Monarch Alternative Capital LP

Monarch Alternative Capital LP (the “Adviser” or “Monarch”) is an investment adviser formed in Delaware with its principal place of business in New York, New York. The Adviser was formed on March 26, 2002. The Adviser is wholly owned by MDRA GP LP, which is majority owned both directly and indirectly by the Adviser’s three co-founders: Michael A. Weinstock, Andrew J. Herenstein and Christopher M. Santana. A partnership committee comprising the three founders, Adam Sklar and Stacey Maman sets strategic direction for the Adviser. The Adviser provides discretionary investment advisory services to its clients, which are pooled investment vehicles intended as investments for sophisticated investors such as institutional investors and high net worth individuals who are qualified to invest under applicable law (each such vehicle a “Fund” and collectively, the “Funds”). In addition, the Adviser has in the past provided and may in the future provide discretionary investment advisory services to private funds that are established by or in conjunction with third parties (“Third Party Funds” and together with the Funds, “Clients”). The Adviser provides and may in the future provide non-discretionary investment advisory services, including to Third Party Funds. It should be noted that any such future relationships may be subject to minimum investment size and other possible special requirements. Clients may be structured as open end, closed end or hybrid funds. Clients typically are U.S. and non-U.S. limited partnerships or non-U.S. corporate entities that are not registered or required to be registered under the Investment Company Act of 1940, as amended (the “1940 Act”) or the Securities Act of 1933, as amended (the “Securities Act”). Interests in Clients are typically privately placed to qualified investors in the United States (“U.S.”) and elsewhere. These qualified investors are U.S. persons that are “Accredited Investors” and “Qualified Purchasers,” non-U.S persons or “Knowledgeable Employees” as defined under applicable SEC rules and regulations. The Adviser is focused on investing in corporate credit and real estate. Clients may invest in and hold a variety of instruments, including bank loans, public and private corporate bonds, municipal and sovereign debt, asset-backed securities, equity securities received in connection with debt restructurings or otherwise, real estate and private equity. Clients may also hold a variety of derivative instruments or short positions for investment and hedging purposes. The Adviser tailors its advisory services as described in the investment program of each Client’s private placement memorandum or organizational documents or as set forth in the investment management agreement with such Client (collectively, “Governing Documents”). Please refer to Item 8 for a more detailed description of the Adviser’s investment strategies and instruments held by Clients. The Adviser manages each Client’s portfolio according to the terms of the Client’s Governing Documents. The terms upon which the Adviser serves as investment manager of a Client and the terms of such Client are generally fixed at the time a Fund is first offered or are generally negotiated before the Adviser is engaged. Such terms are set out in a Client’s Governing Documents, which may be amended from time to time. These terms, which vary among Clients, generally include restrictions or guidelines on the types of securities and other assets in which a Client may invest, as well as the amount of assets a Client may invest in any issuer, security type, industry or geography, among others. The Adviser is not obligated, although it has the authority, to structure any Client’s investment in order to address or give effect to the individual objectives

or considerations of any investors or group of investors in that Client. While Clients’ portfolios are managed utilizing an opportunistic, event driven strategy, the particular investment targets and limitations are tailored for each Client and are reflected in the relevant Governing Documents. For example, certain Clients’ strategies involve a diversified portfolio with a preference for senior debt while maintaining flexibility to invest throughout the capital structure. Other Clients’ strategies provide for an emphasis on longer-term credit and real estate opportunities. The Adviser also manages Clients focused exclusively on real estate. For all Clients, there is a focus on opportunities with the potential for process control, including from distress, restructuring or other complexity. The Adviser may in the future manage Clients with other non-diversified or coinvestment strategies, including those focused on a particular market segment or asset class; Third Party Funds and certain other Funds from time to time request changes in concentrations of certain investments or investment classes within their portfolios and may request certain non-discretionary services in conjunction with their discretionary services. These Clients may have a greater degree of concentration of investments in individual companies, countries, market segments or industries. The Adviser does not assign specific individuals to support only specific Clients. Members of the Adviser’s investment committees manage each Client with the input of the broader investment team. Within Monarch’s one-team model investment professionals develop specialization that may change depending on where the Adviser determines opportunity resides. The Adviser may create teams to focus on a particular area that includes investment professionals dedicated to that area. In particular, the Adviser has created a real estate focused team that sits within the broader investment team. Persons reviewing this Form ADV Part 2A Brochure should not construe this as an offering of any of the Funds described herein. Any such offering will only be made pursuant to the delivery of a private placement memorandum to prospective investors. The Adviser does not participate in wrap fee programs. As of December 31, 2025, in respect of Clients that the registrant advises as of the date hereof and its proprietary account described below, the Adviser managed approximately $15.6 billion in assets on a net asset value basis, including unfunded and contingent commitments. Of these approximately $15.6 billion in assets managed by the Adviser, approximately $668.0 million in assets are non-discretionary, $155.6 million are in separately managed accounts (approximately $58.1 million of which is held in non-securities portfolios) and $0.4 million in assets are attributable to a proprietary account that does not actively trade its positions and is not expected to participate in new investment opportunities, although it has and is expected to participate in investments the purpose of which is to protect or enhance an existing position.

Clients are generally charged a monthly or quarterly management fee in advance based on the net asset value of their assets under management with the Adviser, commitments or contributions. The management fee for certain closed end funds is charged on the lesser of net asset value (gross of any accrued incentive) or commitments. The Adviser has entered into other arrangements including charging management fees on the basis of actively invested capital and has previously charged a commitment fee on undrawn capital commitments, which it may do in the future. Clients that terminate investment advisory services or investors that are mandatorily redeemed from a Client before the end of a pre-paid billing period will generally be refunded any pre-paid fees for the period for which they did not receive services, unless otherwise provided in the Governing Documents. Management fees for Clients generally range from 0.50% to 1.75% on an annual basis, and lower fees may be available depending on various factors. Certain closed end funds may pay no management fees during all or a portion of the fund’s harvest period. Management fees are allocated for all purposes to investors in Clients that are subject to such fees and are charged gross of any accrued incentive allocation on the investor capital balance. Furthermore, Clients are charged a performance allocation or fee that, depending on the applicable terms, may be taken annually and/or upon distributions. The performance allocation for Clients generally ranges from 10% to 20% with varying hurdles or preferred return requirements, although the Adviser may charge higher or lower fees in the future. The performance allocation for open end Clients is generally based on net capital appreciation at the end of each fiscal year. Any incentive fee or allocation for open end Clients is also subject to a “net-loss carry forward” provision whereby a performance allocation or fee is not charged until losses from prior years have been recouped. The performance allocation for closed end Clients is based on the return to a Client’s underlying investors and the achievement of a certain preferred rate of return that varies among Clients and underlying investors. Clients have also negotiated lower fees on certain coinvestments and co-investments offered to certain investors will not bear any fees. In addition, Third Party Funds have been, and in the future may be, subject to a minimum amount of management fees for an initial period. As such, underlying investors should consult a Client’s Governing Documents for a more complete discussion of the management fees and other compensation arrangements to which such investors are subject. Each Client’s Governing Documents note the fee and allocation arrangements available to investors, including any fee breaks based on investment size. Furthermore, the Adviser may permit Clients to waive, cap, rebate or reduce all or part of the fees or performance allocation with respect to certain investors without waiving, capping, rebating or reducing the fees or performance allocation with respect to other investors. Third Party Funds negotiate their fees with the Adviser. Third Party Funds may also negotiate provisions regarding various expenses such as formation, audit, administration, custodial or others. The Adviser is generally granted the discretion to deduct its fees and allocations as incurred; however, certain Clients, generally Third Party Funds, authorize payment to the Adviser. As described in particular detail by each Client’s Governing Documents, underlying investors generally bear the costs and expenses associated with a Client’s formation and the execution of its investment strategy. Accordingly, by investing in a Client, underlying investors bear the cost of the organization and offering of such Client and any related feeder funds, master fund and other

special purpose vehicles, including external legal and accounting expenses and out-of-pocket expenses or disbursements. In addition, investors also bear all expenses relating to a Client’s operations, and such Client’s pro rata share of the expenses relating to the operation of any master fund or other vehicles through which it may directly or indirectly invest. Such expenses generally include, but are not limited to: •

the management and incentive fee or allocation;

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fees payable and costs and expenses reimbursed to any third-party alternative investment fund manager and general partner or similar entity required for a Client;

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fees paid to a Client’s administrator, depositary, brokerage agent, custodian and transfer agent;

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fees paid to professional advisors (including consultants and administrators) regarding tax, compliance, accounting, legal, architectural or engineering matters related to the Client (including its relationship with each of its investors) or its investments;

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fees paid to operating partners, collateral managers, asset managers and directors, registered office fees, bank service fees, investment or trading related fees, such as Bloomberg terminals, brokerage commissions or spreads, prime broker fees or custodian fees;

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construction management fees, development fees, property management fees, leasing commissions, acquisition fees, disposition fees, title fees and other fees and expenses paid to title companies, brokerage fees, costs of title insurance and property-related insurance;

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research expenses (including expenses associated with research-related conferences or seminars) consultant, operator or servicer fees, structuring and ongoing costs (e.g., expenses, fees and costs of third parties that provide specialized reporting, operational know-how or services, data and/or analysis, and in respect of entity formation, servicing and maintenance, including as related to directors, executors, or other governance structures or functions, whether on a one-off or on-going basis, as to specific companies, investments, sectors or asset classes in which the Client has made or may make an investment, or subscriptions to certain specialized publications) related to the analysis, negotiation, purchase, sale, restructuring, sourcing, workout, monitoring, holding or disposition of investments, whether or not the investment is consummated, and expenses relating to the construction and development or redevelopment of any investments;

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due diligence (including, but not limited to, the engagement of specialized service providers relating to an investment, group of investments or strategy, tax or accounting consultants, legal or financial advisors and other consultants or advisors) expenses related to the analysis, purchase, sale or hedging of investments, and expenses associated with the formation and operation of vehicles established to make such investments (including employees of, or taxes, including VAT, paid in respect of, such vehicles), whether or not consummated;

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expenses, including, but not limited to, fees for legal or regulatory advice, filing preparation support or software, submission costs, disclosure and compliance services incurred in connection with the registration, qualification, exemption, disclosure or other legal and regulatory compliance requirements applicable to a Client under U.S. federal, state, local or

non-U.S. law or regulation, including applicable non-U.S. fund regime requirements (but, for the avoidance of doubt, excluding adviser-focused regulatory reporting, i.e., Form ADV); •

professional liability insurance for the Adviser (i.e., D&O and E&O policies), Client filing and registration fees and service provider expenses, applicable taxes, or other operational fees or expenses, including indemnification and insurance expenses for claims and the costs and expenses of litigation, arbitration or similar proceedings involving a Client;

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costs related to (for example, obtaining, developing, customizing, implementing, supporting or maintaining) technology, systems (e.g., Bloomberg Terminals) or services (including for example, outsourced or co-sourced services and artificial intelligence tools) utilized with respect to a Client or its activities (e.g., investments and investment structures), including but not limited to internal fund accounting (e.g., NAV, reconciliation, valuation and other support services), data and risk management, trading (e.g., software supporting order management, general ledger or allocation processes), position or other data management, cash and position reconciliation, trade execution tracking, regulatory filings, maintaining investor information and generating investor reports and other investor information including responses to due diligence questionnaires and requests for proposals;

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expenses related to any limited partner advisory committee of a Client;

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expenses relating to the valuation or appraisal of investments and expenses associated with securities quotation services and products (e.g., Bloomberg, Intex, IDC, NYSE, and other similar services);

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expenses, including, but not limited to, fees for legal or regulatory advice or compliance services, relating to anti-money laundering and know your customer laws, regulations or rules;

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expenses relating to investor communications, such as an investor portal, and expenses related to holding an annual informational meeting of investors;

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any withholding or other taxes, together with any interest and penalties thereon that are not properly chargeable to one or more of a Client’s investors and that are payable to U.S. federal, state and local, and other governmental agencies and all expenses incurred in connection with any tax audit, investigation, settlement or review;

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other expenses related to the investment, financing, monitoring, enhancement, disposition or reporting of Client assets;

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all costs and expenses in connection with any credit facility entered into by a Client or any special purpose vehicle or other borrowing or indebtedness (including margin loans) undertaken by the Fund, including the payments of any principal or interest, as well as servicing fees and special servicing fees;

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costs and expenses of forming and maintaining any alternative investment vehicles and investment vehicles;

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costs and expenses related to complying with any side letter agreements and the “most favored nations” processes associated with such side letter agreements;

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fees, costs and expenses incurred in connection with any tender offer for limited partner interests in the Partnership or other secondary transaction led by the General Partner, in each case, whether or not consummated;

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fees and expenses incurred in connection with transfers of interests not otherwise borne by the applicable transferor or transferee;

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fees and expenses incurred in connection with distributions of cash, assets or other property to investors;

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all expenses relating to investor defaults and related enforcement or remedial actions;

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costs and expenses incurred in connection with amendments to, restructuring of, or compliance with the constituent documents of a Client and related entities;

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fees, costs and expenses incurred in connection with dissolving, liquidating, winding-up or terminating a Client; and

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travel, lodging, meals or entertainment related to any of the foregoing.

Clients pay the fees, costs and expenses of their service providers under the relevant agreements at commercial rates negotiated from time to time. No maximum level of fees has been established between Clients and their service providers. In addition, the service providers may have a right to be reimbursed by Clients for reasonable out-of-pocket expenses. The foregoing expenses or fees may be charged on a recurring or one-off basis and may be calculated as a flat-fee or a percentage of Client assets or otherwise. Furthermore, none of the fees charged to and payable by Clients are subject to a generally applicable maximum level. Clients do not bear the cost of (i) any remuneration to employees or officers of the Adviser, (ii) expenses solely related to the Adviser or its affiliates unless specifically noted above or (iii) any expenses relating to holding an annual informational meeting of investors in the Clients. For the avoidance of doubt, a Client will bear the cost of officers, employees, vendors or third-party operators or managers of investments or their holding structures, including where such officers, employees, vendors or third-party operators or managers are appointed, hired or engaged by or at the direction of the Adviser. Expenses incurred for the benefit of one or more Clients will generally be allocated as of the end of each month in which it is incurred pro rata in proportion to either the size of each of such Clients, the relative exposure (actual or anticipated) of each of such Clients to the investment to which such expense relates or as otherwise determined by the Adviser in accordance with its policy on expense allocation. Other expense allocations may result from the Adviser’s policies, which are available upon request. For example, pursuant to the Adviser’s best execution policy, research expenses attributable to higher commissions (or larger spreads) will be borne by the Adviser’s Clients

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The Adviser seeks to capitalize on the dynamic and growing opportunity set in the corporate credit and real estate universe resulting from a supply-demand imbalance, rising default rates, economic concerns, and other factors. Like the markets in which it invests, the Adviser’s processes and strategies also evolve and change. The Adviser draws upon the extensive experience of the Adviser’s team, which includes over 30 years of researching, investing in, and restructuring distressed entities. With a focus on corporate credit and real estate, Monarch seeks to identify inefficient market segments that provide for attractive opportunistic investments that leverage Monarch’s core skills and experience to create value. Monarch takes a flexible and opportunistic approach to investing by generally focusing on areas with limited competition, including mid-sized capital structures, less trafficked instruments in large situations and differentiated investment approaches within certain segments and industries. The Adviser utilizes a research-driven approach to investing. Monarch seeks to develop a superior understanding over sellers of investments that typically may be unwilling or unable to hold instruments in complex or dynamic situations, by utilizing its expertise and conducting more research about the company, the capital structure and, as applicable, the restructuring or legal process. The Adviser approaches investing on a “bottom-up” basis meaning that the investment team seeks to invest in what it believes to be the most attractive opportunistic credit and real estate investment opportunities at a given time based on rigorous analysis of each individual investment rather than building the portfolio based on market factors such as the direction of the economy, interest rates, currencies and credit spreads. Monarch frequently takes an active approach in its investment strategy and seeks to drive value creation by capitalizing on its differentiated restructuring and legal expertise and the ability to navigate complex situations. Being active creates opportunities for value by driving outcomes, which can provide for enhanced economics when compared to passive investors, incremental investment opportunities, and other offerings at attractive terms, as well as new opportunities in related situations. When Clients receive significant equity stakes in restructured companies, members of Monarch’s investment team may join the board of directors of a restructured company or otherwise become actively involved to influence management and work to enhance the value of Client investments. Additionally, when active in the restructuring or legal process, the investment team typically participates in groups such as ad hoc creditors’ groups and bank steering committees. Monarch’s investment team may also participate in official Chapter 11 creditors’ committees. The Adviser’s ongoing process following the initial investment entails continual research and active involvement to identify additional opportunities for follow-on investments, support its efforts to influence the outcome of a restructuring or legal process and maximize the value of the investment. In real estate, Monarch focuses primarily on real estate debt and structured credit, specifically single asset single borrower securitizations, as well as other securitized assets. Monarch’s investment team takes a flexible and opportunistic approach to investing by focusing on areas where it believes there is limited competition. Monarch’s dynamic approach to sourcing opportunities seeks to capitalize on an ever-evolving investment landscape.

An investment in securities or other financial instruments, including the portfolio companies and other investments held by Clients, involves a significant degree of risk. There can be no assurance that the investment’s targeted returns will be achieved or that there will not be a loss of capital. A Client’s losses will be borne solely by the underlying investors and not by the Adviser. Therefore, an investor should only invest in a Client if the investor can withstand a total loss of its investment. Prospective Clients or investors in Clients should take note of the general aforementioned risk of loss and carefully review the various risks particular to the Adviser’s investment strategy outlined below and in the applicable Client’s Governing Documents. Not all risks are apparent or known, so prospective Clients or investors in Clients should not assume that the following is a complete list of risks attendant to a Client’s investment program. Material, Significant or Unusual Risks Relating to Investment Strategies General Investment Risks All Client investments risk the loss of capital. A Client’s investment program, refined research techniques, active participation in the reorganization process and targeted and portfolio-wide hedging activities may not successfully moderate this risk nor may a careful selection of loans, securities, equity interests, other financial instruments and assets. There can be no assurance that a Client’s program will be successful or that investments purchased by a Client will increase in value. All prospective Clients or investors in a Client should consult their own legal, tax and financial advisors prior to investing in a Client or engaging the Adviser’s investment advisory services. Reliance on Key Management Personnel The success of a Client will depend, in large part, upon the skill and expertise of the management of the Adviser. There is no assurance that the members of the Adviser’s investment committees or other key members of the management of the Adviser will continue to be employed by the Adviser for any period, or that the Adviser will be able to attract, develop, integrate and retain replacements or additional employees when needed. In the event of the death, disability or departure of any of such individuals, the business and the performance of a Client may be adversely affected. In addition, investors in Clients will have no opportunity to control the day-to-day operations, including investment and disposition decisions. Nor will they have an opportunity to evaluate for themselves the relevant economic, financial and other information regarding investments to be made by the Adviser on behalf of such Client. Accordingly, Clients will be dependent upon the judgment and ability of the Adviser in investing and managing the Clients. General Economic and Market Conditions The success of the Adviser’s activities is affected by general economic and market conditions, which are generally unpredictable and can be caused by a variety of economic, social, political, military, climatic and other factors. The Adviser’s investment advisory activities and operations, or the activities and operations of a Client, Client portfolio company or service provider, are subject to risks associated with unforeseen or catastrophic events, including terrorist attacks, natural disasters, and the emergence

of a pandemic, which could create economic, financial, and business disruptions. These events could lead to operational difficulties that could impair the ability to continue such activities and operations. Catastrophic events have created, and continue to create, economic and political uncertainties and have contributed to global economic instability. Future terrorist activities, military or security operations, global health emergencies or natural disasters could further weaken the domestic/global economies and create additional uncertainties, which may negatively impact the businesses in which Clients invest directly or indirectly and, in turn, could have a material adverse impact on Clients. Losses from terrorist attacks, global health emergencies and natural disasters are generally uninsurable. From time to time, countries have experienced outbreaks of infectious illnesses. Any spread of an infectious illness, public health threat or similar issue could reduce consumer demand or economic output, result in market closures, travel restrictions or quarantines, and generally have a significant impact on a particular country’s economy, which in turn could adversely affect Client investments. Epidemic or Pandemic Considerations Any public health emergency, including any outbreak of COVID-19, SARS, H1N1/09 flu, avian flu, other coronavirus, Ebola or other existing or new epidemic diseases, or the threat thereof, could have a significant adverse impact on the Fund and its investments and could adversely affect the Fund’s ability to fulfill its investment objectives. The extent of the impact of any public health emergency on the operational and financial performance of the Adviser or any Client will depend on many factors, including the duration and scope of such public health emergency, the extent of any related travel advisories and restrictions implemented, the impact of such public health emergency on overall supply and demand, goods and services, investor liquidity, consumer confidence and levels of economic activity and the extent of its disruption to important global, regional and local supply chains and economic markets, all of which are highly uncertain and cannot be predicted. The effects of a public health emergency may materially and adversely impact the value and performance of a Client’s investments as well as the ability of the Client to source, manage and divest investments and achieve its investment objectives, all of which could result in significant losses to the Client. In addition, the operations of each of the Client, its investments and Monarch may be significantly impacted, or even halted, either temporarily or on a long-term basis, as a result of government “shelter in place” or “stay at home” orders and directives, quarantine and curfew measures, voluntary and precautionary restrictions on travel or meetings and other factors related to a public health emergency, including its potential adverse impact on the health of any such entity’s personnel. Geopolitical Risks and Other Business Interruptions The Adviser’s investment advisory activities and operations, or the activities and operations of a Client portfolio company and service providers, could be interrupted or adversely affected by extraordinary events or emergency situations, including, without limitation, outbreaks of infectious diseases, epidemics or pandemics, war, terrorism, failure of technology, disasters,

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The Adviser manages pooled investment vehicles that permit investment only by sophisticated investors that are typically institutional investors or high net worth individuals. A description of each Client, including its operation and activities, management fees, performance-based fees/allocation, where applicable, and structure can be obtained from such Client’s Governing Documents. Other than for limited discretion advisory services, the Adviser generally requires that any new Third Party Fund seeking the Adviser’s exclusive management commit to invest or subscribe for no less than $100 million. Such Clients are generally required to maintain a minimum amount of assets to retain eligibility for such advisory services. The Adviser or its related persons have entered into and in the future expect to enter into side letters or other similar agreements with investors in a Fund that have the effect of establishing rights under, or altering or supplementing the terms of, that Fund’s Governing Documents. Such rights or terms in any such side letter or other similar agreement are not subject to approval by the Funds’ other investors and have included and may in the future include, among other things, (i) different liquidity or notice periods, minimum investment amounts or fees or incentive allocations, (ii) excuse rights applicable to particular investments (which may increase the percentage interest of other investors in, and contribution of obligations of other investors with respect to, such investments) or expenses, (iii) the agreement of the Adviser or its affiliates to extend certain information rights or additional diligence, valuation or reporting rights to such investor, including, but not limited to, accommodating special regulatory or other circumstances of such investor, (iv) additional obligations and restrictions on the Adviser or its affiliates and the Fund with respect to the structuring of investments in light of the legal, tax and regulatory considerations of such investor, (v) different levels of preferred return and/or different claw back arrangements, (vi) other rights or terms in light of particular legal, regulatory, public policy or other characteristics of such investor, or (vii) confidentiality of investor information and dispute resolution. Monarch generally expects that side letters may be entered into with larger or legacy investors and investors with obligations to comply with specific regulatory or internal policy requirements, as well as with such other investors as the Adviser may deem appropriate. Investors who have side letters or similar arrangements may make independent investment decisions based on the information obtained pursuant to those arrangements. The terms of any such side letter or agreement generally will not be disclosed to other investors unless the Adviser or its affiliates have specifically agreed to do so with another underlying investor or as may be required by applicable law. The terms and conditions of certain side letters or similar arrangements differ with respect to material terms and confer favorable rights or waive obligations for investors with such letters.

The Adviser (or its affiliated entities) charge performance based fees or allocations that are based on a share of capital gains or capital appreciation of a Client’s assets. As a general matter, any performance based fees charged to a Client must comply with the requirements of Section 205 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and the rules thereunder. The amount, if any, of incentive fee or allocation to which Clients are subject varies. For example, some Clients have lower management fees but higher incentive fees or allocations than other Clients. In addition, incentive fees or allocations may be paid by Clients at different times such as annually or upon distributions exceeding various thresholds. Any given fee arrangement may be more or less advantageous depending on performance and timing of distributions. Prospective investors or Clients should note that incentive fees or allocations may create an incentive for the Adviser to select riskier or more speculative investments than would be the case in the absence of such compensation. Potential conflicts of interest may also arise with the allocation of limited investment opportunities to the extent that the Adviser may have an incentive to allocate investments that are more likely to generate excess distributions but that are also riskier or are expected to increase in value to principal accounts or preferred Clients, including Clients with higher incentive fee or allocation structures. Compensation paid by co-investors creates an incentive for the Adviser to favorably allocate investments to such third parties. The compensation arrangements referred to in this section present potential conflicts when the Adviser’s interests may not be or may not be perceived to be aligned with the best interests of one or more of its Clients or their underlying investors. Improper activity could manifest itself in the form of inappropriate recommendations or investments allocated to certain Clients because the Adviser hopes the Client will attract additional investors or because it has been underperforming in an investment strategy. In addition, the Adviser will face a conflict of interest when pricing a position because marking it down could cause (i) a decline in a Client’s performance and a decrease in fees to the Adviser or (ii) an increase in performance volatility, which can make the Client potentially less attractive to existing and prospective investors. In its efforts to address these conflicts, the Adviser has implemented a trade allocation and aggregation policy, which is available to investors and potential investors for review upon request, that together with procedures adopted thereunder mitigate the risk that investment opportunities are allocated other than fairly among Clients, proprietary accounts and co-investment vehicles. These policies and procedures take into account variations in investment programs, objectives, restrictions, liquidity, available purchasing power (e.g., cash and available borrowings), portfolio balance, anticipated inflows/outflows and other factors, but do not permit consideration of a Client’s performance fee or incentive arrangement. As a general matter, allocations are subject to the Adviser’s policy of generating capital for Clients with upcoming redemptions or distributions and investing capital of new Clients or those with excess liquidity resulting from in-flows. Clients may invest through special purpose vehicles to enhance the Adviser’s ability to allocate opportunities in furtherance of this policy, among other things. The Adviser’s compliance department regularly reviews Client transactions to confirm that allocations are done in a fair manner and in accordance with the Adviser’s policies and procedures. The compliance department seeks the input of the Chief Financial Officer and Chief Executive Officer, or members of their teams as needed. The Adviser has also adopted a valuation policy, which is available to investors and potential investors for review upon request, which together with procedures adopted thereunder mitigate the risk that investments are improperly marked. The policies and procedures

provide for regular review and testing of pricing. Valuations of Client investments, which will affect the amount of management and incentive fees or allocations, may involve uncertainties and judgment determinations, and if such valuations should prove to be incorrect, Client net asset value could be adversely affected. Other than as required by U.S. GAAP, the Adviser does not generally make retroactive adjustments to valuations to reflect new valuation information after a pricing period has closed, even though such information may result in more reliable pricing. Where Clients invest together in the same portfolio companies the applicable investment restriction or guidelines of a Client that is most restrictive will impact the terms or manner in which other Clients can invest. Such restriction may be detrimental to such other Clients. For example, one Client has certain limitations regarding portfolio company indebtedness. Accordingly, with respect to any investment in which such Client invests alongside another Client, the other Client’s financing options at such portfolio company may be limited by such restriction, which may increase the cost of financing or cause such Client’s investments to incur a lower overall level of financing than it would have absent such restriction. The Adviser, its affiliates and their respective employees hold investments in various Clients that may be disproportionate both in absolute terms and relative to each Client's capital account balances. The existence of such disproportionate holdings may create an incentive for the principals and employees of the Adviser to devote a more significant portion of their time and attention to the investment programs of Clients in which the Adviser, its affiliates and their respective employees hold larger investments in absolute or relative terms. In addition, such disproportionate holdings may create an incentive for the Adviser to make investments that are more conservative or aggressive on behalf of a Client than would be the case in the absence of such disproportionate holding, which may result in reduced returns for such Client. A Client and/or one or more other Clients that have invested side-by-side may be required to liquidate their investments, including, for example, due to the exercise by their respective investors of their right to dissolve such Client. In the case of a dissolution, this may require the selling of the Client's investments under circumstances that may negatively affect returns. Where another Client that has invested alongside a Client is forced to liquidate its investments, such liquidation may also negatively affect the value of the Client's investments and/or the circumstances of their disposition, which could negatively affect the Client's returns. In addition, other Clients that have invested side-by-side with a Client may voluntarily sell or otherwise dispose of their investments, including, for example, in order to generate liquidity, to fulfill contractual commitments to exit certain investments by a specified date or under specified circumstances. The market impact associated with such sales or dispositions by other Clients may adversely affect the ability of the Client to liquidate its position in the same or similar investment, the price at which such liquidation occurs, or, where the Client does not liquidate its position, the mark-to-market value of such position. Where the Adviser is presented with limited disposition opportunities, the Adviser may also take into account the liquidity needs of each Client, including the need to generate capital for Clients with upcoming redemptions or distributions, which may result in a Client's exit from an investment in a less advantageous manner than would otherwise occur. From time to time Clients invest in parts of an issuer’s capital structure different than those held in another Client’s portfolio or such investments are made in different relative amounts. The Adviser acknowledges there may be conflicts of interest in managing such investments, especially in distressed situations. For example, the Adviser from time to time appoints personnel to serve

on various committees (generally unofficial), including creditor ad hoc committees, creditor steering committees, equity holders’ committees or other groups to ensure preservation or enhancement of a Client’s position as a creditor or equity holder in bankruptcy or insolvency proceedings or otherwise be engaged in financial restructuring activities in a variety of capacities. Such activities may result in the Adviser receiving confidential information that may, as a result of applicable securities laws or the internal policies of the Adviser, limit or otherwise constrain the Adviser’s flexibility in purchasing or selling securities or other obligations with respect to other Clients’ portfolios. In an effort to avoid such restrictions or limitations, the Adviser may elect not to receive confidential information, which may be relevant to a Client’s portfolio, that other market participants are eligible to receive or have received. Clients may also invest in instruments issued directly or indirectly by portfolio companies in which other Clients have an economic interest, such as finance vehicles. In such cases the decision to invest in a financing vehicle such as a securitization may conflict with the decision by a portfolio company to obtain financing by way of such vehicle. Certain portfolio companies will in the ordinary course of their business provide services or sell goods to, receive services or goods from, lease space to or from, or participate in agreements, transactions or other arrangements with (including the purchase and sale of assets and other matters that would otherwise be transacted with independent third parties) other portfolio companies, which will not be owned by the same Clients or the ownership among Clients will not be in the same proportion. These transactions or arrangements will involve the payment or receipt of money or other benefits. In certain cases, an investment thesis regarding a portfolio company will contemplate facilitating a relationship with another portfolio company. Any such transaction or arrangement may be entered into with the active participation of the Adviser. To the extent of any such participation, the Adviser will face a conflict if it stands to earn more fees in connection with Clients more weighted to one portfolio company over another.

Certain affiliates of Monarch serve as general partners, administrative general partners and commodity pool operators to Funds. As general partners these affiliates receive performancebased compensation from such Funds. Monarch’s wholly-owned subsidiary, Monarch Alternative Capital (Europe) Ltd (“Monarch UK”), provides research services to Monarch and is registered with the Financial Conduct Authority in the United Kingdom. Monarch UK shares the same control persons as the Adviser and either shares the same named officers as the Adviser or the named officers of Monarch UK are subject to the supervision of, and report to, the Adviser’s executive officers. In addition, Monarch UK has limited discretion to execute trades on behalf of Clients. As set forth in Schedule R of Part 1A of this Form ADV, Monarch and Monarch UK are together filing this single Form ADV and Monarch UK as the relying adviser is thus considered to also be registered with the SEC on this Form ADV. Monarch has claimed an exemption from registration with the CFTC with respect to its status as a commodities trading advisor pursuant to CFTC Rule 4.14(a)(8) and it, along with certain affiliates operate collective investment vehicles pursuant to an exemption from CPO registration under CFTC Rule 4.13(a)(3). As part of the Adviser’s business, the Adviser and its employees maintain or have developed various relationships with third parties that have the potential to raise conflicts of interest. Such relationships may be professional, personal or familial, working, economic or a mixture; such third parties include, but are not limited to, valuation agents, administrative agents and sub-agents, administrators, lenders, investment bankers, broker-dealers, title companies, appraisers, restructuring and other advisers (such as attorneys, investment bankers and accountants), turnaround specialists, placement agents, consultants, and other service providers, vendors to and operators of portfolio companies, investors in the Clients, co-investors, and current and former employees of the Adviser. Certain of such third parties will: introduce investment opportunities or investors to the Adviser; provide investment banking, directorship, consulting, advisory or operational support services to the Adviser or an affiliate, the Clients or portfolio companies; invest in Clients (including, in the case of current and former employees or other related parties, on a no fee, no carry basis); co-invest in portfolio companies; themselves be portfolio companies of one or more Clients; provide prime brokerage or other significant business or investment services to or otherwise transact with the Adviser, the Clients and portfolio companies. Such third parties will in certain cases receive direct commercial compensation from a portfolio company, a Client (including a Client that does not hold an investment in such third parties) or the Adviser (or its affiliate) for providing these services, which compensation and services are intended to be on an arm’s-length basis and, except as specifically noted to the contrary, such amounts are not offset against the management fee of the relevant Client. The Adviser seeks to reduce potential conflicts of interest resulting from such arrangements by structuring compensation packages for such persons in a manner that the Adviser believes will align with the best interests of the Clients, and seeks to retain only consultants and service providers which it believes provide a level of service at a value generally consistent with other relevant market alternatives. However, there can be no assurance that no other service provider is more qualified to provide the applicable services or could provide such services at a lesser cost. Where such third parties are portfolio

companies of a Client, the Adviser faces a conflict when determining whether to retain such third parties to act on behalf of that and other Clients, as the compensation paid to such third parties will benefit the Client holding an ownership interest in such third parties and could result in additional fees for the Adviser. In addition, the Adviser faces a conflict when allocating among Clients in light of the fact that certain of their investors, particularly large financial institutions, provide the Client(s) or the Adviser with prime brokerage or banking services. The Adviser also faces a conflict when determining the suitability of available investment opportunities for its Clients where the Adviser’s personnel have a personal interest in a service provider engaged for the purpose of offering the Adviser investment opportunities or advising on portfolio investments.

Monarch has adopted a Code of Ethics designed to address actual and potential conflicts that may arise from personal trading or other activities by Adviser personnel. Among other prohibitions and requirements set out in the Code of Ethics, Adviser personnel are generally not permitted to purchase or sell any security held by, or recommended to, Clients at the time of the contemplated transaction or at any time in the preceding sixty days. From time to time, the Chief Compliance Officer may direct or permit Adviser personnel to transact in an issuer in respect of which a Client has an interest, where such transaction is determined to be in the best interest of such Client because it would, for example, mitigate or alleviate a conflict of interest. Similarly, where there is unlikely to be any meaningful conflict (e.g., broad-based ETFs), the Adviser categorically permits such trading. Additionally, Adviser personnel are required to obtain prior approval from the Chief Compliance Officer (or his designee) and applicable members of the Adviser’s investment committees before placing covered personal trading orders (i.e., most trades other than mutual funds or broad-based ETFs). Duplicate transaction statements related to personal trading in securities of certain of the Adviser’s personnel are provided to the Adviser’s compliance department by the broker with whom such personnel maintain a covered securities trading account (i.e., one that is not limited to mutual funds or certain other exempt securities) via an electronic feed to the Adviser’s personal trading compliance system, or, in certain circumstances, they may be forwarded by such broker or the relevant personnel directly to the Adviser’s compliance department. The Adviser or certain of its personnel also regularly receive or provide usual and customary business meals, business entertainment, or gifts from or to persons with whom the Adviser does business. The Adviser has adopted procedures within its Code of Ethics that it believes are reasonably designed to help ensure that such activities do not affect its judgment on issues relating to managing Client accounts (for example, issues relating to the best execution of Client trading orders) and do not improperly influence third parties. Included in the Adviser’s Code of Ethics and in other written policies, are policies that the Adviser maintains regarding the use and dissemination of material non-public information. Such policies seek to monitor and control the flow of material non-public information with the aim of avoiding any misuse, whether by way of trading or disclosure. As a part of the Adviser’s policies and procedures, the Chief Compliance Officer maintains a list of issuers about whom the Adviser may possess material non-public information or other confidential information (from whatever source) as well as the names of issuers in respect of which the Adviser may have agreed to a trading restriction or otherwise became restricted (the “Restricted List”). Depending on the particular circumstances, the Restricted List will subject identified instruments to certain trading restrictions or pre-clearance requirements, including restrictions on personal securities transactions. Trading by Clients in instruments on the Restricted List is monitored by the Adviser’s compliance team. Subject to any exceptions granted by the Chief Compliance Officer (or his designee), the policies and procedures described above and contained in the Code of Ethics will be strictly enforced. If you would like to receive a copy of the Adviser’s Code of Ethics, please contact us at 212.554.1700 or via email IR@monarchlp.com.

The Adviser does not, in the ordinary course, purchase or sell investments for or to its Clients from itself or its related persons. The Adviser and its related persons have, however, in limited circumstances, engaged in such principal transactions with Client consent in order to provide liquidity to a Client at or near the end of its term. The Adviser or its related persons may do so in the future. Clients may purchase or sell assets from or to one another. To-date, Clients have transacted directly with each other only under certain special circumstances, such as bringing a recently formed Client into a recent illiquid investment where it was contemplated by the Adviser that such Client would participate in such investment or where the cross trade was executed on a consentedto basis. Such cross trades may be executed at cost plus an agreed upon rate as set forth in a Client’s Governing Documents; also, such cross trades have been and may in the future be executed on the basis of fair market value in accordance with the Adviser’s Valuation Policy, which is available for review upon request. Clients are permitted to, directly or indirectly, sell investments to or buy investments from other Clients (any such transaction, a “Cross Transaction”). In addition, and without limitation, a Client could enter into transactions in which investments held directly or indirectly by such Client are (i) pooled and securitized and one or more other Clients acquire interests (directly or indirectly) in one or more tranches of such securitized vehicle, or (ii) are exited or realized in connection with a refinancing or recapitalization transaction in which other Clients are a source of capital, or, in each case, vice versa. Clients may also participate in rebalancing or other trades with other Clients from time to time, in respect of one or more investments in which Clients hold or may in the future hold an interest. Such trades may be effectuated in respect of investments held directly or through one or more special purpose vehicles that enable the rebalancing, allocation or transfer of underlying opportunities among Clients invested in such special purpose vehicles, or they may be effectuated directly with an issuer/borrower. Various conflicts of interest exist in connection with Cross Transactions because there is no assurance that any Client will receive the best price otherwise possible, or that the Adviser or its affiliates will not have an incentive to seek to improve the performance of one Client even if it is at the expense of another Client, including by selling underperforming assets in order to, for example, avoid losses in a selling Client or to increase the fees payable by Clients acquiring or gaining exposure to the assets. The Adviser, its affiliates and employees may receive significant economic benefits as a result of a Cross Transaction, including receiving a portion of any profits earned by selling Clients as carried interest, a favorable return on their capital invested in such selling Client (if any), management fees from purchasing Clients and, depending on investment returns, a portion of the profits earned by a purchasing Client as carried interest. In addition, the Adviser and its affiliates and employees may hold significant direct or indirect interests in one or more Clients participating in a Cross Transaction and could be incentivized to make decisions that benefit such Clients at the expense of other Clients. In order to determine that pricing is on an arm's length basis and that a Cross Transaction or other conflicted transaction is in the best interest of all relevant Clients, the Adviser may (but is not required to) take one or more of the following actions: (i) pricing based on the Adviser's valuation policies and procedures (including reviews of comparable market data and the Adviser's own experience as a buyer or seller of similar assets), (ii) ensuring the presence of or participation by unaffiliated third parties to help validate the pricing and other terms of such transaction, or (iii) running an auction or other competitive process. In respect of certain Cross Transactions or principal transactions, the Adviser may obtain independent

third party fair valuation services, although it is not required. Such services cannot guarantee that any such transactions are effectuated at a fair price nor do they ensure that such transaction is appropriate for any Client. Costs associated with third-party valuation services and any other incremental costs and expenses associated with any Cross Transaction or principal transaction will be allocated as fund expenses in accordance with the Adviser's expense allocation policy in effect at such time. As a result, the Fund and/or other Monarch Funds could bear the entirety of the costs and expenses associated with a Cross Transaction or a principal transaction, even though Monarch will also benefit economically from such transaction. Nonetheless, one Client could be advantaged or disadvantaged to the detriment or benefit of another Client in the event that the investment being exchanged is not fairly priced or presents a more or less appealing opportunity. There can be no assurance that any conflicts of interest arising as a result of any Cross Transaction will be resolved in a manner that is fair and equitable to each Client. No fees will be charged by the Adviser or its affiliates to Clients in connection with the completion of a Cross Transaction; however, the purchasing Client may pay fees to the Adviser for managing the asset that are higher than those paid to the selling Client. A Cross Transaction may constitute a principal transaction due to the ownership interest in a Client by the Adviser or its personnel. In such cases, consent from the Client will be obtained in compliance with Section 206(3) of the Advisers Act. In respect of any principal transactions required to be consented to under applicable law, certain Clients may provide any such consent through their limited partner advisory committees. Certain investments are made through special purpose vehicles that enable the allocations of underlying opportunities on a non-pro rata basis among Clients invested in such special purpose vehicles. The Adviser has adopted a policy regarding the allocation of trades through such vehicles that is set forth in its Aggregation and Allocation Policy, which is available for review upon request. To facilitate the implementation of Client investment strategies, the Adviser uses certain special purpose trading vehicles, from which it does not collect any incremental management fees or incentive fees or allocations (on a net basis), through which Clients invest. In addition, from time to time the Adviser causes Clients to purchase or sell instruments issued by companies on which its personnel serve as board members or in other similar capacities. To the extent the Adviser or its personnel receive any fees related to such service, such fees are netted from management fees owed by the Clients, unless otherwise agreed with a Client. Please see the response to Item 5 for additional information on fee offsets. The Adviser may recommend to Clients the purchase or sale of instruments of an issuer in which the Adviser or its related persons, may also invest or currently be invested. However, as a general matter, Adviser personnel are not permitted to trade in securities held by a Client (as described in more detail above). Principals, officers or employees whose primary responsibilities are portfolio management, research analysis or trade execution may, subject to limitations in the Adviser’s Code of Ethics, engage in personal securities transactions where the underlying traded security is within his or her sector of coverage. This personal trading can create a conflict of interest due to the perception that the Adviser is expending Client resources researching a particular investment or recommending a particular investment transaction because of a financial interest held in the underlying security by the Adviser, its affiliates, personnel or related persons. The Adviser has adopted policies and procedures reasonably designed to ensure that its activities are carried out in compliance with applicable regulatory requirements and to minimize potential conflicts of interest (e.g., review of Client transactions by the Adviser’s compliance department, prior employee trade approval from its Chief Compliance Officer (or his designee) in regard to personal securities

transactions, etc.). The Adviser has no obligation to recommend for purchase or sale by advisory Clients any investment that the Adviser, its affiliates, personnel or related persons purchase or sell for themselves.

The Adviser selects brokers, dealers, banks and other financial intermediaries to effect transactions for Clients on the basis of a variety of factors, including but not limited to the following: the ability to effect prompt and reliable executions at favorable prices; the operational efficiency with which transactions are effected; the financial strength, integrity and stability of the executing party; the quality, comprehensiveness and frequency of available research services considered to be of value; the availability (or lack of availability) of the investment; and the competitiveness of commission rates in comparison with other brokers satisfying the Adviser’s other selection criteria. Based on the applicable investment strategy, a limited universe of execution parties may be able to offer investments or provide bids for existing Client positions. In such cases, the executing party offering the investment or making a bid may represent the only execution party for such transaction and would therefore be “best execution.” Research services furnished by brokers may include written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; statistics and pricing or appraisal services, as well as discussion with research personnel. The Adviser is authorized to pay higher prices for the purchase of financial instruments from, or accept lower prices for the sale of such instruments to, firms that provide it with such investment and research information or to pay higher commissions to such firms if the Adviser determines such prices or commissions are reasonable in relation to the overall services provided. In addition, the Adviser has and expects to continue to select such brokers from time to time to execute trades in financial instruments other than those in respect of which it received research from such broker, as it deems necessary or appropriate to provide compensation for such research. As a result, any given Client could pay trade compensation for the benefit of research in respect of an opportunity in which it will not participate. Soft dollar research services may include research reports on companies, industries, and securities; economic and financial data; financial publications; proxy analysis; trade industry seminars; computer databases; quotation services; and research oriented software and other services. Research services provided by firms for one or more Clients may be utilized by the Adviser in connection with its investment services for other Clients. The Adviser may endeavor to direct sufficient commissions and commission equivalents to firms that, pursuant to such arrangements, provide research services in order to ensure the continued receipt of services the Adviser believes are useful in its investment decision-making process. To the extent the Adviser receives research services with soft dollars, it may reduce its need to pay for such services with its own assets. The Adviser also pays for research in “hard dollars”, which are reimbursed to the Adviser by the Clients. Any management fees and performance-based compensation paid to the Adviser are not reduced as a result of the receipt of brokerage or research services. Certain Third Party Funds have in the past and may in the future limit the counterparties with which the Adviser may enter into certain transactions on their behalf. From time to time, brokers (including prime brokers) may assist Clients in raising additional funds from investors, and representatives of the Adviser may speak at conferences and programs sponsored by such brokers for potential investors interested in investing in private funds which are sponsored by one of the Clients’ prime broker or custodians or another third party. Through such “capital introduction” events, prospective investors in a Fund would have the opportunity to meet with representatives of the Adviser. Currently, none of the Adviser or the Clients compensate or intend to compensate any such brokers or custodians or other third parties for organizing such

events or for any investments ultimately made by prospective investors on account of attending such events, although they may do so in the future. While such events and other services provided by a broker may influence the Adviser in deciding whether to use such broker in connection with brokerage, financing and other activities of a Client, the Adviser will not commit to allocate a particular amount of brokerage to a broker in any such situation. Moreover, the Adviser and not the Client may be the principal beneficiary of those services. The Adviser’s personnel also may receive gifts and gratuities from executing counterparties. These gifts may include tickets to sporting events, meals and other entertainment, transportation, attendance at seminars or other educational training or informational events, logo items and other gifts that may be of substantial value. It is the Adviser’s policy that gifts or entertainment of substantial value be reported to the Chief Compliance Officer or his designees. The Adviser manages Clients that share similar, but not identical, investment strategies and objectives. As a result, any particular investment may be deemed suitable for one or more Clients, but not others. To the extent a particular investment is deemed to be generally suitable for more than one Client, the Adviser generally endeavors to allocate such investment pro rata to such Clients based on assets under management, however, various considerations routinely require a different allocation that the Adviser determines is fair under the circumstances to all Clients. For example, among others, the Adviser considers each Client’s investment strategy, current risk profile, exposure to similar investments, availability of cash, liquidity need, ability to borrow and cost of borrowing. In addition, a Client’s tax or regulatory status may prevent an allocation or change the nature or terms of the investment, as may particular restrictions placed by a Client or investors in a Fund. The Adviser may also determine that a particular pro rata allocation is too small to be meaningful or economic, or needs to be increased to avoid “odd-lots” or “minimum trading lots”. Where more than one Client participates in an acquisition or disposition of an investment, the Adviser generally aggregates the purchase or sale among its Clients in a manner that would not give preferential treatment to any single Client. If all such transactions are not filled at the same price, Clients will, subject to certain exceptions set forth in the Adviser’s Aggregation and Allocation Policy, receive an average of the prices for all transactions in that investment for a given business day.

Other than as stated elsewhere in this brochure, no other persons, other than Clients, provide any economic benefit to Monarch for providing investment advisory services to its Clients. Certain service providers to a Client or its portfolio investments (or portfolio companies themselves) also have relationships with, provide or have provided goods or services to, or are owned by, Monarch personnel or organizations in which they have an interest, or other Clients or their portfolio investments. For example, the Adviser’s personnel have an interest in service providers engaged by the Adviser or its Clients whereby the service provider offers the Adviser or its personnel investment opportunities or investment advice in respect of portfolio investments. In some cases, these service providers (or portfolio companies) provide discounts on services for one or more of these parties. In addition, the Adviser has an interest in retaining service providers that are portfolio companies of a Client to perform services for that Client and other Clients, as amounts paid to such service provider by Clients will benefit the Client holding an ownership interest in such service provider and could result in additional fees for the Adviser. The Adviser has entered into and may in the future enter into certain solicitation arrangements for the purpose of introducing investors to the Funds. Pursuant to such arrangements, Monarch may make cash payments to the solicitor that constitute a portion of the fees that Monarch receives from each Fund investor referred by such solicitor. Such payments may also be made by such Funds, which will then be reimbursed by Monarch, including by way of a management fee credit. Such Fund investors will not be charged extra fees by Monarch, although they may pay fees directly to such solicitor.

The Adviser is committed to observing the highest standards of integrity and regulatory compliance in all aspects of its work. The Adviser does not have any legal or disciplinary events that are material to the evaluation of the Adviser’s advisory business or the integrity of the Adviser’s management.

The Adviser generally holds daily meetings, which all investment professionals are required to attend and which are also attended by many non-investment professionals, to review recent transactions, present new ideas and review developments on current investments. In addition to these scheduled daily meetings, members of the Adviser’s investment committees review Client accounts on a regular basis. While Clients generally hold debt investments until the completion of a restructuring or bankruptcy or other value creating event and post-restructuring equities until their market price reflects the investment team’s view of the equity’s fundamental value, the Adviser is responsive to changes in the relevant investment thesis that may prompt a sale at an earlier date. Members of the investment team monitor a real-time database of credits, and other micro- and macro-economic data to inform the members of the Adviser’s investment committees of any changes that may affect portfolio decisions. In addition, the Adviser’s personnel produce a variety of periodic, typically monthly, metrics to track the breakdown of Clients’ accounts across capital structure, instrument type, industry and geography. The Chief Compliance Officer (or his designee) in conjunction with the Adviser’s back-office staff conducts periodic trading reviews and monitors compliance with various Client investment guidelines and the Adviser’s allocation policies. Special reviews of Client accounts may also occur upon the occurrence of certain events, for example an event that disproportionately impacts a particular Client portfolio. Third Party Funds generally receive transactional reporting at or near the time that trades are executed and are afforded full transparency to the relevant account’s portfolio composition. Subject to specially negotiated arrangements, which may provide additional disclosures, investors in Funds generally receive regular estimated performance reports from the Adviser, monthly or quarterly statements from the administrator and annual audited financial statements. In addition, the Adviser generally provides Fund investors quarterly investor letters that include some performance attribution information. Moreover, the Adviser regularly makes its investor relations staff available to address Client inquiries as well as inquiries from underlying investors. Finally, the Adviser has hosted annual investor meetings and may do so in the future.

The Adviser generally does not maintain direct custody of any Client’s assets. However, Rule 206(4)-2 under the Advisers Act, broadly defines “custody” to also include holding indirectly Client funds or securities, or having any authority to obtain possession of them. As a result, the Adviser is considered to have custody of Client assets because the Adviser or its related persons serve in a capacity that gives them legal ownership of or access to each Client’s funds or financial instruments or because the Adviser is authorized under the Client’s Governing Documents to withdraw the Client’s funds or financial instruments maintained with a third-party custodian upon instruction to the third-party custodian. Third Party Funds have previously entered and may enter into advisory arrangements that do not give rise to such custody over certain of the Third Party Fund’s assets. In accordance with Rule 206(4)-2, for each Client where the Adviser is considered to have “custody” of its assets, that Client’s financial statements are subject to an annual audit conducted by an independent registered public accounting firm in accordance with U.S. GAAP and delivered to the underlying investors within 120 days of the Client’s fiscal year end. Investments held in special purpose vehicles over whose assets the Adviser may be deemed to have “custody” are included in such audited financial statements and are generally not separately audited. Underlying investors of any Client are encouraged to review the financial statements carefully.

In most cases, Clients grant the Adviser discretionary trading and investment authority. Any limitations on this authority are set out in each Client’s Governing Documents. Generally, such limitations are not limited to absolute restrictions but rather constitute investment directives and guidelines that the Adviser follows in the exercise of its discretion. Certain Clients, however, have established and may in the future impose absolute restrictions on the Adviser’s investment discretion. Please refer to Item 4 for additional information.

The Adviser has the power to vote Client securities and other instruments and Clients generally may not direct the Adviser’s vote in a particular situation. Generally, the Adviser votes all of its Clients’ instruments in the same manner. The Adviser’s policy is to vote in a manner that serves the best interests of its Clients overall. In the case of debt instruments, voting items typically pertain to amendment and consent requests, and bankruptcy or reorganization proposals. Clients do not always hold identical positions in an issuer, and as a result, a conflict may arise in respect of voting. In determining how to vote any proxy, the Adviser will consider the aggregate impact on the value of Client holdings, the anticipated costs and benefit, including, among other things, the effect on liquidity. A conflict may also arise between the interests of Monarch and one or more of its Clients. If such a conflict arises, the Adviser may abstain from voting, vote as recommended by a third party service that the Adviser may choose to employ, or take such other action as mandated by its proxy policy, including voting as it, in good faith, determines is most fair and equitable. A copy of the proxy policy will be provided to any Client upon request. All Clients are also entitled, upon request, to the record of proxies received and voted on their behalf by the Adviser since adoption of the policy. To receive a copy of the proxy policy or information as to how proxies were voted, please contact us at 212.554.1700 or via email at IR@monarchlp.com.

Not applicable.