Syncracy Operational Management LLC

As of December 31, 2024, Syncracy manages $193,082,610 in regulatory assets under management ("RAUM") on a discretionary basis. The Adviser does not manage any assets on a non-discretionary basis

Item 5: Fees and Compensation Item 5.A. Fees and Compensation of the Syncracy Funds Syncracy receives management fees from the Funds as compensation for its advisory services. These fees are generally charged monthly in advance and are calculated as a percentage of each Investor’s capital account as of the beginning of the applicable month. As outlined in the Governing Documents:

Class A Limited Partners are charged an annual management fee of 1.5% (approximately 0.125% monthly); Class B Limited Partners are charged an annual management fee of 2.0% (approximately 0.1667% monthly).

The General Partner may, in its sole discretion, waive or reduce fees for certain investors, including but not limited to affiliates, friends and family of the principals, or large institutional investors. The General Partner may also receive a performance allocation, or incentive compensation, from the Funds. This allocation is based on a percentage of the net profits earned by each Limited Partner and is subject to a high-water mark. As disclosed in the PPM, the performance allocation is generally:

15% of net profits for Class A Limited Partners; 20% of net profits for Class B Limited Partners.

The General Partner has discretion to vary or waive the performance allocation for certain investors, as set forth in the governing documents of the Funds.

Item 5.B. All fees and performance allocations are deducted directly from Fund assets pursuant to the authority granted to the Adviser in the Governing Documents. Investors do not receive separate invoices. Fees are withdrawn from Investor accounts without prior notice but are subject to post-deduction reporting and periodic statements.

Item 5.C. Except as disclosed in the Governing Documents, Syncracy bears its own expenses. This includes office space, utilities, computer equipment, software, secretarial, clerical, and other employee related and personnel expenses, except as assumed by the Funds.

Organizational Expenses Each Fund will bear its own organizational expenses. Such expenses are generally capped at a fixed amount.

Expenses of the Funds The Funds bear a range of expenses, which are paid from Fund assets and not from Syncracy’s management fees. These expenses include, but are not limited to:

Organizational and Offering Expenses: All costs incurred in connection with the formation of the Fund, the

offering of interests, and the preparation of related documents and regulatory filings. Legal, Audit, Tax, and Accounting Fees: Fees and expenses incurred in connection with legal services, fund audits, tax return preparation, and accounting services. Administrative and Compliance Costs: Expenses related to fund administration, regulatory reporting, compliance support, anti-money laundering (AML) services, and other third-party service providers (e.g., Cayman AML officers, FATCA/CRS reporting). Custody and Execution Costs: Fees related to the safekeeping of Digital Assets, including costs of custody solutions, digital wallets, and smart contract audit services. This also includes commissions, gas fees, exchange trading fees, and slippage incurred in connection with trade execution. Technology and Infrastructure: Technology-related expenses, including costs associated with data feeds, analytics, infrastructure for blockchain interactions (e.g., nodes or validators), and cybersecurity systems. Professional Services: Expenses for consultants or external advisers, including valuation agents, risk management consultants, or blockchain analytics firms. Travel and Due Diligence: Reasonable travel expenses and costs related to investment diligence and site visits, where applicable. Taxes and Regulatory Fees: Taxes, governmental charges, filing fees, and other expenses incurred in connection with the conduct of the Fund’s business.

The General Partner retains broad discretion to determine which expenses are allocable to the Funds, provided they are incurred in connection with the operation or administration of the Funds or their investment activities. Certain expenses may be allocated among the Funds and their respective classes or series in a manner the General Partner deems fair and equitable. Syncracy does not retain any portion of these expenses unless specifically disclosed or authorized. Investors should carefully review the Governing Documents for complete expense disclosures.

Item 5.D. As discussed above in response to Item 5.A., the management fees of the Funds are payable monthly in advance.

Neither Syncracy, nor any of its employees, are compensated for the sale of securities or other investment products or mutual funds. Additionally, Syncracy does not charge advisory fees in addition to commissions or markup fees for the purchase and sale of securities for the Funds’ portfolios.

Investment Strategy Syncracy’s investment objective is to provide capital appreciation and capital preservation by investing across a broad spectrum of digital asset opportunities. The Adviser’s strategy spans both liquid and illiquid Digital Assets, including, but not limited to, digital currencies, cryptocurrencies, decentralized application tokens and protocol tokens, cryptographic tokens, non-fungible tokens (“NFTs”), smart contracts, blockchain-based assets, cryptoassets, digital currency networks, digital coins, stablecoins, altcoins, cryptocurrency platforms, decentralized finance (“DeFi”) assets, initial coin offerings (“ICOs”), pre-ICOs, simple agreements for future tokens (“SAFTs”), simple agreements for future equity (“SAFEs”), token warrants, and other current or future forms of cryptofinance and blockchain-native assets (collectively, “Digital Assets”). In addition, Syncracy may invest in companies related to the Digital Asset sector across both public and private markets, including venture capital and private equity-style investments (“Portfolio Companies”). The Funds’ investments in Digital Assets and Portfolio Companies are referred to collectively as “Portfolio Investments.”

The Adviser may employ a variety of strategies, including but not limited to: Directional and relative value trading across centralized and decentralized exchanges; Staking, yield farming, and liquidity provisioning on DeFi protocols; Derivatives trading, including the use of futures and options where the underlying assets are Digital Assets or securities; Opportunistic participation in token launches, pre-sales, and OTC transactions.

Syncracy utilizes a discretionary and opportunistic approach, incorporating fundamental analysis, technical indicators, on-chain metrics, market structure trends, and sentiment signals. The Adviser seeks to capture inefficiencies in digital asset markets and to capitalize on both short- and medium-term opportunities. Although the strategy includes both liquid and illiquid investments, the Adviser primarily focuses on liquid Digital Assets and trading protocols with active secondary markets. The Adviser may also consider broader macroeconomic and regulatory factors as part of its analysis and portfolio construction processes.

Items 8.B. and 8.C. Risks of Investment in the Funds The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment in the Funds. Each Investor and prospective Investor in a Fund should carefully review the applicable Fund’s offering documents and the agreements referred to therein for risks involved in an investment in the Fund. Undisclosed Investing Strategy. Syncracy’s investment strategy and the techniques it will employ to attempt to reach each Fund’s goals are proprietary and may not be disclosed to potential Investors. As a result, a potential Investor’s decision to invest in the Funds may be made without the benefit of being able to review and analyze Syncracy’s strategy and techniques.

Lack of Liquidity and Transferability. The Funds impose significant restrictions on the redemption, transfer, pledge, or other disposition of Fund interests. As such, it is unlikely that an Investor will be able to readily liquidate or transfer its interest in a Fund, particularly in the case of unanticipated liquidity needs. Fund interests are not registered under the Securities Act of 1933 or applicable state securities laws and may not be resold or transferred except in compliance with such laws and the restrictions set forth in the applicable Fund’s governing documents. Under those documents, Limited Partners generally may not transfer or pledge all or any portion of their interest without the prior written consent of the General Partner or, if applicable, the board of directors, which consent may be granted or withheld in their sole discretion (though not unreasonably withheld). Furthermore, a Fund may invest a portion of its assets in Side Pocket Investments, which may include illiquid positions that lack a readily determinable market value or are subject to contractual lockups or contingent events. These investments may be carried at fair value as determined by Syncracy and may not be realized for an extended period of time, if at all. Investors withdrawing from a Fund who hold an interest in a Side Pocket Investment will not receive proceeds attributable to such interest until the investment is realized or otherwise deemed realizable. These limitations may significantly impair a Limited Partner’s ability to obtain liquidity and should be carefully considered before investing. In-Kind Distributions. Although the Funds intend to satisfy withdrawal requests in cash, there can be no assurance that sufficient cash will be available at the time of a withdrawal to accommodate the request. Market conditions, the illiquidity of certain portfolio holdings, or other operational considerations may limit the Funds’ ability to liquidate investments at favorable prices or within required timeframes. In such cases, Syncracy may make in-kind distributions of portfolio assets to withdrawing Limited Partners. These distributions could include Digital Assets or other instruments that are not publicly traded, lack a liquid market, or are subject to transfer restrictions. Investors receiving in-kind distributions may be required to hold such investments for an indefinite period and bear the risk of loss, valuation uncertainty, and extended illiquidity. The potential inability to promptly sell or value such distributed assets may adversely affect the ability of an Investor to realize the anticipated value of its withdrawal. Effect of Substantial Redemptions. If a significant number of Investors in a Fund request redemptions during a limited timeframe, Syncracy may be required to liquidate portfolio assets more rapidly than would otherwise be optimal. This could adversely affect the value of those assets due to depressed market conditions or limited buyer interest and may disrupt Syncracy’s intended portfolio construction and investment strategy. Rapid asset sales could result in realized losses, missed opportunities, or reduced exposure to core investment themes. In addition, the fixed costs of managing the Fund would be borne by a smaller asset base, which may reduce the Fund’s efficiency and performance. Although assets allocated to Side Pocket Investments would generally not be subject to immediate redemption, large-scale redemptions in the broader portfolio could still have a material adverse effect on Fund operations and the remaining Investors. Effect of Performance Allocation. The General Partner will be entitled to receive a performance-based allocation from each Fund, calculated as a percentage of the Fund’s net realized and unrealized profits (excluding assets held in Side Pocket Investments). This performance allocation may create a potential conflict of interest by incentivizing Syncracy to pursue investment strategies that carry greater risk or are more speculative than would be the case in the absence of such compensation arrangements. While the performance allocation is intended to align Syncracy’s interests with those of its Limited Partners, it may also result in an emphasis on short-term performance or high-volatility investments, especially near performance measurement periods. This could lead to investment decisions that would not otherwise be made solely on the basis of long-term risk-adjusted returns. Digital Assets. Digital Assets are subject to limited regulatory oversight, and the infrastructure supporting their trading, custody, and valuation remains underdeveloped and evolving. Unlike traditional currencies issued by central banks, Digital Assets are created and governed by decentralized protocols or software code, and their value is primarily determined by supply and demand dynamics on various unregulated or lightly regulated exchanges. These exchanges may be subject to fraud, operational failures, or cybersecurity breaches, and in some cases have been permanently shut

down without warning. If a Fund holds assets on an exchange that experiences such a failure, the Fund may lose access to its assets, either temporarily or permanently. The price of Digital Assets may be influenced by a wide range of factors, including market sentiment, media coverage, regulatory developments, macroeconomic indicators, interest rates, and geopolitical events. Due to these factors, Digital Assets have experienced extreme volatility, including sudden and sharp price declines. There is no guarantee that any digital asset will maintain its value over time or that such assets will continue to be accepted as a means of payment or investment. As a result, investments in Digital Assets carry significant risk and may result in substantial or total losses. Qualified Custodians and the Custody Rule. In 2003, the SEC amended Rule 206(4)-2 under the Investment Advisers Act of 1940 (the “Custody Rule”) to require registered investment advisers to maintain custody of client funds and securities with “qualified custodians,” as defined under the Advisers Act. However, these regulatory changes predate the development of Digital Assets and were not designed to address the technological and operational nuances of digital asset custody. The current custody infrastructure for Digital Assets remains limited, with only a small number of custodians offering services in this space, many of whom have restricted capabilities or limited regulatory histories. In some cases, the use of a third-party custodian may provide less security for a Fund’s Digital Assets than a self-custody solution, depending on the type and structure of the assets held. As a result, it may be difficult or impossible for Syncracy to ensure full compliance with the Custody Rule with respect to certain digital asset holdings. Furthermore, it remains uncertain whether specific Digital Assets qualify as “client funds or securities” under the Custody Rule, and the SEC has not yet issued definitive guidance on whether custody of such assets must be maintained with a qualified custodian. If future guidance or rulemaking extends custody requirements to Digital Assets, the Funds may need to make structural changes that could adversely affect operations, incur additional costs, or limit investment flexibility. Syncracy retains full discretion to evaluate custody risks and select custody arrangements it deems appropriate, including the use of thirdparty custodians or evolving custody technologies. Liquidity Risk. Liquidity risk arises when a Fund is unable to sell or otherwise exit an investment position in a timely manner or at a favorable price. Certain investments held by the Funds may be subject to legal restrictions on resale, may not be listed on any exchange, or may be traded only in thin or fragmented markets. These include, but are not limited to, private placements, early-stage Digital Assets, and instruments traded on decentralized or over-the-counter platforms. The absence of a robust secondary market for such assets may prevent a Fund from disposing of a position when desired, or may force a Fund to accept materially lower prices upon sale. Additionally, liquidity constraints may affect a Fund’s ability to rebalance its portfolio, meet redemption requests, or take advantage of new opportunities. In extreme cases, illiquidity may require the use of Side Pocket Investments or in-kind redemptions. These risks are heightened in periods of market stress, heightened volatility, or regulatory uncertainty, where buyers may withdraw from the market entirely. As a result, Limited Partners may experience delays in liquidity or significant reductions in the value of their investments. Lack of Diversification. While Syncracy endeavors to construct each Fund’s portfolio based on its assessment of risk and return opportunities, the Funds are not subject to any formal diversification requirements and may concentrate investments in a limited number of Digital Assets, sectors, protocols, or positions. This lack of diversification significantly increases exposure to individual investment risks, such as protocol failures, regulatory actions, or adverse market movements affecting a single position or sector. In addition, certain Digital Assets may be highly correlated with one another or influenced by common market factors, which may amplify losses in a downtrend. Unlike diversified funds that may offset underperformance in one area with gains in another, Syncracy’s Funds may experience concentrated losses if core positions decline in value. While Syncracy retains the flexibility to adjust portfolio concentration based on market conditions or investor withdrawals, such adjustments may be limited by liquidity, timing, or strategic considerations. As a result, investors should be prepared for the possibility of significant volatility and

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Syncracy provides discretionary investment advice exclusively to private pooled investment vehicles, as described in Item 4.C above. These Funds are organized in reliance on the exemption from registration under Section 3(c)(1) of the Investment Company Act of 1940, as amended (the “Investment Company Act”). Investors in the Funds are generally expected to be “accredited investors” within the meaning of Rule 501(a) under the Securities Act of 1933, as amended (the “Securities Act”), and “qualified clients” within the meaning of Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The Funds may accept investments from high net worth individuals, family offices, funds of funds, institutional investors, pension plans, endowments, foundations, and other sophisticated entities. Each Fund generally imposes a minimum investment amount, which is disclosed in the Fund’s private placement memorandum and limited partnership agreement. The General Partner may, in its sole discretion, waive or reduce such minimum investment requirements on a case-by-case basis.

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss

As noted under Item 5 above, Syncracy generally receives performance-based compensation in the form of a performance allocation with respect to the Funds. This compensation is calculated based on a percentage of net profits, subject to a high-water mark and other terms as set forth in the Governing Documents. Syncracy recognizes that the receipt of a performance-based fee could create potential conflicts of interest, as it may incentivize the Adviser to make investment decisions that are riskier or more speculative than would be the case if these arrangements were not in place. This includes the possibility of favoring one account over another in pursuit of greater compensation. Syncracy seeks to address these potential conflicts by managing the Funds in accordance with its fiduciary duty and consistent with each Fund’s stated investment objectives, guidelines, and restrictions, as set forth in their respective private placement memoranda and other governing documents. The Adviser also maintains internal controls and oversight procedures designed to ensure the fair and equitable treatment of all clients and adherence to applicable regulatory standards.

Selection of Other Investment Advisers and Related Conflicts Syncracy does not recommend or select other investment advisers for its clients and does not receive any direct or indirect compensation from other advisers. Syncracy does not have any business relationships with other investment advisers that create material conflicts of interest.

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Syncracy has adopted a Code of Ethics (the “Code”) that sets forth the standards of conduct expected of the Adviser’s personnel and is designed to address actual and potential conflicts of interest. The Code establishes the ethical and professional standards that Syncracy requires of its supervised persons, outlines the fiduciary duties owed to clients, and requires compliance with applicable federal securities laws. The Code includes policies and procedures relating to personal trading by supervised persons. Among other provisions, it includes pre-approval and trading restrictions before participating in certain personal securities transactions, generally including transactions involving Digital Assets, private placements or limited offerings, and initial public offerings. Supervised persons are also required to submit reports of personal securities holdings upon commencement of employment and annually thereafter, and to report personal securities transactions on a quarterly basis. Personal trading by supervised persons involved in managing client accounts must be conducted in a manner that places client interests ahead of personal interests with respect to client-eligible investments. The Code also addresses the handling of material non-public information and other confidential information, as well as policies governing political contributions, gifts and entertainment, and other potential sources of conflicts of interest. A copy of Syncracy’s Code of Ethics is available to Investors and prospective Investors upon request.

Items 11.B., 11.C., and 11.D. Syncracy and certain of its related persons may invest in one or more of the Funds managed by the Adviser. These related persons may include investment personnel, executive officers, or entities under common control with Syncracy. As a result, Syncracy or its related persons may have a material financial interest in securities or other assets held by the Funds. This could present a conflict of interest by creating an incentive for Syncracy to make investment decisions that benefit its own interests or those of its related persons, potentially to the detriment of the Funds or their investors. For example, Syncracy or a related person may hold an interest in a Fund or an affiliated vehicle that is allocated a particular investment opportunity, while another Fund managed by Syncracy is not. From time to time, Syncracy may recommend or cause the Funds to invest in Digital Assets or other instruments in which a related person of the Adviser has a material financial interest. For example, a related person may have invested in, advised, or otherwise received compensation from a protocol, foundation, or entity associated with a particular digital asset that is also recommended to a Fund. These circumstances may present a conflict of interest because Syncracy or its related persons could benefit from transactions entered into by the Funds. Syncracy and its related persons do not engage in principal transactions with the Funds unless appropriate disclosures are made and prior written consent is obtained in accordance with applicable law. However, a related person may invest in or sell a digital asset at or around the same time that Syncracy recommends the same asset to a Fund, which could result in a benefit from market activity associated with the Fund’s trading. Syncracy and its related persons may invest in the same Digital Asset or related instruments that are recommended to, or transacted in for, client accounts. These investments may occur before, after, or at or about the same time as transactions by the Funds. This practice presents conflicts of interest, including the potential for related persons to benefit from market activity driven by client transactions, receive more favorable execution, or otherwise trade in a manner that could adversely affect the price or availability of assets considered or held by the Funds.

Syncracy has established policies and procedures to monitor and address these conflicts in a manner it deems fair and equitable, including restrictions on personal trading contained in its Code, as described above, and regular monitoring of related persons’ transactions and trading patterns for actual or perceived conflicts of interest, including those arising from personal trades in the same or related assets at or around the time of client transactions.

Item 12: Brokerage Practices Item 12.A.1. The Funds may invest in Digital Assets through centralized or decentralized Digital Asset exchanges, over-the-counter (“OTC”) counterparties, or other private arrangements, including privately placed investment opportunities. These transactions are generally executed without the use of a broker-dealer. In selecting a Digital Asset exchange, OTC counterparty, or other trading venue, Syncracy considers a range of factors, including, without limitation: execution quality, pricing and slippage, liquidity, reliability, transaction costs, execution speed, asset availability, platform security, jurisdiction, and regulatory posture. Syncracy may also evaluate its own experience with a venue or counterparty, including prior performance, responsiveness, and reputation within the Digital Asset ecosystem. Syncracy is not obligated to solicit competitive bids and does not have a duty to seek the lowest available cost. Instead, it exercises discretion to select the trading venues and counterparties it deems appropriate under the circumstances, based on a good faith assessment of the relevant factors. Syncracy may change trading venues or counterparties without prior notice to Investors. Syncracy does not currently engage in soft dollar arrangements.

Item 12.A.2. Syncracy does not participate in selecting or recommending broker-dealers in exchange for Fund referrals.

Item 12.A.3. Syncracy does not engage in directed brokerage by its Funds.

Syncracy may face potential conflicts of interest when allocating investment opportunities among the Funds it advises. Although investment activity currently occurs primarily through a single investment vehicle, Syncracy maintains practices to ensure that, if allocation decisions become applicable, such opportunities are allocated in a fair and equitable manner across eligible Funds. If multiple Funds are eligible to participate in a particular investment, Syncracy will consider a variety of factors in determining allocations, including each Fund’s available capital, investment strategy, portfolio composition, and other relevant considerations. Allocations may be made on a pro rata basis or using another method Syncracy deems fair and appropriate under the circumstances. Allocations will not be made in a manner that unfairly favors one Fund over another.

Item 13: Review of Accounts Items 13.A. and 13.B. Syncracy’s investment personnel regularly review the Fund holdings to monitor compliance with investment objectives, risk parameters, and strategy guidelines, as outlined in the respective Governing Documents. Reviews include evaluation of portfolio composition, position sizing, liquidity, and adherence to stated investment limitations or restrictions. These reviews are conducted on an ongoing basis and may occur more frequently in response to market events, changes in portfolio positioning, or material developments affecting specific holdings.

Neither Syncracy nor its related persons directly or indirectly compensate any person who is not a supervised person, including placement agents, for client referrals. However, while Syncracy has not previously engaged third-party placement agents, it may do so in the future to assist in introducing prospective investors to the Funds. In such cases, Syncracy will seek to comply with Rule 206(4)-1 under the Advisers Act to the extent applicable.

There are no material legal or disciplinary events related to Syncracy.

Item 10: Other Financial Industry Activities and Affiliations Item 10.A. and 10.B. Broker-Dealer, Commodity Pool Operator, or Commodity Trading Advisor Registration Neither Syncracy nor any of its management persons are registered, or have an application pending to register, as brokerdealers or registered representatives of a broker-dealer. Similarly, neither Syncracy nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, commodity trading advisor, or as an associated person of any such entity.

Item 10.C. Material Relationships or Arrangements with Industry Participants Syncracy does not have any arrangements with the following types of related persons that create a material conflict of interest: • a broker-dealer, municipal securities dealer or government securities dealer or broker; • a futures commissions merchant, commodity pool operator or commodity trading adviser; • a banking or thrift institution; • an accountant or accounting firm; • a lawyer or law firm; • an insurance company or agency; • a pension consultant; or • a real estate broker or dealer. As disclosed in Item 7 of Part 1A of Form ADV, the Adviser has related persons that are foreign private investment advisers. Certain of these related persons, provide investment advice to certain of the Adviser’s clients.

Investors receive written quarterly reports that include unaudited performance updates and relevant fund-level metrics. In addition, audited financial statements prepared in accordance with U.S. generally accepted accounting principles (“U.S. GAAP”) by an independent public accounting firm are provided annually. These audited statements are delivered within 120 days of the end of the Fund’s fiscal year.

Item 14: Client Referrals and Other Compensation Item 14.A. Syncracy does not receive a direct economic benefit from any third party for providing investment advice or other advisory services to the Funds.

Syncracy is subject to the Custody Rule, which governs the custody of client assets by SEC-registered investment advisers. To comply with the Custody Rule, each Fund managed by Syncracy is subject to an annual financial statement audit by an independent public accounting firm that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board ("PCAOB"). The audited financial statements will be prepared in accordance with U.S. generally accepted accounting principles and will be distributed to all investors within 120 days of the Fund’s fiscal year-end. Syncracy encourages investors to carefully review the audited financial statements upon receipt and compare them against any periodic statements or reports provided by Syncracy or the Funds’ administrators. Syncracy will generally maintain each Fund’s securities and assets with a qualified custodian, when available, in an account either in the name of the respective Fund or in accounts that hold only the assets of the Fund, under Syncracy’s name as agent or trustee for the Fund. Certain assets may be exempt from the qualified custodian requirement if: (1) they are acquired directly from the issuer in a transaction (or series of transactions) not involving any public offering; (2) they are uncertificated and ownership is recorded only on the issuer’s books in the name of the Fund; and (3) they are transferable only with the prior consent of the issuer or other holders of the issuer’s securities. In the case of Digital Assets, where use of a qualified custodian is not practicable or available, Syncracy maintains custody of such assets directly and implements protocols to safeguard the private cryptographic keys that provide access. These measures may include the use of cold storage, multi-party computation wallet technologies, multisignature wallets, and other third-party software solutions. In certain cases, Digital Assets may be temporarily stored on centralized digital asset exchanges in connection with trading activities. Syncracy recognizes that safeguarding access to private keys is essential to preserving client assets, and loss or compromise of such keys could result in permanent loss of Digital Assets. Accordingly, Syncracy regularly reviews and tests its internal controls and procedures related to custody, key management, and Digital Asset transfers. Digital Asset custody remains an evolving regulatory area. Although Syncracy is not a qualified custodian, the Adviser believes that such practices are reasonably designed to safeguard client assets and align with its fiduciary duties. Syncracy continues to monitor developments in custody regulation, including any SEC rulemaking that may affect Digital Asset investment advisers, and will adapt its practices to remain in compliance with applicable laws and best practices.

Syncracy has discretionary authority to manage the investment accounts of the Funds and, accordingly, to determine the types and amounts of investments to be made on behalf of each Fund. This authority is granted through the execution of the relevant Governing Documents, which define the scope of Syncracy’s discretionary powers with respect to each Fund. Investors do not have the ability to impose restrictions on Syncracy’s discretionary authority. Instead, each Investor must execute a subscription agreement that includes various representations, including those related to their suitability to invest in the applicable Fund.

Item 17: Voting Client Securities Item 17.A. To the extent Syncracy has discretionary authority to vote proxies on behalf of a Fund, it will do so in the best interests of the applicable Fund and in accordance with Syncracy’s proxy voting policies and procedures. While the Funds primarily invest in Digital Assets that are not typically subject to proxy voting, there may be limited circumstances in which Syncracy is asked to vote on matters relating to such investments. In such cases, Syncracy will evaluate the issue and determine whether voting is in the best interests of the relevant Fund. Syncracy may abstain from voting if it determines that doing so is appropriate under the circumstances. In the event of a material conflict of interest, Syncracy will adhere to its proxy voting policies and procedures to ensure that votes are cast in a manner consistent with its fiduciary duty. Although not anticipated as a routine practice, Syncracy may retain an independent third party to vote proxies, including in situations where a material conflict of interest is identified. Investors generally do not have the ability to direct the voting of proxies. However, Investors and prospective Investors may request additional information about how Syncracy has voted proxies, if applicable, and may obtain a copy of Syncracy’s proxy voting policies and procedures upon request.

Syncracy has proxy voting authority with respect to securities held by the Funds.

Item 18: Financial Information Item 18.A. Syncracy does not require nor solicit pre-payment of more than $1,200 in fees per Fund, six months or more in advance.

Item 18.B. Syncracy is not aware of any financial condition that is reasonably likely to impact its ability to meet its contractual commitments to the Funds.

Syncracy has not been the subject of a bankruptcy petition at any time during the past ten years.