting at the expense of any client; Require Supervised Persons to comply with federal securities laws; Place limitations on personal securities trading by Supervised Persons (as further described below) including preclearing certain personal securities transactions; Require Access Persons to submit initial and annual reports of personal securities holdings and quarterly personal securities transaction reports to LFCM’s Chief Compliance Officer (the “CCO”). Require the CCO or his/her designee to review Supervised Persons personal transaction and holdings reports; and Require reporting of violations of the Code.

The Code is available to investors in the Funds or prospective client upon request by contacting the CCO at (787) 333-0240. Item 11.B – Participation or Interest in Client Transactions LFCM does not engage in principal trading with the Funds or in cross-trading of the Fund’s assets with other accounts controlled by LFCM.

The personal accounts of Affiliated Persons (“Affiliated Accounts”) can invest in the same securities as the Master Fund at or about the same time as the Master Fund. This creates a conflict of interest because the Affiliated Persons could focus on the performance of the Affiliated Accounts rather than of the Master Fund. Nonetheless, LFCM believes this conflict of interest is mitigated by the fact that generally the securities LFCM invests in for the Master Fund are liquid and readily available investments. In addition, this conflict of interest is mitigated by the facts that certain Affiliated Persons own a significant portion of the Funds and that certain Affiliated Persons’ investments in the Funds comprise a significant portion of their overall investments. To further address the above conflicts of interest, with respect to trading in the Affiliated Accounts, LFCM requires preclearance of any trades in securities other than mutual funds in an amount greater than a limited threshold of the average daily trading volume for such security. In addition, LFCM monitors trading in Affiliated Accounts by reviewing transaction reports and holdings reports required to be submitted under the Code. However, Affiliated Accounts that are clients of LFCM are subject to the Allocation Policies discussed in the immediately following subsection instead of these procedures related to Affiliated Accounts. Allocation Policies

From time to time, LFCM will invest for the Master Fund and for certain managed account clients in the same securities at the same time. Generally, LFCM will determine prior to a trade the amounts of securities it wishes to sell or purchase for the Master Fund and other clients. For all accounts managed according to the same investment strategy, LFCM will generally (subject to the exceptions described below) invest or divest uniform percentages of each account’s total assets in or from identical securities (“target percentages”). Target percentages are generally decided prior to placing an order. LFCM considers some or all of the following factors in making decisions as to the target percentage to purchase or sell for accounts in specific securities: the accounts’ investment objective, policies, restrictions, risk tolerance, time horizon, portfolio construction, tax sensitivity, desired market capitalization range, nature and size of accounts held in the strategy, suitability, tolerance for portfolio turnover, availability of cash or buying power, and whether the accounts are eligible to participate in a trade pursuant to compliance regulations. Based on these factors, at times, the target percentage for a particular security may be a higher or lower amount for a managed account client than the Master Fund. When LFCM seeks to buy or sell a particular security for the Master Fund and a managed account client at the same time, LFCM will, generally, aggregate the purchase or sale of such security for all participating accounts. All eligible accounts generally participate pro rata in the block purchases or sales according to the target percentage established for each participating account and bear pro rata the commission cost. If partial sales or purchases are made of equity securities, the allocation of the equity securities to the accounts shall be in the same ratio as the amounts intended to be bought or sold based on the target percentages. Exceptions to this policy may occur. For example, if one or more accounts would be unable to meet an investment objective, or if a pro rata allocation results in a de minimis allocation to certain accounts, LFCM may deviate from the allocation formula. When equity securities transactions are only partially filled, a conflict of interest may arise to the extent LFCM aggregates orders of the participating accounts together. Under such circumstances, if the managed account clients did not participate in such limited opportunities, the Master Fund would be able to purchase or sell a greater percentage of the security. As noted above, LFCM expects this conflict of interest to arise infrequently, because generally the securities LFCM invests in for the Master Fund are liquid and readily available investments, and, when the Master Fund does invest in the limited opportunities, they comprise a relatively small portion of the Master Fund’s assets. ITEM 12 – BROKERAGE PRACTICES Item 12.A – Selection of Broker-Dealers LFCM is responsible for choosing the brokers through which it will execute trades on behalf of its clients. Currently, LFCM expects to trade for the Master Fund primarily through the Master Fund’s prime brokers. LFCM also may utilize one or more other prime brokers, U.S. and nonU.S. securities and futures brokers or clearing firms, introducing brokers, executing brokers, dealers, custodians and counterparties (collectively together with the Master Fund’s existing prime brokers, “Brokers”) to trade on behalf of clients. In selecting Brokers to execute transactions, LFCM need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Securities transactions for clients are placed with Brokers on the basis

of obtaining the best overall terms available, which LFCM evaluates based on a variety of factors, including the Broker’s reliability, reputation, financial responsibility, stability, ability to execute trades, nature and frequency of sales coverage, commission rate, if any, and responsiveness. Item 12.A.1 – Research and Other Soft Dollar Benefits In addition to considering a Broker’s overall terms and execution capability, LFCM considers the research and brokerage services the Broker makes available. The payment for such benefits by LFCM may be made with “soft” or commission dollars of the Master Fund. Any soft dollar benefits received by LFCM will be in compliance with the safe harbor provided by Section 28(e) of the Securities and Exchange Act of 1934, as amended. Research services paid for in this way will assist LFCM in carrying out its investment decision making responsibilities. Such research services include general economic research, market and statistical information, industry and technical research, strategy and company research and research related to performance measurement and may be written or oral. Brokers that provide both research and execution services are generally paid higher commissions than those paid to Brokers that do not provide such research and execution services. The proposed relationships with Brokers that provide soft dollar services to LFCM may influence LFCM’s judgment in allocating brokerage business and create a conflict of interest in using the services of those Brokers to execute brokerage transactions. For example, by using Fund commissions to obtain products and services, LFCM does not have to produce or pay for such products and services. Consequently, LFCM has an incentive to select or recommend Brokers based on its interest in receiving products and services, rather than the Funds’ interests in receiving most favorable execution. Generally, brokerage and/or research services will be used to service both the Master Fund and the managed account clients. However, at times, certain research received from executing brokers may only benefit the managed account clients. This conflict is mitigated by the fact that the reverse is also true that, at times, certain research received from executing brokers will be used exclusively for the Master Fund. Item 12.A.2 – Brokerage for Client Referrals From time to time, Brokers may assist the Feeder Funds in raising additional capital from investors. LFCM may consider referrals of investors to the Feeder Funds in determining its selection of Brokers. This creates a potential conflict of interest between the judgment of LFCM in allocating brokerage business to brokers to execute the Fund’s transactions and the possible receipt of future referrals. This conflict is partially mitigated by the fact that LFCM is required to seek best execution when selecting Brokers. In addition, LFCM will not commit to an investor or Broker to allocate a particular amount of brokerage in any such situation. Item 12.A.3 – Directed Brokerage LFCM does not recommend, request or require that a client direct LFCM to execute transactions through a specified broker-dealer.

LFCM aggregates orders of securities being purchased and sold at the same time as described in Item 11 above regarding LFCM’s allocation policies. Trade Errors Trading errors are an intrinsic factor in any complex investment process and will occur notwithstanding the exercise of due care and the existence of procedures reasonably designed to prevent such errors. Such errors might include, for example, incorrect entry of a trade into an electronic trading system, errors when reconciling trade activity, or drafting errors related to trade contracts or confirmations. Except to the extent required by non-waivable provisions of federal or state securities laws, the clients (and not LFCM) will bear any losses resulting from portfolio management, trading, or administrative errors in connection with the clients’ investment activities in the absence of fraud, willful misconduct, or gross negligence by LFCM or its affiliates or personnel. Any gains or benefits that result from trade errors will also accrue to the clients. Such errors might include, for example, incorrect entry of a trade into an electronic trading system (e.g., 1,000 shares instead of 10,000 shares are traded), errors when reconciling trade activity, or drafting errors related to derivatives contracts or confirmations. Given the volume of transactions executed by LFCM on behalf of the Master Fund, investors in the Funds should assume that any such errors might occur, although LFCM does not expect them to occur frequently. When resolving issues concerning trade errors, investors should be aware that LFCM will have conflicts of interest such as determining whether the trade error was caused by its gross negligence and the amount of loss due to the trade error. This conflict of interest is mitigated by the fact that certain Affiliated Persons own a significant portion of the Funds which mitigates the incentive to disfavor the Funds in determining the cause of the trade error. ITEM 13 – REVIEW OF ACCOUNTS Item 13.A – Review of Client Accounts There is direct management of all client accounts on a daily basis by or under the supervision of Mr. Helmers in his capacity as LFCM’s portfolio manager. Daily reports of the clients’ portfolio positions and performance are provided to the portfolio manager.

LFCM does not directly compensate any person for client or investor referrals. However, as noted in Item 12.A.2 above, LFCM may consider referrals of investors to the Feeder Funds in determining its selection of Brokers. See Item 12.A.2 above for additional information about such arrangements.

There are no disciplinary or legal events to report. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Item 10.A – Broker-Dealers LFCM is not registered, and does not have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Item 10.B – Futures and Commodity Trading LFCM is also registered as a CPO with the Commodity Futures Trading Commission (the “CFTC”) under the Commodity Exchange Act (“CEA”) and is a member of the National Futures Association (“NFA”). LFCM will operate the Funds as exempt pools under CFTC Rule 4.7 and, therefore, is not required to adhere to certain disclosure, reporting, and recordkeeping requirements under the CEA.

Item 10.C – Material Relationships As noted in Item 4 above, Long Focus Capital Partners, an affiliate of LFCM, is the Manager for the Onshore Feeder and in that capacity is responsible for administering all of the Onshore Feeder’s business and affairs other than its investment activities. Long Focus Capital Partners performs similar functions for the Offshore Feeder and the Master Fund.

Investors in the Feeder Funds receive the following: (i) annual financial statements, audited by an independent certified public accounting firm; (ii) a monthly statement detailing their account information, including the beginning and ending equity of the account; (iii) copies of such investor's Schedule K-1 to the Master Funds’ tax returns, as applicable; and (iv) other reports or documents as determined by LFCM in its sole discretion.

ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Item 14.A – Economic Benefits Provided to LFCM from Non-Clients LFCM does not receive any economic benefits from non-clients for providing investment advice to its clients.

LFCM does not have physical custody of any client assets. However, under Rule 206(4)-2 under the Advisers Act LFCM is deemed to have custody of the assets of the Funds. To comply with the requirements of Rule 206(4)-2, each Fund annually distributes to its investors such Fund’s audited financial statements prepared in accordance with U.S. generally accepted accounting principles (“GAAP”), no later than 180 days after each fiscal year-end. In addition, upon the final liquidation of any Fund, LFCM will obtain a final audit of the Fund’s financial statements prepared in accordance with GAAP and distribute the audited financial statements to all of the Fund’s investors promptly after completion of the audit.

LFCM generally has discretionary authority to buy and sell Financial Instruments for the Funds including, without limitation, to determine the amount of such investments to be bought and sold, subject to restrictions that may be imposed in the applicable Offering Documents and the terms of any investment advisory agreement between LFCM and the Funds. These restrictions and terms may limit LFCM’s advice concerning investments in certain securities or sectors, concentration limits or leverage, among other things. ITEM 17 – VOTING CLIENT SECURITIES Item 17.A – Authority to Vote Client Securities Although LFCM is authorized to vote proxies on behalf of its clients, generally, LFCM does not do so. However, LFCM may vote proxies for certain securities where the act of voting will entitle the Funds to directly receive proceeds from a merger or other corporate action. With respect to other types of proxies, LFCM has determined that the costs inherent in monitoring and voting proxies outweigh the potential benefits in light of the small position size typically held by the Funds in any given security. While LFCM does not anticipate that any Fund would benefit by voting proxies, LFCM’s general determination not to vote proxies on behalf of the Funds results in decisions being made with respect to underlying portfolio securities without input from LFCM.

Where the act of voting will entitle a Fund to directly receive proceeds from a merger or other corporation action and LFCM does choose to vote such proxy, the Chief Compliance Officer will consider whether LFCM is subject to any material conflict of interest in connection with such proxy vote. Employees must notify the Chief Compliance Officer if they are aware of any potential conflict of interest associated with a proxy vote. If the Chief Compliance Officer detects a material conflict of interest in connection with LFCM’s proxy voting activities, the Chief Compliance Officer will meet with Mr. Helmers, and/or outside counsel, as necessary, and determine the best course of action that the Chief Compliance Officer believes is in the Fund’ best interests. LFCM does not accept requests from the Funds or its investors to vote proxies in a particular manner. LFCM’s proxy voting policy and procedures are available upon request. A Fund may obtain LFCM’s proxy voting policy or a record of LFCM’s proxy voting for such Fund by contacting LFCM’s Chief Compliance Officer, at (787) 333-0240. LFCM will not be the lead plaintiff in class action lawsuits or actively participate in the litigation of any such lawsuit. Furthermore, LFCM expects that with respect to most class action settlements it will not file proofs of claim on behalf of the Funds because of the immaterial amounts that will be recovered by filing such proofs of claim.

Not applicable. ITEM 18 – FINANCIAL INFORMATION Item 18.A – Balance Sheet Not applicable. Item 18.B – Financial Conditions Likely to Impair Contractual Commitments LFCM has no financial condition that impairs its ability to meet contractual commitments to clients.

LFCM has never been the subject of a bankruptcy proceeding.