RLH Capital LLC

RLH Capital, LLC is a Delaware limited liability company with its principal office and place of business at 119 Hicks Lane, Great Neck, New York 11024. The Adviser is registered with the SEC as an investment adviser. Mr. Louis Camhi serves as the Adviser’s Managing Member and Chief Compliance Officer. Mr. Camhi is responsible for day-to-day investment management and oversight of the Adviser’s private fund platform. The Adviser provides discretionary investment management services exclusively through pooled investment vehicles. The Adviser’s current platform consists principally of RLH Series Fund, LP, a Delaware limited partnership established with multiple protected and/or registered series, and RLH Spac Fund, LP, a Delaware limited partnership focused on special purpose acquisition company and related event-driven strategies. The Adviser’s primary advisory relationship is with the funds and series themselves, rather than with underlying investors individually. The Adviser does not provide individualized financial planning or separately managed account advice to the limited partners of the funds by reason of their investments. RLH Series Fund, LP is structured as a multi-series private fund. The Adviser may establish protected and/or registered series and, if appropriate, one or more classes within a series. Each series is intended to constitute a separate and distinct pool of assets and liabilities under Delaware’s series partnership statute and to be treated as a separate and distinct partnership for U.S. federal income tax purposes. The series arrangement is a significant part of the Adviser’s business model because it permits the Adviser to launch discrete strategy sleeves with separate investor groupings, economics, and duration. An investor in a particular series is intended to be a partner only of that series and not of the master partnership or any other series solely by virtue of that investment. The Adviser’s core mandate through RLH Series Fund, LP is to pursue attractive returns by making loans and investing in securities on behalf of its series. The general strategy is to finance companies seeking to go public in the near to intermediate term, including companies involved in SPAC transactions or other public market pathways. The Adviser seeks opportunities where smaller financings and complex transaction dynamics may create pricing inefficiencies and more favorable deal terms. Within RLH Series Fund, LP, the Tactical PIPEs I Series is a distinct registered series formed to invest in private investments in public equity involving micro-cap through mid-cap public companies conducting capital raises to build or diversify crypto treasuries. The Tactical PIPEs I Series is designed to participate in PIPEs tied to the acquisition or integration of top-tier crypto assets, specifically including Bitcoin, Ethereum, Solana, and other leading cryptocurrencies by market capitalization. The Tactical PIPEs I Series is intended to focus on micro-cap through midcap U.S.-listed public companies pursuing a crypto treasury strategy. Crypto exposure is intended to be limited to Bitcoin, Ethereum, Solana, and a select group of high-liquidity, large-cap digital assets approved for the series, and the strategy is not intended to pursue illiquid or fringe tokens. The series is designed to target investments near net asset value, without lock-ups, and with a nearterm path to liquidity following SEC effectiveness of registration rights. A second strategy sleeve within RLH Series Fund, LP is the Special Opportunities I Series. This series follows a more concentrated special situations mandate focused on one or more loans to, or RLH Capital, LLC — Form ADV Part 2A | Page 4

securities of, companies seeking to go public in the near to intermediate term. The series may hold as few as one investment, and the ultimate allocation of the series will depend on available capital, timing, and the set of opportunities available when capital is called and deployed. RLH Spac Fund, LP is a separate private investment partnership focused on a diversified portfolio of instruments related to special purpose acquisition companies. Its objective is to maximize riskadjusted returns and preserve capital primarily by investing in SPAC units, common stock, warrants, and options. The fund may invest throughout the SPAC lifecycle—before a transaction announcement, between announcement and closing, and after closing—and may also use options, hedges, and related public-market techniques. The Adviser provides continuous and regular supervisory or management services solely to pooled investment vehicles. It currently advises three pooled investment vehicle clients and reports approximately $63.5 million of discretionary regulatory assets under management. Its compensation consists principally of a percentage of assets under management and performancebased compensation, and its advisory business is organized entirely around private funds and series rather than retail accounts or separately managed accounts.

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The Adviser is compensated primarily through management fees, performance-based compensation, and reimbursement or allocation of fund and series expenses. The fee structure differs by vehicle and, in the case of RLH Series Fund, LP, may differ by series. Because the Adviser’s compensation can increase with committed capital, deployed capital, capital account balances, and net profits, the structure creates important conflicts of interest, including incentives to raise and retain capital, to favor performance-fee-paying vehicles, to accelerate monetization or crystallization events, and to pursue investments with greater expected upside and greater attendant risk. For RLH Spac Fund, LP, investors are generally charged a management fee payable in advance each month equal to one-twelfth of 1.25% per annum of the investor’s capital account balance as of the beginning of the month. The management fee is therefore tied to monthly capital account value rather than to committed capital. The SPAC Fund also charges an annual performance allocation equal to 15% of each investor’s ratable share of partnership profits, but only to the extent such profits exceed the investor’s high-water mark. For RLH Series Fund, LP, the governing economics are series-specific. Investors in each series generally are subject to a management fee payable to the General Partner and also generally are subject to an allocation of series profits to the General Partner, but the precise management fee and carried interest terms can vary by series. In the Tactical PIPEs I Series, the management fee is 2.0% per annum during the investment period based on capital commitments and, after the investment period, 2.0% per annum based on unreturned capital contributions. The Tactical PIPEs I Series also uses specific capital funding mechanics relevant to the economic profile of the series. The minimum capital commitment is generally $100,000, subject to the General Partner’s authority to accept lesser amounts. Only 1.5% of the investor’s capital commitment is due at the applicable closing, with the remaining capital commitments funded later pursuant to capital call notices. The investment period runs for twelve months from the final closing date, no cost-of-carry contribution applies, and the General Partner may not retain net cash proceeds for reinvestment absent the written consent of each series limited partner. The Special Opportunities I Series uses a similar 2.0% annual management fee structure during the investment period based on capital commitments and, after the investment period, based on unreturned capital contributions. It includes an important variation: an amount equal to the first twelve monthly management fee payments is due upon the initial closing date in lieu of the first twelve monthly payments that otherwise would have been owed. That front-loaded fee is economically similar to an origination-style charge and increases the Adviser’s compensation earlier in the life of the series. In addition to management fees and incentive compensation, the Funds and Series bear a broad range of operating expenses. Depending on the applicable vehicle and transaction, these expenses may include organizational and offering expenses, legal, accounting, audit, tax, administration, custody, financing, research, travel, due diligence, broken-deal, data-processing, and other operating costs. A portion of a Series’ assets may remain uninvested for the purpose of paying such expenses. RLH Capital, LLC — Form ADV Part 2A | Page 6

For RLH Spac Fund, LP, selling commissions and referral fees may be paid in connection with the offering of partnership interests. A portion of the management fee and/or performance allocation may be remitted to third parties introducing limited partners to the partnership, or the General Partner may use its own resources to compensate such introducers. In addition, brokerage from partnership trades may be directed to broker-dealers that introduce limited partners to the partnership, subject to applicable law. Affiliated investment in the Funds also affects the economics. The General Partner and its affiliates, including Louis Camhi and other affiliated persons, are permitted to make capital commitments to the series, but are not required to do so. Partnership interests held by affiliated persons generally are not subject to the management fee or carried interest, although those affiliated investors share pro rata in other expenses and liabilities. As a result, the Adviser and its affiliates may participate in the same economic upside as outside investors without bearing the same fee burden. The fee structures described above also interact with the funds’ liquidity arrangements. Investors in RLH Series Fund, LP generally will not be permitted to withdraw capital from a series or redeem interests without the consent of the General Partner. In contrast, RLH Spac Fund, LP provides quarterly liquidity following an initial twelve-month lock-up period, subject to forty-five days’ notice and a general limit of 50% of a partner’s capital account balance as of any particular withdrawal date. Withdrawals before the end of the lock-up period may be permitted in the General Partner’s sole discretion, but the investor will generally be subject to an early withdrawal penalty equal to 3.0% of the withdrawal proceeds, which penalty becomes an asset of the partnership. The more restrictive liquidity profile of the series structure and the conditional liquidity profile of the SPAC Fund benefit the Adviser by reducing redemptions or by imposing costs on early exits while preserving management fee bases and, where applicable, the timing of incentive fee crystallization.

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Loss The Adviser employs a combination of fundamental analysis, event-driven analysis, capital structure analysis, opportunistic transaction review, and thematic market analysis in selecting and managing investments. Because the Adviser’s strategies focus on transactions surrounding publicmarket entry, SPAC combinations, PIPE financings, bridge loans, warrants, and other eventsensitive structures, the Adviser’s process emphasizes transaction-specific due diligence rather than benchmark-relative portfolio construction. The Adviser reviews publicly available disclosures, transaction documents, capital raising terms, trading dynamics, sponsor incentives, covenant packages, warrant coverage, registration-rights timelines, expected liquidity paths, and market appetite for the securities or financing structures involved. The Adviser also relies on the experience and judgment of Louis Camhi and on the Adviser’s relationships with bankers, syndicate desks, counterparties, issuers, and other market participants. RLH Series Fund, LP seeks to achieve attractive returns by making loans and investing in securities on behalf of its series. The general strategy contemplates financing companies that are seeking to go public in the near to intermediate term, including companies involved in SPAC transactions, and pursuing opportunities where smaller bridge financings and negotiated structures may permit enhanced pricing or structural protection. The Adviser may also use special purpose vehicles as part of its investment process. A series may invest through limited partnerships, LLCs, or other entities organized to hold portfolio investments. The principal reasons for using SPVs are to isolate liabilities and risks such as litigation exposure to a specific investment and to offer co-investment opportunities to strategic partners or affiliates. In some cases, the relevant series may not be the sole investor in an SPV and may not control all governance rights, which can introduce additional risk. Within RLH Series Fund, LP, the Tactical PIPEs I Series is a thematic strategy focused on PIPE transactions involving micro-cap through mid-cap public companies conducting strategic capital raises to build or diversify crypto treasuries. The strategy is limited to PIPEs involving the acquisition or integration of top-tier crypto assets, specifically Bitcoin, Ethereum, Solana, and other leading cryptocurrencies by market capitalization. The Tactical PIPEs I Series includes substantive guardrails. Target companies are intended to be U.S.-listed micro-cap through mid-cap public companies pursuing a crypto treasury strategy. Crypto exposure is intended to be limited to Bitcoin, Ethereum, Solana, and a select group of highliquidity large-cap digital assets approved for the series, with no intended exposure to illiquid or fringe tokens. The strategy also seeks PIPE investments at or near net asset value, without lockups, and with a near-term path to liquidity following SEC effectiveness of registration rights. The Tactical PIPEs I Series is intended to benefit from several perceived competitive advantages, including Louis Camhi’s experience advising on a comparable transaction, the Adviser’s relationships with crypto-native bankers, company management teams, and syndicate desks, and the Adviser’s broader capital markets experience. Those factors may improve sourcing and negotiation but do not eliminate investment risk. RLH Capital, LLC — Form ADV Part 2A | Page 10

The Special Opportunities I Series represents a concentrated special situations approach. It is designed to pursue investments in a portfolio of one or more loans to, or securities of, companies seeking to go public in the near to intermediate term. The portfolio may be comprised of as few as one investment, and the ultimate allocation of the series will depend on available capital, timing, and the opportunity set available when commitments are called and deployed. RLH Spac Fund, LP uses a different but related strategy set. Its objective is to maximize riskadjusted returns and preserve capital primarily by investing in a diversified portfolio of SPAC instruments, including units, common stock, warrants, and options. The Adviser seeks significant long-term capital appreciation while attempting to maintain a lower level of risk as measured by the volatility of returns. The SPAC Fund strategy includes several core sleeves: SPAC arbitrage through purchases of SPAC shares and units near trust value in primary offerings and secondary trading; purchases of pre-announcement warrants; post-announcement opportunities evaluated on a fundamental and/or technical basis, including both long and short positions; options strategies such as writing puts at trust value and covered calls; warrant arbitrage involving discounts to intrinsic value and hedging through short common stock or written calls; and PIPE investments undertaken before a transaction announcement. The Adviser’s methods of analysis do not eliminate the risk of loss. Each RLH Series Fund series may be highly concentrated in a limited number of opportunities and does not represent a diversified investment program. There are inherent limitations in all descriptions of investment processes due to complexity, confidentiality, and subjectivity, and there can be no assurance that any fund or series will achieve its objective or avoid substantial or total losses. A key risk applicable to both RLH Series Fund strategies and the SPAC Fund is the risk of investing in SPACs or in issuers whose fortunes are tied to SPAC transactions. SPACs are shell companies formed to raise capital in an IPO and later merge with or acquire one or more unidentified businesses. Until a business combination is completed, a SPAC generally holds U.S. government securities, money market instruments, or cash. SPAC securities therefore are highly dependent on management’s ability to source and consummate a profitable acquisition. RLH Series Fund strategies also face specific credit and structuring risk because certain series may serve as lenders to SPACs or to companies expected to be taken over by SPACs. If a SPAC fails to enter into an expected acquisition or other transaction, the borrower may have difficulty repaying a loan. To the extent a financing is structured in part as a loan and in part as consideration for warrants or equity, a series may also be exposed to the risks of equity ownership in the SPAC or target. The Tactical PIPEs I Series introduces an additional layer of cryptocurrency-related risk. By virtue of the PIPE transactions it intends to undertake, the series will indirectly have exposure to risks specific to cryptocurrencies. A principal risk is the rapid fluctuation of cryptocurrency market prices. High volatility, shifting market sentiment, custody issues, technological failures, or legal and regulatory developments may materially affect the value of the strategy and the public companies in which the series invests. RLH Capital, LLC — Form ADV Part 2A | Page 11

Leverage risk is another material consideration. Tactical PIPEs I Series does not intend to use leverage as a central part of its investment program, but it may incur indebtedness to pay partnership expenses, provide working capital, fund capital contributions on an expedited basis, purchase the interest of a withdrawing participating partner (including a defaulting partner), or otherwise protect portfolio investments or other series assets. More broadly, series and funds may borrow for investment or operational purposes, which can magnify gains and losses. The Funds and Series also face liquidity and transferability risks. Investors in RLH Series Fund, LP generally are not permitted to withdraw capital from a series or redeem interests without the consent of the General Partner. RLH Spac Fund, LP provides quarterly liquidity only after an initial twelve-month lock-up and only up to a stated withdrawal limit, with earlier withdrawals subject to the General Partner’s discretion and generally a 3.0% early withdrawal penalty. Interests in the Funds are not publicly traded, no public market is expected to develop, and transfers are heavily restricted. A limited partner generally may not pledge, assign, sell, exchange, or transfer its interest except with the consent of the General Partner, which may be granted or withheld in its sole and absolute discretion. Illiquidity can increase the severity of mark-to-market losses because investors may be unable to exit during adverse market conditions. Valuation risk is also present. Net asset value for RLH Spac Fund, LP is determined no less frequently than monthly, and each partner’s share of NAV is determined by reference to the partner’s capital account relative to other partners’ capital accounts. Securities are valued at fair market value and changes in fair market value are treated as net profit or loss. Management fees, performance allocations, and withdrawal proceeds therefore can be affected by judgments regarding valuation, especially where market quotations are unavailable or where securities are thinly traded, restricted, or otherwise difficult to value. The SPAC Fund strategy also involves substantial optionality and derivative exposure. The strategy contemplates investments in units, common stock, warrants, options, debt instruments, and other securities across the SPAC capital structure. Warrants, options, and post-announcement long/short positions can be especially sensitive to volatility, borrow cost, time decay, liquidity conditions, financing availability, and deal-specific developments. The SPAC Fund strategy also affords broad latitude to change tactics, to use leverage, and to take positions in instruments that are not exhaustively described in this brochure. Investors therefore face strategy-drift risk in addition to normal market risk. Even if the Adviser remains within the broad objective of maximizing risk-adjusted returns in SPAC-related opportunities, the precise mix of tactics may change over time as market conditions evolve. Tax-sensitive investors also face risks. The Funds contain provisions intended to address taxsensitive or tax-exempt investors and contemplate circumstances in which borrowings may be offered to such investors so that leverage and related interest expense are not allocated to them in an inconsistent manner. The Funds also contain tax representative provisions and procedures that can affect investors’ after-tax outcomes. Finally, the Adviser’s strategy platform is exposed to regulatory and market-structure risks that extend beyond securities price movements. For Tactical PIPEs I Series, future laws or directives affecting digital currencies, exchanges, custodians, or service providers may materially impair the RLH Capital, LLC — Form ADV Part 2A | Page 12

acceptance of cryptocurrencies and therefore the market narrative around crypto treasury strategies. For the SPAC Fund, changing SEC rules or market practices affecting SPAC IPOs, deSPAC transactions, PIPEs, underwriting, or disclosure may reduce the availability or attractiveness of the opportunities on which the strategy depends. There is no assurance that any fund or series will achieve its objective or avoid substantial or total losses. Investors should therefore understand the Adviser’s strategies as specialized, opportunistic, and highly judgment-intensive approaches that may at times produce meaningful gains but can also produce abrupt and material losses, extended illiquidity, financing stress, and valuation volatility.

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The Adviser’s advisory clients are pooled investment vehicles. The pooled investment vehicles are intended only for sophisticated investors who do not require immediate liquidity, for whom an investment in the relevant fund or series does not constitute a complete investment program, and who fully understand and are willing to assume the risks involved. Tactical PIPEs I Series and Special Opportunities I Series generally require a minimum capital commitment of $100,000, while RLH Spac Fund, LP generally requires a minimum initial capital contribution of $250,000, subject in each case to the General Partner’s discretion to accept lesser amounts. Because the Adviser’s clients are pooled vehicles, references in this brochure to “clients” generally refer to the funds and series themselves and not to the underlying investors individually. Underlying investors’ rights are determined by the terms applicable to the relevant fund or series.

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As described in Item 5, the Adviser is compensated through carried interest and performance allocations in addition to management fees. Performance-based compensation creates a direct economic incentive for the Adviser to favor investment opportunities that it believes can generate high absolute returns, even where such opportunities also involve higher volatility, greater leverage, greater illiquidity, or greater downside risk. The Adviser’s performance-based compensation is asymmetric in the sense that the Adviser participates in upside through carried interest or performance allocation but is not required to return prior management fees if investments decline in value. Even where incentive fees are subject to high-water mark or cumulative-loss-account protections, the Adviser may still have an incentive to pursue strategies designed to recover prior losses more quickly in order to return to an incentive-compensationearning posture.

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The Adviser’s principal financial industry activity is serving as investment adviser, general partner, and/or manager to RLH Series Fund, LP, its associated series, and RLH Spac Fund, LP. Louis Camhi, the Adviser’s Managing Member and Chief Compliance Officer, currently serves on the board of directors of POSaBIT Systems Corporation and is also the Managing Member and Chief Compliance Officer of Framework Digital Advisors, an SEC-registered investment adviser (CRD No. 338868). These outside activities and affiliations may create potential conflicts of interest and competing demands on Mr. Camhi’s time and attention and may also create conflicts relating to confidential information, investment opportunities, trading, and the allocation of resources and opportunities among the Funds and their series, affiliated persons, affiliates, SPVs, or other vehicles. In particular, by virtue of his board service, Mr. Camhi may receive material non-public information that could restrict the Adviser’s ability to purchase, sell, recommend, vote, consent with respect to, or otherwise act on investments involving the relevant issuer or related securities. In addition, because the Adviser’s strategies involve SPAC-related investments, PIPE transactions, bridge financings, negotiated transactions, and other event-driven opportunities, conflicts may arise in connection with sourcing, evaluating, structuring, allocating, monitoring, and exiting investments. The Adviser seeks to manage these conflicts through its compliance policies and procedures, including its Code of Ethics and policies relating to confidential information, insider trading, and allocation of investment opportunities.

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Transactions and Personal Trading The Adviser has adopted a Code of Ethics designed to reflect its fiduciary duties under the Investment Advisers Act and to address the personal trading, confidentiality, and conflict-ofinterest issues inherent in managing private funds that pursue event-driven and transactionsensitive strategies. The Code is expected to require, among other things, standards of business conduct, protection of confidential information, compliance with federal securities laws, preclearance or monitoring of certain employee trading, and procedures designed to detect and prevent insider trading or misuse of material non-public information. The need for a robust Code of Ethics is heightened by the Adviser’s business model. The Adviser may evaluate issuers before transaction announcements, may interact with company management teams, bankers, counterparties, syndicate participants, and other market intermediaries, and may be exposed to sensitive or non-public information during due diligence or negotiation. The Adviser and its affiliates may invest in the Funds and may hold partnership interests that generally are not subject to management fee or incentive compensation. Those investments create alignment in some respects but also create conflicts, because the Adviser and its personnel may have economic interests in the same trades, securities, or issuers as the Funds while not being subject to identical fee burdens. The Adviser and its personnel may also invest through affiliates, SPVs, or parallel vehicles and may have incentives to favor one form of participation over another.

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The Adviser selects brokers, counterparties, and other execution venues in its discretion, subject to the obligation to seek best execution under the circumstances. Because the Adviser’s strategies include public market trading, SPAC securities, warrants, options, PIPE-related transactions, and negotiated financings, best execution for the Funds does not necessarily mean lowest nominal commission rate. The Adviser may consider execution capability, financing terms, ability to locate securities for short sales, access to new issues or PIPE allocations, operational reliability, risk management, relationship quality, access to information and market color, and the capacity of the broker or counterparty to support complex event-driven strategies. As a result of certain arrangements, the partnerships may pay higher commissions than would be the case in the absence of those arrangements, and a portion of the management fee and/or performance allocation may be remitted to third parties introducing limited partners to the partnership. The General Partner may also direct brokerage from partnership trades to brokerdealers that introduce limited partners to the partnership, subject to applicable law. These arrangements create potential conflicts between capital-raising objectives and best execution considerations. Cantor Fitzgerald & Co. is a principal prime broker used by RLH Spac Fund, LP, and the Adviser may use other or additional firms for prime brokerage services. The Adviser also uses prime brokers that include Clear Street LLC for at least one private fund relationship, and Spicer Jeffries LLP serves as auditor for RLH Spac Fund, LP. Prime brokers may act as custodians for some or all fund assets and may provide margin financing, securities lending, and other services that influence execution, financing, and risk management. The Adviser may aggregate or bunch transactions for accounts where it believes doing so is consistent with fair treatment and best execution. It may also separate accounts where mandates, liquidity profiles, investor consents, or regulatory constraints differ. The Adviser is not required to allocate every transaction pro rata among vehicles, and it may determine that some opportunities are appropriate only for a single fund, series, class, or SPV. Where the Adviser participates in primary offerings or “New Issues,” special allocation mechanics may be used to comply with FINRA restrictions and to classify investors as restricted or unrestricted. These mechanics can result in some investors or accounts participating differently in IPO-related transactions than others.

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The Adviser may compensate third parties for referring investors to the Funds. Selling commissions and/or referral fees may be paid in connection with the offering of partnership interests, and a portion of the management fee and/or performance allocation may be remitted to third parties introducing limited partners to a partnership. The General Partner may also use its own resources to compensate such introducers. These arrangements create conflicts because the Adviser has an incentive to compensate parties who help it raise capital.

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The Adviser does not currently have any legal or disciplinary event that is material to a client’s or prospective client’s evaluation of the Adviser or the integrity of its management. The Adviser will amend this brochure if any such event becomes reportable.

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Because the Adviser manages pooled investment vehicles rather than individualized advisory accounts, the Adviser reviews the portfolios of the Funds and Series on a continuous and eventdriven basis rather than through a separate household-account framework. The review process is inherently both investment-focused and operational. In addition to monitoring issuer and transaction developments, the Adviser reviews capital account movements, funding status against capital commitments, withdrawal requests, financing arrangements, borrowings, and administrative records. RLH Spac Fund, LP provides monthly unaudited performance reporting as well as annual audited financial statements and tax information. RLH Series Fund, LP provides reporting and tax information at the series level, with the timing and detail of reporting varying based on the relevant series and the stage of its investment program.

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The Adviser is deemed to have custody of client assets by virtue of its role as General Partner and manager of the Funds and Series and, where applicable, because fees and expenses are paid from fund assets and because the Adviser has authority over the disposition of fund and series property. Investors receive annual audited financial statements and periodic unaudited reports. RLH Spac Fund, LP furnishes audited financial statements within 120 days, or as soon thereafter as reasonably practicable, after the end of each fiscal year. Those financial statements include a balance sheet or statement of financial condition, an income statement or statement of operations, a statement of changes in partners’ capital, and related notes. The Funds also provide tax reporting to investors, generally including annual Schedule K-1 information. The Adviser distributes audited financial statements to investors where applicable and operates within an ecosystem of prime brokers, custodians, administrators, and auditors. The Adviser expects to continue to rely, where available and appropriate, on the annual audit and investorreporting framework used by its private funds. Valuation provisions are part of the custody environment as well. Securities are valued at fair market value and changes in fair market value are treated as net profit or loss. Because management fees, performance allocations, and withdrawal proceeds depend on those determinations, safeguards around who provides prices, how exceptions are handled, and how administrator and broker marks are reconciled are important custody-related controls.

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The Adviser has broad discretionary authority to manage the assets of the Funds and series. The General Partner is primarily responsible for the management of each partnership and each series and is authorized to acquire, hold, dispose of, and manage portfolio investments; borrow money where permitted; establish additional series and classes where authorized; pledge assets in connection with borrowings; allocate liabilities and opportunities among series; determine valuations where required; and take all related actions necessary or desirable for the conduct of the business.

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The Adviser does not provide underlying investors with the right to direct the manner in which proxies, consents, waivers, tenders, restructurings, registration-right demands, or other voting and consent rights are exercised with respect to securities or contractual rights held by a Fund or Series. To the extent the Adviser has authority to vote or consent on behalf of a Fund or Series, it will exercise that authority in a manner it believes is in the best interests of the relevant vehicle, taking into account the investment objective of the Fund or Series, the economics of the position, liquidity considerations, contractual obligations, regulatory requirements, and any applicable conflicts of interest. Because the Adviser’s strategies emphasize event-driven and negotiated transactions, the economically important “voting” decisions may frequently involve negotiated deal rights rather than routine annual meeting ballots. The Adviser generally expects to exercise such rights in a manner it believes is in the best interests of the relevant fund or series, taking into account the investment objective, expected economics, liquidity effects, counterparty relationships, and any conflicts that may be present. If a material conflict arises in connection with the exercise of voting or consent rights, the Adviser may consider internal escalation, consultation with counsel, abstention where practicable, or other conflict-management steps consistent with the best interests of the relevant fund or series. Where the Funds hold securities or contractual rights through SPVs, proxy and consent decisions may also be made at the SPV level rather than directly at the issuer level. In those circumstances, the Adviser may need to determine how to vote or direct the SPV itself, how to coordinate with other investors in the SPV, and how to respond when the series has only minority governance rights. The Adviser may not always control the relevant SPV or retain all governance rights, which means voting and consent outcomes can be affected by third-party investors or managers.

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The Adviser does not solicit or require prepayment of advisory fees from any client six months or more in advance in an amount of more than $1,200, other than economic arrangements embedded in private fund structures. The Adviser is not aware of any financial condition, bankruptcy event, insolvency proceeding, or similar circumstance that is reasonably likely to impair its ability to meet contractual commitments to its clients.

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