Ursa Fund Management, LLC

Description of the Advisory Firm Ursa Fund Management LLC (“Ursa” or “We”) is a Delaware limited liability company formed in February of 2016 primarily for the purpose of sponsoring and managing pooled investment vehicles. Andrew Hahn and Russell Douglas are the co-founders. Together, Andrew and Russell co-manage Ursa. Andrew Hahn. Prior to co-founding Ursa, Mr. Hahn was a member of the U.S. options marketmaking business at Evolution Capital Management, LLC (“Evolution”), a global hedge fund based in Santa Monica from 2005 to 2011, exclusive of 2008-2009 when Mr. Hahn worked at Synergy Capital Management (“Synergy”), also a U.S. options market-making business. Prior to joining Evolution, Mr. Hahn worked for a statistical arbitrage fund in Southern California, where he backtested the fund’s Portfolio Manager’s empirically observed patterns. Mr. Hahn holds a B.S. in Pure Mathematics from the University of California, Los Angeles. Russell Douglas. Prior to co-founding Ursa, Mr. Douglas started at Evolution in 2006, where he worked on the Asia desk for one year before joining the U.S. team. Mr. Douglas holds a B.A. in Business Economics from the University of California, Los Angeles.

The pooled vehicle we sponsored and manage is the Ursa Fund Partners LP (the “Ursa Fund”), which was formed in February 2016. Ursa is also engaged as a sub-advisor to manage a portion of Investment Opportunities SPC’s portfolio (the “Portfolio Fund,” and together with the Ursa Fund, the “Funds”). The Funds offer interests (“Interests”) to certain qualified investors, as described in response to Item 7, below; such shareholders and Investors are referred to herein as “Investors.” Description of Advisory Services Strategy – We serve as the investment manager to the Funds pursuant to separate investment management agreement between each of the Funds and Ursa. The Funds’ objective is to generate superior risk-adjusted returns on capital through investments in the corporate action and eventdriven space. To achieve this objective, Ursa utilizes proprietary scanning methods of corporate filings together with extensive research and analysis to seek attractive investment opportunities. The Funds generally invest in publicly-traded equity securities and derivatives, but it may also invest in other types of instruments that Ursa considers appropriate and in such Fund’s best interests. The Funds may also employ an “interest rate arbitrage” strategy, whereby it can collect a higher implied interest rate through a combined stock versus options structure than the debt financing rate paid to the clearing firms utilized by the Funds. The interest rate arbitrage strategy can lead to concentrated holdings and significant margin balances at one or more of the Funds’ clearing firms. The Fund may also invest in Bitcoin exchange traded funds (“ETFs”) or other digital assets (collectively, “Digital Assets”). The Ursa Fund is not limited with respect to the types of investment strategies it may employ, the markets or instruments in which it may invest or the percentage of its capital that may be any type or amount of a security. The Portfolio Fund is limited to investment in equities, equity options, total return swaps, and corporate bonds and convertible notes. In addition, the Ursa Fund may make certain investments (“Opportunistic

Investments”) from time to time and may utilize hedging, leverage or other strategies to achieve the Fund’s investment objective. Client Tailored Services and Client Imposed Restrictions We do not tailor portfolio management services to the individual needs of Investors in the Funds. Assets Under Management As of December 31, 2025, Ursa had assets under management on a discretionary basis of $1,198,312,942.

Management Fee Ursa will not charge the Funds any Management Fee. Rather, each Fund’s administrative costs are borne directly by such Fund, as disclosed below. Incentive Allocation, Generally At the end of each fiscal year, Ursa Fund Management LLC, General Partner of the Ursa Fund, will receive from the Ursa Fund, a performance-based allocation (the “Incentive Allocation”) equal to 35% of the aggregate net income indirectly allocated to each Investor in the Ursa Fund. At the end of each fiscal year, Ursa will receive from the Portfolio Fund, an Incentive Allocation equal to 10% of the amount of increase in the net asset value of each shareholders shares in the Portfolio Fund. An Incentive Allocation is also made as to amounts withdrawn or redeemed, as of the effective time of the withdrawal by Investors. Incentive Allocations are subject to a “high water mark” provision under which Ursa receives an Incentive Allocation from an Investor only to the extent Net Income allocated to that Investor’s Capital Account or Series of Shares, as applicable, exceeds any Net Losses previously allocated to it since the last date an Incentive Allocation was assessed (or the original date of contribution if no Incentive Allocation has previously been assessed). An Investor’s “high water mark” shall be the maximum of such Investor’s ending Capital Account balance as of year-end, after accounting for any of such Investor’s Capital Contributions and any withdrawals (the “HWM”). With respect to the Ursa Fund, in the event an Investor’s ending yearly Capital Account balance is below its HWM, the Incentive Allocation for the Ursa Fund will be reduced to 17.5% of the Net Income allocated for the month to such Investor for such month (the “Reduced Allocation”). References herein to the Incentive Allocation include the Reduced Allocation, unless specified otherwise. The Reduced Allocation shall continue to apply for each month an Investor’s Capital Account is below its HWM, as calculated by such Investor’s Capital Account balance as of monthend. Upon the first occurrence of an Investor’s Capital Account surpassing its HWM (each such occasion, an “HWM Event”), a pro-rated Incentive Allocation will apply with respect to Net Income allocated for the month to such Investor, calculated as follows: (1) an amount equal to 17.5% of the Net Income allocated for the month to such Investor through the HWM; and (2) thereafter, an amount equal to 35% of Net Income allocated for the month to such Investor from the HWM through the end of the month. Provided that the Investor’s Capital Account is above its HWM for the following month, the Investor will be readjusted to an Incentive Allocation equal to 35%, as described above.

If an Investor makes a partial withdrawal or receives a distribution at a time when he or she has unrecovered losses, for purposes of calculating the Incentive Allocation those unrecovered losses will be reduced in proportion to the withdrawal. Ursa, in its sole discretion, may elect to reduce, otherwise modify or waive the Incentive Allocation with respect to any Investor. Incentive Allocation, Opportunistic Investments The OI Incentive Allocation (as defined below) will be calculated separately from and independently of the Incentive Allocation applicable to the Ursa Fund’s other investments. Upon liquidation of the Opportunistic Investment, Ursa will receive an allocation equal to 35% of the Net Income allocated to each OI Capital Account (the “OI Incentive Allocation”). For the avoidance of doubt, the OI Incentive Allocation shall be calculated and earned, and may be withdrawn by Ursa, when the Opportunistic Investment is liquidated. If, upon liquidation of the Opportunistic Investment, an Investor’s OI Capital Account has unrecovered losses, then no OI Incentive Allocation is made with respect to that Investor’s OI Capital Account. Each OI Incentive Allocation is calculated and earned, and may be withdrawn, by Ursa separately and independently of any prior or future OI Incentive Allocations. For the avoidance of doubt, any unrecovered losses in respect of the Opportunistic Investment will not be carried forward to the Investor’s Capital Account in the Fund or included in the calculation of the Incentive Allocation applicable to the Fund’s other investments, including any future Opportunistic Investments. Ursa, in its sole discretion, may elect to reduce, otherwise modify or waive the OI Incentive Allocation with respect to any Investor. Expenses The Ursa Fund bears its own expenses including, but not limited to, investment related expenses such as the Fund’s brokerage commissions, interest on margin accounts and other indebtedness, custodial fees, bank service fees, withholding and transfer fees, taxes, systems and technology expenses, third party research tools, corporate licensing fees, legal and auditing expenses, accounting (including Foreign Account Tax Compliance Act compliance costs), fund administration, filing fees and expenses (including regulatory filings made in respect of the Fund such as Form PF preparation and filing expenses), outsourced risk management advisory and software, investment related consultants and travel costs that are research related, expenses incurred with respect to the preparation, duplication and distribution to Investors and prospective Investors of Fund offering documents, annual reports and other financial information, marketing and syndication expenses (including those incurred in marketing Fund Interests in the European Union), office space and utilities and any other services or service provider expenses deemed necessary by Ursa on behalf of the Fund. The Portfolio Fund bears its own reasonable expenses, including brokerage commissions and other transaction charges, interest, fees and expenses incurred in the borrowing and lending of securities, the costs implicit in repurchase and reverse repurchase agreements, custodial fees and expenses, and taxes in connection with the Portfolio Funds activities. Expenses (excluding any expenses directly attributable to the Portfolio Fund’s trading activities) charged to the Portfolio Fund will not exceed an aggregate amount of $175,000 in any given fiscal year. Ursa bears its own expenses, including computer equipment and software (not otherwise paid by the Fund), healthcare and secretarial, clerical, employee related and other personnel, except as assumed by the Fund or except as paid for through the permitted use of commission dollars.

Investment Strategy and Process, Generally Ursa utilizes proprietary scanning methods of corporate filings together with extensive research and analysis to seek attractive investment opportunities. Once Ursa has sourced an idea, it will follow news flow and corporate filings, searching for an attractive entry point. If Ursa identifies an attractive entry point, it will generally express its views by initiating a stock, options or combined stock and options position. Ursa intends to employ a discerning and patient approach, and will only trade in opportunities that it believes have favorable risk-reward characteristics. There may be occasions when the Fund does not make many trades, if Ursa determines that there are few or no compelling opportunities. Ursa believes this strategy will provide investors with exposure to a selective number of thoroughly vetted opportunities throughout the year. Each Fund’s portfolio is expected to be concentrated in certain “Big Event” opportunities that Ursa considers promising, after conducting extensive research and game planning with respect to such opportunities. The Ursa Fund may make certain follow-on investments (“Opportunistic Investments”) in Big Event investments from time to time (see Opportunistic Investments below). Ursa anticipates supplementing the Ursa Fund’s Big Event investments with investments in “Small Event” opportunities each month, through which Ursa seeks to cover costs and generate small positive returns. Big Event and Small Event opportunities share similar characteristics, although Big Event trades are more liquid and can be forecast much further in advance. When conditions allow, the Ursa Fund may employ an “interest rate arbitrage” strategy, whereby it can collect a higher implied interest rate through a combined stock versus options structure than the debt financing rate paid to the clearing firms utilized by the Ursa Fund. The interest rate arbitrage strategy can lead to concentrated holdings and significant margin balances at one or

more of the Ursa Fund’s clearing firms. There can be no assurance that Ursa will be able to employ this strategy as the implied interest rates collected with the combined stock versus options structure could be below the interest rates charged by one or more of the Fund’s clearing firms. The Funds generally invest in publicly-traded equity securities and derivatives, but it may also invest in other instruments, including but not limited to Digital Assets, and purchasing or selling debt instruments and instruments that are not listed on a U.S. exchange. Investment Strategy and Process, Opportunistic Investments An “Opportunistic Investment” is an opportunity extended by the Ursa Fund from time to time that allows each Investor to (i) increase their exposure to the Ursa Fund’s best Big Event investments at each Investor’s sole discretion, or (ii) participate in another opportunity extended by the Fund. The specific instruments of each Opportunistic Investment and the specific strategies will be set forth in a separate “Opportunistic Investment Addendum” applicable to such Opportunistic Investment. The Ursa Fund will generally only allow Opportunistic Investments when the investment allows for additional investment capacity beyond the on-going capital in the general Ursa Fund account. The Ursa Fund will generally utilize the capacity in the general Ursa Fund account first, before utilizing any Opportunistic Investment funds. Additionally, certain Investors of the Ursa Fund may elect to participate only in Opportunistic Investments. A Investor that participates only in a specific Opportunistic Investment generally has the same rights and characteristics of the Investors of the Ursa Fund, except as set forth in the applicable Opportunistic Investment Addendum for each such Opportunistic Investment. Risk Factors, Generally Following are descriptions of some of the most common risks associated with investing in the Funds. Please consult the applicable Funds’ Private Placement Memorandum for a more complete disclosure of risks. Reliance On Ursa. The success of the Funds depends on Ursa’s ability to develop and implement investment strategies to achieve such Fund’s investment objectives. Although Ursa may impose limits on the types of positions the Ursa Fund may take, or the concentration of its investments, the Partnership Agreement imposes no such limits. Investors will have no right or power to take part in the management of the Funds. Each Fund’s investment performance could be materially adversely affected if any members of the investment team were to die, become ill or disabled, or otherwise cease to be involved in the active management of the business of such Fund’s portfolio. Absence of Regulatory Oversight. While the Funds may be considered similar to investment companies, they are not required, and do not intend, to register as such under the laws of any jurisdiction. For instance, the provisions of the Investment Company Act of 1940, as amended (the “Investment Company Act”), which may provide certain regulatory safeguards to investors, are not applicable. Business and Regulatory Risks of Hedge Funds. Legal, tax and regulatory changes could occur during the term of the Funds that may adversely affect a Fund. The regulatory environment for hedge funds is evolving, and changes in the regulation of hedge funds may adversely affect the value of investments held by the Funds and the ability of the Funds to obtain the leverage it might

otherwise obtain or to pursue its trading strategies. In addition, securities and futures markets are subject to comprehensive statutes, regulations and margin requirements. The SEC, other regulators and self-regulatory organizations and exchanges are authorized to take extraordinary actions in the event of market emergencies. The regulation of derivative transactions and funds that engage in such transactions is an evolving area of law and is subject to modification by government and judicial actions. The effect of any future regulatory change on the Funds could be substantial and adverse. Limited Withdrawal Rights. An investment in the Ursa Fund is suitable only for certain sophisticated investors who have no need for liquidity in the investment. Generally, Investors may withdraw their Capital Accounts as of the end of each calendar month after the expiration of the applicable Lock-Up Period. Ursa, in its sole discretion, may waive the Lock-Up Period requirement or any withdrawal restriction as to any Investor. Further, distribution of proceeds upon an Investor’s withdrawal may be limited where, in Ursa’s view, the disposal of all or part of the Fund’s assets, or the determination of the value of the Investor’s Capital Account, among other reasons, would not be reasonable or practicable or would be prejudicial to the non-withdrawing Investors. Incentive Allocation to Ursa. Ursa is entitled to receive an Incentive Allocation, based upon the net capital appreciation, if any, allocated to the Capital Account of an Investor in the Ursa Fund or the increase in net asset value of a series of shares in the Portfolio Fund. The Incentive Allocation may create an incentive for Ursa to make investments that are riskier or more speculative than would be the case if such arrangement were not in effect. In addition, because the Incentive Allocation is calculated on a basis which includes unrealized appreciation of the each Fund’s assets, it may be greater than if such compensation were based solely on realized gains. Risk Factors, Investment and Trading General Investment and Trading Risks. An investment in either Fund involves a high degree of risk, including the risk that the entire amount invested may be lost. The Funds invest in securities and other financial instruments using strategies and investment techniques with significant risk characteristics. No guarantee or representation is made that either Fund’s program will be successful. Each Fund’s investment program may utilize investment techniques including, but not limited to option transactions, margin transactions, short sales, forwards, leverage and derivatives trading, the use of which can, in certain circumstances, maximize the adverse impact to which the Funds may be subject. Equity Investments. The Funds’ equity investments may involve substantial risks and may be subject to wide and sudden fluctuations in market value, with a resulting fluctuation in the amount of profits and losses. There are no absolute restrictions in regard to the size or operating experience of the companies in which the Funds may invest (and relatively small companies may lack management depth or the ability to generate internally, or obtain externally, the funds necessary for growth and companies with new products or services could sustain significant losses if projected markets do not materialize). Equity prices are directly affected by issuer specific events, as well as general market conditions. In addition, in many countries investing in common stocks is subject to heightened regulatory and self-regulatory scrutiny as compared to investing in debt or other financial instruments. Small- and Mid-Cap Risks. A portion of each Fund’s assets may be invested in securities of smallcap and mid-cap issuers. While in Ursa’s opinion the securities of small- and mid-cap issuers may

offer the potential for greater capital appreciation than investments in securities of large-cap issuers, securities of small-cap issuers may also present greater risks. For example, some smalland mid-cap issuers often have limited product lines, markets, or financial resources. They may be subject to high volatility in revenues, expenses and earnings. Their securities may be thinly traded, may be followed by fewer investment research analysts and may be subject to wider price swings and thus may create a greater chance of loss than when investing in securities of largercap issuers. The market prices of securities of small- and mid-cap issuers generally are more sensitive to changes in earnings expectations, to corporate developments and to market rumors than are the market prices of large-cap issuers. Transaction costs in securities of small- and midcap issuers may be higher than in those of large-cap issuers. Exchange-Traded Funds. The Fund may invest in exchange-traded funds (“ETFs”), which are a type of index fund bought and sold on a securities exchange. The risks of owning ETF shares generally reflect the risks of owning the underlying securities they are designed to track, although lack of liquidity in an ETF could result in it being more volatile. Investors in ETFs bear a proportionate share of the expenses of those ETFs, including management fees, custodial and accounting costs, brokerage commissions, and other transaction costs. ETFs are also subject to other risks, including the risk that their prices may not correlate perfectly with changes in the underlying index and the risk of possible trading halts due to market conditions or other reasons that, in the view of the exchange upon which an ETF trades, would make trading in the ETF inadvisable. An exchange-traded sector fund may also be adversely affected by the performance of that specific sector or group of industries on which it is based. Digital Assets. Digital Assets are loosely regulated and there is no central marketplace for currency exchange. Supply is determined by a computer code, not by a central bank, and prices can be extremely volatile. Digital Asset exchanges have been closed due to fraud, failure, or security breaches. Any of the Fund’s funds that reside on an exchange that shuts down may be lost. Several factors may affect the price of Digital Assets, including, but not limited to: supply and demand, investors’ expectations with respect to the rate of inflation, interest rates, currency exchange rates or future regulatory measures (if any) that restrict the trading of Digital Assets or the use of Digital Assets as a form of payment. There is no assurance that Digital Assets will maintain their long-term value in terms of purchasing power in the future, or that acceptance of Digital Asset payments by mainstream retail merchants and commercial businesses will grow. Digital Assets are created, issued, transmitted, and stored according to protocols run by computers in the Digital Asset network. It is possible these protocols have undiscovered flaws which could result in the loss of some or all assets held by the Fund. There may also be network scale attacks against these protocols which result in the loss of some or all of assets held by the Fund. Some assets held by the fund may be created, issued, or transmitted using experimental cryptography which could have underlying flaws. Advancements in quantum computing could break the cryptographic rules of protocols which support the assets held by the fund. The Fund makes no guarantees about the reliability of the cryptography used to create, issue, or transmit assets held by the Fund. Digital Asset Exchanges. The Digital Asset exchanges on which Digital Assets trade are relatively new and largely unregulated and may therefore be more exposed to theft, fraud and failure than established, regulated exchanges for other products. In general, Digital Asset exchanges are

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We provide investment advice to the Funds previously described. Investors in the Funds may include high net worth individuals, trusts, foundations, endowments, charitable organizations, pension plans and other unregistered funds. The minimum initial investment in the Ursa Fund is $500,000. The minimum investment in the Ursa Fund may be modified by Ursa. Each investor in the Ursa Fund must be an “accredited investor” as defined in Regulation D under the U.S. Securities Act of 1933, as amended. Each investor in the Ursa Fund must also be a “qualified client” as defined in Section 275.205-3 of the U.S. Investment Advisers Act of 1940, as amended (the “1940 Act”). The Portfolio Fund meets the definition of “accredited investor” and “qualified purchaser”.

Please refer to Item 5 for the description of our performance-based fees.

Neither Ursa Fund Management LLC nor any of its principals are registered or have an application pending to register as (1) a broker-dealer or a registered representative of a broker-dealer; or (2) a futures commission merchant, commodities pool operator, a commodity-trading advisor, or an associated person of the foregoing entity Ursa Fund Management LLC, a Delaware limited liability company, is the General Partner of Ursa Fund Partners LP. Ursa, our affiliates and its members, officers and employees may engage in other business activities, including providing investment management and advisory services to other accounts, and shall not be required to refrain from any activity, to disgorge profits from any such activity or to devote all or any particular amount of time or effort of any of their officers, directors or employees to a Fund and its affairs. Any such accounts may pursue a substantially similar investment strategy as that of another Fund.

Trading Ursa has adopted a Code of Ethics (“Code”) that describes the standards of business conduct that it requires of employees and accounts owned predominantly by persons associated with Ursa, and establishes procedures intended to prevent Ursa, and its personnel and certain of their relatives, from inappropriately benefiting from Ursa’s relationships with its clients. The Code provides that: i. ii. iii.

iv. v.

Ursa’s clients’ interests come before Ursa’s or employees’ interests; Ursa must disclose to clients all material facts about conflicts of which it is aware between Ursa’s and its employees’ interests on the one hand and clients’ interests on the other; Employees must operate on Ursa’s and their own behalf consistently with Ursa’s disclosures to and arrangements with clients regarding conflicts and its efforts to manage the impacts of those conflicts; Ursa and its employees must not take inappropriate advantage of Ursa’s clients or their positions of trust with or responsibility to clients; and Ursa and its employees must comply with all applicable securities laws. The Code generally prohibits employees from trading in any securities held by client accounts and requires employees to report personal securities holdings on an annual basis.

In addition, Ursa monitors all employees’ securities transactions: employees must arrange for duplicate copies of their brokerage statements and trade confirmations to be sent to the Chief Compliance Officer. The Code includes procedures for and restrictions on employee trading intended to prevent employees from benefiting from, or appearing to benefit from, any price movement that may be caused by client transactions or Ursa’s recommendations regarding securities. Among other things, these include requirements that employees make a written request for and receive clearance from Ursa’s Chief Compliance Officer (or his or her designee)

before they buy or sell any security (other than certain government securities, shares of mutual funds not managed by Ursa, and certain other types of securities that Ursa does not believe create a potential for conflicts of interest). Pre-cleared transactions must be completed within a specified time frame. The Code also contains restrictions on and procedures to prevent inappropriate trading while Ursa is in possession of material nonpublic information. Ursa will provide a copy of its Code of Ethics to any client or prospective client upon request. Such a request may be made by submitting a written request to Ursa at the address on the cover page to this brochure.

We are responsible for selecting broker-dealers to execute trades and negotiating any commissions paid on such transactions. Our primary consideration in placing transactions with particular broker-dealers is to obtain execution in the most effective manner possible. We also take into account a variety of other factors, including the financial strength, integrity and stability of the broker-dealer and the commissions charged. We may also consider the quality, comprehensiveness and frequency of available research and other products and services considered to be of value. The products and services furnished by broker-dealers may include, among other things, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; and statistics and pricing or appraisal services, discussion with research personnel, special execution capabilities, and the availability of stocks to borrow for short trades. Ursa currently does not utilize “soft dollars” to pay for Fund expenses. Each Fund has an account established at brokers for clearing and settling such Fund’s securities and options transactions. Settlement functions normally include, among other matters, arranging for (i) the receipt and delivery of securities purchased, sold, borrowed and loaned, (ii) the making and receiving of payments, (iii) custody of securities fully paid for or not fully paid for and (iv) custody of all cash, dividends and exchanges, distributions and rights accruing to such Fund’s account. The Funds may utilize other brokers from time to time. The Funds are not committed to continue its relationship with its broker(s) for any minimum period and either Fund may, in its sole discretion, select other brokers for the Fund. We do not direct client transactions to a particular broker-dealer in return for client referrals. We do not recommend, request, require or permit a client to direct us to execute transactions through a specified broker-dealer. We will not engage in cross trades between client accounts, as such trades could potentially pose a conflict of interest for one or more of our clients. Any trading errors (errors relating to placement, execution, or settlement of trades) due to causes other than fraud, gross negligence, reckless or intentional misconduct, or criminal wrongdoing will be for the account of the applicable Fund, which will accept the profits or suffer the losses from such trading errors pro rata. Ursa believes that trading errors are a known cost of doing business. Ursa has obvious incentives to avoid trading errors for reputational reasons as well as the fact that Ursa will indirectly suffer the consequences of trading errors through the Incentive

Allocation payable to Ursa. Nevertheless, Investors should assume that trading errors will occur periodically and that each Fund will be responsible for any resulting losses, even if such losses result from the negligence (but not gross negligence) of Ursa’s personnel.

Ursa does not receive any economic benefit from a person who is not a client for providing investment advice or other advisory services to Ursa’s clients. Ursa does not directly compensate any person for advisory client referrals.

In November 2016, Ursa Group, LLC, a former affiliate of Ursa Fund Management, LLC, entered into a settlement agreement with the Chicago Board Options Exchange (“CBOE”) related to File no. 16-0030. As part of the settlement agreement, Ursa Group, LLC agreed to pay a fine of

$45,000. More information about this event is available by viewing the Firm’s ADV Part 1 available on the SEC’s website, which is listed on the cover page of this brochure.

Review of Accounts Each Funds portfolio is reviewed by Andrew Hahn and Russell Douglas on a regular basis (typically daily) to ensure appropriate exposure and risk levels based on market conditions. On a monthly basis, the Principals review each Fund to determine that investment activities comply with the restrictions of the offering documents and to reconcile positions, valuations, cash, corporate actions, and performance between custodians and Ursa’s books and records.

Reports Each Investor in the Ursa Fund receives the following reports: Monthly: • •

An unaudited estimate of net fund performance A capital statement showing individual Investor returns and activity

Quarterly: •

A letter from Ursa’s managing member.

Yearly: • •

Audited fund financial statements Schedule K-1s for investors in the Fund.

Custody of each Fund’s assets is maintained with a prime broker or other broker (“qualified custodian”). Each Fund is audited annually and Investors in each Fund are sent the audited financial statements within 120 days following the end of such Fund’s fiscal year end. The audit is conducted by a Public Company Accounting Oversight Board (PCAOB) accountant. The General Partner may maintain custody of the Fund’s Digital Assets with Third Party Custodians selected by the General Partner, including the use of multiparty computation custodians, on or within “hot wallets” on exchanges, or “cold wallets”, either through paper or hardware cold storage, and/or on “air-gapped” computers utilized by the Fund. To the extent the General Partner maintains custody of any of the Fund’s Digital Assets, the General Partner shall select or generate the private keys that control movement of the Digital Assets.

Though all Ursa Fund assets are maintained at a qualified custodian, Ursa (as General Partner of the Ursa Fund) is deemed to have custody of the Ursa Fund’s assets due to its ability to take control or possession of such assets. Due to this, Ursa is required to report the assets associated with the Fund in ADV Part 1 Item 9. In light of the foregoing, Ursa has implemented the audit procedures described at the beginning of this Item 15 to provide Investors with confirmation of the safekeeping of Fund assets.

Ursa has broad discretion, without limitation, to determine the: • • • •

securities to be bought or sold for the Funds’ account(s); amount of securities to be bought or sold for the Funds’ account(s); broker or dealer to be used for a purchase or sale of securities for the Funds’ account(s); commission rates to be paid to a broker or dealer for the Funds’ securities transaction(s).

Ursa has adopted policies and procedures that address generally the guidelines it expects to follow in the exercise of its voting authority over proxies it receives on behalf of clients. Ursa will vote client proxies in the best interest of its clients. Ursa will consider a number of factors to determine whether exercising the clients’ voting rights as to its securities is in the relevant clients’ best interest, such as whether the securities are being held for a short or long period of time. When voting a proxy, Ursa will generally follow its voting guidelines. Ursa attempts to identify conflicts of interest that may arise in the proxy decision making process. If a material conflict of interest over proxy voting arises between Ursa and a client, Ursa will seek to resolve the conflict and vote the proxies in a manner that is in the relevant clients’ collective best interests. Ursa will provide, upon request, a copy of those policies and procedures and/or information concerning its voting record on account proxy matters. Such a request may be made by submitting a written request to Ursa at the address on the cover page of this brochure.

Ursa does not solicit or require prepayment of more than $1200 per client, six months or more in advance, and has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients. Ursa Fund Management LLC has not been the subject of a bankruptcy petition.