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Corbin Capital Partners, L.P.: investment adviser

Corbin Capital Partners, L.P. is an investment adviser registered with the SEC (file 801-63358, CRD 130819). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.

Assets managed
$11.2B
Discretionary
99%
Accounts
27
Employees
56
In advisory roles
17
Disclosures
0

Company page · SEC adviser record · Full Form ADV (PDF)

The firm reports that it or a related person has custody of client cash and securities.

Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.

Clients and fees

Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.

Client typeClientsAssetsShare
Private funds and other pooled vehicles13$6.4B57.0%
Pension and profit-sharing plans2$2.1B18.8%
Other: Sole investor vehicles/series unit12$2.7B24.2%

How it is paid

  • A percentage of assets under your management
  • Performance-based fees

Services

  • Portfolio management for pooled investment vehicles (other than investment companies)
  • Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles)
  • Selection of other advisers (including private fund managers)

Who owns it

Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.

Direct owners (Schedule A)

OwnerTypeRoleStakeSinceControlPublic company
Corbin Capital Partners Holdings,Company (U.S.)LimitedE 75% or moreJan 2025Yes

Indirect owners (Schedule B)

OwnerOwns a stake inTypeStakeControlPublic company
Corbin Capital Partners GP, LLCCorbin CapitalCompany (U.S.)F General partner, trustee or managing memberYes
Craig Gary BergstromCorbin CapitalPersonD 50% to 75%Yes
Tracy Karen StuartCorbin CapitalPersonD 50% to 75%Yes

Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.

Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.

Disciplinary history

The firm answered No to every disciplinary question on Form ADV (Item 11).

The brochure

Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.

Part 2A of Form ADV March 2026, filed Mar 31, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

Corbin, a Delaware limited partnership, is an alternative investment manager that provides investment advisory services to private investment funds, separate accounts and single investor vehicles (collectively the “Corbin Funds” or “Clients”). Corbin Funds generally implement their investment programs by employing the services of third-party investment managers (“Investment Managers”) in various ways, including by investing in hedge funds, closed-end funds and other investment vehicles managed by such Investment Managers, establishing discretionary and non-discretionary managed accounts with such Investment Managers and partnering on co-investments with such Investment Managers. Corbin and its predecessor firms have been in business since the mid-1980s.

Read the rest of Item 4 (1,086 more words)

Corbin Capital Partners GP, LLC, a Delaware limited liability company owned and controlled by Tracy Stuart, Corbin’s chief executive officer, and Craig Bergstrom, Corbin’s chief investment officer, is the general partner of Corbin. Ms. Stuart and Mr. Bergstrom collectively own a majority interest in Corbin. Corbin’s net assets under management (“AUM”) as of January 1, 2026, were $9,983,790,433, of which $9,886,148,017 were managed on a discretionary basis and $97,642,416 were managed on a nondiscretionary basis. To avoid double counting assets, these figures exclude all investments made by Clients into Commingled Funds (as defined below). Please note that this is an unaudited estimate and the methodology used to calculate the net asset value of Client accounts that Corbin manages differs from the methodology used to calculate “regulatory assets under management” for purposes of responding to Item 5.f(2) of Part 1 of Corbin’s SEC Form ADV. Additional detail concerning the methodology is available upon request. Overview of Corbin’s Advisory Services In implementing the multi-manager investment programs of its Clients, Corbin utilizes various modes of implementation, including, but not limited to: allocating Clients’ capital among various Investment Managers through investments in hedge funds, closed-end funds and other investment vehicles managed by such Investment Managers (“Portfolio Funds”); establishing managed accounts with Investment Managers; making investments upon the advice or recommendation of, or alongside as a co-investor with, or otherwise in partnership with or with the involvement of, Investment Managers; and making investments independently without the involvement of any Investment Managers. The mix of implementation modes differs across Clients’ portfolios and changes over time within Clients’ portfolios. The number, type and concentration of investment strategies also differs across Clients’ portfolios and changes over time within Clients’ portfolios. Over time, the portion of the Clients’ portfolios over which investment discretion is exercised by Investment Managers on the one hand and by Corbin on the other hand will change. Investment Managers generally may implement their investment programs through the use of various securities and financial instruments, including, but not limited to, equity and debt securities of United States (“U.S.”) and non-U.S. corporations and other entities, loans, U.S. government securities, non-U.S. government securities, partnership interests, money market instruments, derivatives on securities and other derivatives, commodity interests including futures contracts, options, options on futures, swaps, forward contracts, currencies, cryptocurrencies and physical commodities, and other financial instruments. In general, there are no material limitations on the securities, financial instruments, strategies, markets or countries in which Investment Managers and Portfolio Funds may invest, and there are no material

limitations on the securities, financial instruments, strategies, markets or countries in which Corbin may invest when implementing its Clients’ investment programs independently or with the involvement of an Investment Manager. The investment program of certain Clients may be limited by contractual terms or by applicable laws, regulations (e.g., the U.S. Employee Retirement Income Security Act of 1974, as amended (“ERISA”), in the case of certain Clients), sanctions or executive orders. Corbin generally enters into investment management agreements that, among other things, grant Corbin the authority to manage Clients’ assets on a discretionary basis and generally grant Corbin unlimited discretionary trading authorization. Currently, Corbin is a party to one investment management agreement under which Corbin is granted discretionary management authority only after the underlying client determines to proceed with a presented investment opportunity. As a general matter, other than through a Customized Fund (as defined below) -- the objectives and guidelines of which would be set forth in the relevant Customized Funds’ Constituent Documents (as defined below) -- Corbin does not permit investors in Corbin Funds (“Investors”) to impose material restrictions on investing in certain securities or types of securities. In general, Corbin manages and/or offers two types of products: Commingled Funds -- “Commingled Funds” are Corbin Funds that are offered to multiple Investors. Corbin establishes the investment objective and portfolio characteristics of these funds and makes investment decisions in its sole discretion. Customized Funds -- A “Customized Fund” is an investment vehicle or separate account that Corbin manages for one Investor (or a group of related Investors). The Investor is involved in establishing the investment objective, portfolio characteristics and terms of the Customized Fund, although generally Corbin maintains discretion to make investment decisions. Investors in Customized Funds are generally subject to a significantly higher minimum investment threshold than Investors in Commingled Funds. In providing investment advisory services to Commingled Funds and to Customized Funds, Corbin causes certain Commingled Funds and Customized Funds to make investments in other Corbin Funds. In this situation, Corbin typically waives the advisory fees it would otherwise receive from the Corbin Fund in which such investment was made so that Clients are not charged twice for management of their assets. Corbin Capital Partners Management, LLC (“CCPM”), an affiliate of Corbin, is the general partner of each Corbin Fund that is a limited partnership and is the manager of a Corbin Fund that is a limited liability company. Other than Investors for whom Corbin manages a Customized Fund in the form of a separate account, Investors in Corbin Funds are not deemed to be Clients but are entitled to the rights and benefits, and are generally subject to the terms and conditions, described in the applicable Corbin Fund’s Confidential Memorandum, Limited Partnership Agreement, Investment Management Agreement and other applicable constituent fund documents (collectively, the “Constituent Documents”). Corbin typically selects third-party service providers, such as auditors, custodians, and/or administrators, on behalf of Clients that are Commingled Funds. For Clients that are Customized Funds, such service providers may be selected by Corbin or by the Investor in the Customized Fund. Corbin will from time to time provide a Client, prospective client, Investor or prospective investor generally at the Client’s, prospective client’s, Investor’s or prospective investor’s request, information, advice, opinions, evaluations, recommendations, forecasts or suggestions (“Informational Responses”) that, with regard to Clients and Investors, relates to matters outside the scope of Corbin’s management of their assets. Such Informational Responses are general in nature and ordinarily do not take into account the Client’s, prospective client’s, Investor’s or prospective investor’s particular circumstances or needs.

Therefore, Informational Responses are not, and should not be considered, advice with respect to the purchase, sale, holding or management of securities or other assets. Unless Corbin expressly agrees otherwise with the Client, prospective client, Investor or prospective investor, Corbin provides Informational Responses solely as a courtesy, and does not assume any duties to the Client, prospective client, Investor or prospective investor other than the duty to act in good faith in connection with providing Informational Responses.

Item 5. Fees and compensation

In general, Corbin charges a management fee of up to 1.5% of the net assets or capital of each Corbin Fund that it manages. The management fee may differ both within certain Corbin Funds and across the various Corbin Funds. Fees are generally deducted from Corbin Funds’ assets although investors in Customized Funds that take the form of separate accounts are typically billed for fees incurred. In certain circumstances management fees charged by Corbin Funds are waived, reduced, modified or rebated. For example, Investors that are principals or employees of Corbin or its related persons are generally not charged management fees.

Read the rest of Item 5 (1,936 more words)

In addition, from time to time, the proceeds of any revenue share owned by a Corbin Fund may be paid to Corbin instead of such Corbin Fund for tax, regulatory or other reasons. Any such proceeds paid to Corbin will reduce the management fee payable and/or performance-based compensation payable by such Corbin Fund to Corbin or its affiliates. In general, Corbin Funds pay their operating expenses and expenses incurred in connection with the sale of their interests. Corbin Funds’ operating expenses currently include, or in the future may include, but are not limited to, investment expenses (e.g., expenses which Corbin determines to be related to the investment of Corbin Funds’ assets, such as custodial fees; brokerage fees and commissions; clearing and settlement charges; bank service fees; other transaction costs; costs related to the negotiation, acquisition, holding, monitoring, restructuring or disposition of any Corbin Fund investment (including expenses related to actual or threatened disputes); other transaction costs; costs related to the investigation of actual and/or potential Corbin Fund investments, including travel costs; expenses relating to potential Corbin Fund investments that are not consummated; expenses relating to investing in other entities, including payment of a pro rata share of such entities’ operating and other expenses as well as, except as otherwise described, payment of associated management and performance fees; expenses payable to Investment Managers in connection with investments that are not made in other entities, including management fees, performance fees and other fees and expenses); research expenses (including third-party research expenses; costs and expenses of products and services relating to research concerning the Corbin Fund’s investments or potential investments; periodicals; publications; subscriptions; data (e.g., Bloomberg); data maintenance, processing and retrieval); directors’ fees; taxes (including taxes paid with respect to, or withheld from, receipts of the Corbin Fund from an investment, directly or indirectly, in a Portfolio Fund or in any other security or financial instrument and costs and expenses incurred in connection with any tax audit, inquiry, settlement or review); insurance costs and expenses (including costs and expenses relating to financial institution bonds, ERISA bonds, professional liability insurance, errors and omissions insurance, directors’ and officers’ insurance, fiduciary liability insurance and investment fund management insurance); auditing and tax preparation expenses (including expenses relating to Corbin Funds’ tax returns and tax reporting for Investors); printing and mailing expenses; legal, regulatory and governmental fees, charges and expenses; filing and reporting fees and expenses (including fees and associated expenses relating to filings and/or reports concerning investment and other activities of Corbin Funds made with government, regulatory or self-regulatory organizations by Corbin Funds, Corbin or any of their affiliates, including but not limited to Form PF and Annex IV); fees and expenses relating to the establishment of placement agent, solicitation, distribution and similar arrangements; corporate licensing fees; registration fees; and fees and out-of-pocket expenses of any service company retained to provide

certain accounting, bookkeeping, middle-office, administrative services, services of anti-money laundering officers, or other similar services; expenses of winding up the affairs of the Corbin Funds; the expenses of any Advisory Committee of a Corbin Fund in accordance with the applicable Constituent Documents (including third-party costs and expenses incurred thereby in connection with such committee retaining advisors to perform services contemplated by the Constituent Documents) and any costs and expenses of annual or special meetings of the Investors or any meetings or conferences with Investors or their representatives, whether individually or in a group, including costs and expenses associated with the presence of a Corbin Fund’s lawyers, accountants or advisers at such annual or special meetings or such other meetings or conferences; all costs and expenses incurred in relation to obtaining waivers, consents or approvals pursuant to the Constituent Documents, and all costs and expenses of, and/or incidental to, the preparation of amendments to the Constituent Documents; costs and expenses incurred in connection with amendments to, and waivers, consents or approvals pursuant to, side letters or similar agreements with Investors and the “most favored nations” election processes in connection therewith. Corbin Funds also pay or reimburse Corbin for certain operating expenses including Corbin Funds’ pro rata portion of the expenses of quotation equipment and other computer software (including the cost of software development) utilized in investment decision-making and investment monitoring, portfolio reporting and/or order/portfolio management; professional fees (including expenses of attorneys, consultants, accountants, advisors and experts) relating to investments and/or operation of the Corbin Funds, expenses relating to third-party pricing services, financial modeling services, valuation agents, and appraisals, expenses related to the negotiation and preparation of side letters for Investors and prospective Investors, and due diligence-related travel expenses. Corbin Funds also pay interest expenses, borrowing costs and any extraordinary expenses (including indemnification or litigation- or investigation-related expenses and judgments, awards or settlements). The expenses above include (i) expenses that Corbin Funds bear directly and (ii) expenses of Corbin and CCPM, as applicable, that are incurred on behalf of, and are reimbursed by, Corbin Funds. These expenses are generally charged pro rata to each Investor at monthend based on the net asset value of each Investor as of the beginning of each month. If applicable, Corbin Funds also bear their pro rata portion of the expenses of other Corbin Funds in which they invest and the fees and expenses of Portfolio Funds in which those Corbin Funds invest. The expenses borne by certain Corbin Funds may be limited by contractual arrangements, applicable law or otherwise.

Expense Allocation Common expenses frequently will be incurred on behalf of Clients and/or co-investors. Corbin seeks to allocate those common expenses among Clients and/or co-investors in a manner that is fair and equitable over time. Expense allocation decisions involve potential conflicts of interest (e.g., an incentive to favor Clients and/or co-investors that pay higher fees, or conflicts relating to different expense arrangements with certain Clients and/or co-investors). Under its current expense allocation policies, Corbin generally allocates common expenses among the applicable Clients pro rata based on their respective net asset values at the beginning of the month in which such expenses were incurred. For purposes of determining common expense allocations, Clients may include Commingled Funds, Customized Funds, as well as investment vehicles whose only investor is another Client. Corbin may, however, use other methods to allocate certain common expenses among the Clients and/or co-investors if it deems another method more appropriate based on relative use of the product or service or the anticipated or actual participation in an investment, the nature or source of the product or service, the relative benefits derived by the Clients and/or co-investors from the product or service or the anticipated or actual participation in an investment, or other relevant factors. Investment expenses incurred (i) jointly for the account of one or more Clients and one or more coinvestor(s) (whether or not such co-investor is also a Client) or (ii) for the accounts of co-investors only will generally be allocated among the applicable Clients and co-investor(s) in proportion to the size of the

investment made (or the anticipated size of the investment to be made) by each in the activity or entity to which the expense relates, or in such other manner as Corbin, in its discretion, considers fair and equitable. Nonetheless, the portion of a common expense that Corbin allocates to a Client and/or co-investor for a particular product or service may not reflect the relative benefit derived by the Client and/or co-investor from that product or service in any particular instance. In certain instances, a Client and/or co-investor(s) may bear expenses for which it receives no corresponding benefit, including in cases where expenses are borne in connection with potential investments that are not consummated by any Client and/or co-investor or by a particular Client and/or co-investor, or where the anticipated allocation of an investment (and thus the associated expenses) changes over time. In addition, because expenses incurred jointly for the account of one or more Clients will generally be allocated based on relative net asset values, Clients with larger net asset values generally will bear a greater share of expenses than Clients with smaller net asset values. In certain situations involving the allocation of common expenses among Clients, a Client that is the only investor in another Client will bear a pro rata portion of the expense based on its NAV and incur the portion of the expense allocated to the Client it is invested in. Generally, Clients and/or co-investor(s) that participate in a co-investment will share in expenses relating specifically to such investment, however, in certain circumstances, co-investors may not share in any or all of such expenses. It is not always possible or reasonable to allocate or re-allocate certain expenses to a co-investor, depending upon the circumstances surrounding the applicable investment (including the timing of the investment), the financial and other terms governing the relationship of the co-investor to any other investment vehicles or accounts organized, managed, advised, sub-advised or owned by principals, employees and direct and indirect owners of CCPM and Corbin and their affiliates (such principals, employees and direct and indirect owners collectively, “Affiliated Persons”, and such investment vehicles or accounts, the “Affiliated Funds”) with respect to the investment and/or the nature of the expense. For example, (i) research expenses that are not specifically related to an investment (but may benefit one or more such investments), (ii) research expenses that are subscription-based, aggregated or otherwise paid for as a single bill or lump-sum payment and (iii) other similar expenses that are difficult to divide and allocate specific amounts to a single investment, generally will not be allocated to co-investors. For the avoidance of doubt, co-investors may not bear (or may bear less than their proportionate share of) expenses incurred in relation to the sourcing, due diligence or negotiation of a co-investment, whether or not such coinvestment is consummated, and expenses associated with potential co-investment opportunities that are ultimately not consummated (e.g., broken deal expenses) are unlikely to be borne by contemplated coinvestors unless a binding commitment has been obtained from such co-investors. In these cases, such expenses will generally be borne by Clients based on their respective net asset values. Such expenses that will generally be borne by Affiliated Funds, may involve expenses that are particularly attributable to coinvestors (e.g., where Corbin or its affiliates seek to address certain regulatory issues with respect to a particular investment that specifically affects certain potential co-investors and the investment is ultimately not consummated or committed to). Corbin’s expense allocations often depend on inherently subjective determinations which are made at the time the expense is incurred, and Corbin undertakes no obligation to revisit such determinations and allocations in light of facts, circumstances or judgments that change after such determinations and allocations were made. Expense allocations made by Corbin in good faith will be final and binding on the Partnership. The allocation of certain expenses may affect the size or performance of, and therefore the fees and/or performance-based compensation earned by Corbin and its affiliates with respect to certain Affiliated Funds and/or co-investors, and therefore Corbin and its affiliates may have a conflict of interest when determining how to allocate expenses among such Affiliated Funds and/or co-investors. Certain products or services, the costs of which are borne exclusively by one or more Affiliated Funds may also benefit Corbin and its affiliates, other Affiliated Funds or third parties, directly or indirectly.

Corbin and its affiliates have a conflict of interest in determining whether such expenses should be borne by certain Affiliated Funds because Corbin, its affiliates and other Affiliated Funds also receive benefits from the products and services provided. (See Item 12 - Brokerage Practices for a more detailed discussion of brokerage and transaction costs).

Item 6. Performance-based fees and side-by-side management

In addition to the asset-based advisory fees disclosed in Item 5 – Fees and Compensation above, Corbin or CCPM receives performance-based compensation from certain Corbin Funds. Such compensation may differ both within certain Corbin Funds and across the various Corbin Funds. Performance-based compensation is generally based on a share of capital gains on, or capital appreciation of, the assets of a Corbin Fund.

Read the rest of Item 6 (1,260 more words)

Performance-based compensation up to 15% of such gains or appreciation may be charged and may differ with respect to a number of terms, including, but not limited to, the applicable measurement period, such compensation being subject to reaching a hurdle rate or preferred rate of return, and if so, whether such hurdle rate or preferred rate is soft or hard, the requirement to recoup prior losses before earning such compensation and whether such compensation is determined by reference to a measurement period or by reference to the value of realized investments. Fees are generally deducted from Corbin Funds’ assets although investors in Customized Funds that take the form of separate accounts are typically billed for fees incurred. The fee schedule for each Corbin Fund is set forth in greater detail in each respective Corbin Fund’s Constituent Documents. The fee schedule for each Corbin Fund is omitted because this brochure is being delivered only to “qualified purchasers” as defined in the Investment Company Act of 1940. In the future, Corbin and/or CCPM may establish affiliated entities to receive performance-based compensation. In certain circumstances incentive fees charged by Corbin Funds are waived, reduced. modified or rebated. For example, Investors that are principals or employees of Corbin or its related persons are generally not charged incentive fees. (See Item 16 – Investment Discretion for more information). In addition, from time to time, the proceeds of any revenue share owned by a Corbin Fund may be paid to Corbin instead of such Corbin Fund for tax, regulatory or other reasons. Any such proceeds paid to Corbin will reduce the management fee payable and/or performance-based compensation payable by such Corbin Fund to Corbin or its affiliates. Corbin and its investment personnel, including investment personnel who are partners of Corbin and accordingly share in performance-based compensation, manage Corbin Funds that are charged performance-based and/or asset-based compensation. Certain Corbin Funds will have higher asset-based fees or more favorable performance-based compensation arrangements than other Corbin Funds. The existence of Corbin Funds with different asset-based fees and/or performance-based compensation can create a conflict of interest for Corbin, which may have an incentive to favor Corbin Funds with higher asset-based fees or more favorable performance-based compensation to the detriment of Corbin Funds with smaller asset-based fees or less favorable performance-based compensation. The existence of a performance-based fee may incentivize Corbin to manage Corbin Funds’ assets in a more aggressive manner than if there was not a performance-based fee. Further, the existence of differing performancebased fees for Corbin Funds trading side-by-side may create a conflict of interest for Corbin with respect to the allocation of investment opportunities. Corbin has adopted policies and procedures regarding the allocation of investment opportunities (the “Allocation Policy”) which are described below, and the Allocation Policy, together with other procedures implemented by Corbin, is intended to address these potential conflicts of interest. It is Corbin’s policy to allocate securities and other financial instruments to Clients, and aggregate orders,

in a fair and equitable manner over time as described in the Allocation Policy. Corbin determines trade allocation prior to execution and the following are the principal factors considered by Corbin when determining such allocations: Client’s investment objectives, strategies and guidelines (including if an investment is within the mandate of a Commingled Fund or a private investment fund that is wholly owned by one or more Commingled Funds, in each case which is sponsored and managed by Corbin or an affiliate of Corbin and which has a specific investment focus or criteria (e.g., opportunistic credit, private credit, hedged equity, sustainability/impact, litigation finance) (each such fund, a “Specialty Fund”), such Specialty Fund will receive priority in allocation); Client’s applicable portfolio restrictions, imposed by agreement or by virtue of federal, state or other applicable law (e.g., ERISA, the Internal Revenue Code); Client’s risk profile; Client’s liquidity profile; Client’s tax status; Client’s existing or expected direct and indirect exposure to the investment; Client’s existing or expected portfolio composition and characteristics; Client’s available cash, including expected, pending or anticipated subscriptions and/or withdrawals/redemptions, and timing of Client’s cash flows; Client’s eligibility to participate in the investment (e.g., minimum investment size, Investor qualifications, etc.) and expected ability to meet the investment timeline; Client’s ability to participate in, and/or the suitability of, the anticipated mode of implementation of the investment (e.g., special purpose vehicle, co-investment, direct investment, managed account, etc.); and any other information determined to be relevant to the fair allocation of investment opportunities, in accordance with the Allocation Policy. Because allocations are determined by Corbin based on the factors listed above, including whether an investment is within a single Specialty Fund’s specific investment focus or criteria, to the extent that there exists limited availability for a particular investment opportunity that falls within such a Specialty Fund’s specific investment focus or criteria, such Specialty Fund will be allocated its desired portion of such investment before other Clients receive an allocation (although other Clients may receive indirect exposure through their interest, if any, in such Specialty Fund). In the event that an investment opportunity is within more than one Specialty Fund’s specific investment focus or criteria, to the extent there exists limited availability for such investment opportunity such opportunity will, subject to the foregoing, be allocated to such Specialty Funds pro rata on the basis of each Specialty Fund’s desired participation, determined by evaluation of the factors listed above. In the event that there is excess capacity in such investment opportunity after allocation to the appropriate Specialty Fund (or Specialty Funds), the excess will be allocated among all other Clients pro rata on the basis of each Client’s desired participation, determined by evaluation of the factors listed above. In the event that an investment opportunity is (i) limited in availability and (ii) not within any Specialty Fund’s specific investment focus or criteria, such investment will be allocated pro rata on the basis of each Client’s desired participation, determined by evaluation of the factors listed above. If Corbin determines that the allocation of any investment opportunity on a pro rata basis would result in a position that is insignificant, inappropriate or non-economic for a particular Client, such Client may not be allocated any portion of the investment. Moreover, Corbin may be constrained from allocation on a pro rata basis in certain situations (e.g., in which an agreement that is required for particular types of trading is not yet in place). Corbin’s Allocation Policy is available upon request. Corbin may offer co-investment opportunities to co-investors. Generally, (i) in the case of co-investors that are non-Specialty Fund Clients, such opportunities may be offered only after all Specialty Funds have received their desired allocations with respect to such opportunities and (ii) in the case of co-investors that are not Clients, such opportunities may be offered only after all Specialty Funds and other Clients over which Corbin exercises discretion have received their desired allocations with respect to such opportunities, and otherwise in any manner among such co-investors that Corbin determines in its sole discretion. Corbin recognizes that in certain instances (e.g., a case where participation by co-investors is

required due to the size of the opportunity under consideration being otherwise too large for Corbin to consummate without such participation) it may be deemed necessary to approach co-investors prior to Corbin having finalized allocations of such opportunity among Clients. Corbin is under no obligation to arrange such co-investment opportunities, and no investor will be obligated to participate in such opportunities. Corbin has sole discretion as to the amount (if any) of a co-investment opportunity that will be offered to any particular investor.

Item 7. Types of clients

Corbin provides investment supervisory services principally to Corbin Funds. (See Item 4 – Advisory Business). The Investors in Corbin Funds are based in the U.S. and outside the U.S and generally consist of: ➢ Banks and other financial institutions ➢ Insurance companies ➢ Retirement and pension plans ➢ Profit sharing plans ➢ Trusts and estates ➢ Charitable organizations ➢ Sovereign wealth entities ➢ High-net-worth individuals ➢ Corporations ➢ Business entities other than those listed above Generally, the minimum initial investment amount for Investors in the Commingled Funds is $5,000,000. The minimum initial investment amount may be waived at the discretion of the general partner or board of directors of each Commingled Fund, and such waivers are frequently granted.

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There is no fixed minimum account size required for Customized Funds. The size of a Customized Fund is subject to negotiation and typically significantly exceeds the minimum investment required for Commingled Funds.

Item 8. Methods of analysis, investment strategies and risk of loss

Generally, Corbin seeks to obtain capital appreciation for Corbin Funds by utilizing various modes of implementation (as described in Item 4 above) in implementing Corbin Funds’ investment programs. Corbin selects Investment Managers and their associated Portfolio Funds, monitors their performance, and allocates and reallocates assets among them as Corbin, in its discretion, deems advisable. In placing a Corbin Fund’s assets under the management of an Investment Manager, interests in Portfolio Funds are often purchased. When investing in a Portfolio Fund, a Corbin Fund typically invests in an investment vehicle that is commonly offered by the Investment Manager to eligible investors.

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Alternatively, a Corbin Fund may work with the Investment Manager to structure or negotiate a more customized investment program or customized set of investment exposures, either through an investment vehicle, seeding or anchor investment arrangement, secondary transaction, continuation fund, traditional separate account or other arrangement. Such structuring and negotiation may affect economic, liquidity and other terms and characteristics of the investment. Corbin Funds may access particular Portfolio Funds through an intermediate entity in which other Corbin Funds may also invest. If such an entity is used, Corbin will not charge any fees at the intermediate entity level, but the Corbin Fund will bear its pro rata portion of the expenses of such entity. A Corbin Fund may also obtain exposure to the performance of Portfolio Funds without investing in those Portfolio Funds by entering into derivative instruments with institutional

counterparties, the return on which is based on the performance of the Portfolio Fund. A Corbin Fund may also purchase and sell interests in Portfolio Funds from or to third parties, including through options or other derivative instruments. In certain instances, Portfolio Funds are owned solely by investment vehicles or accounts managed by the Investment Manager. In addition, certain Corbin Funds may purchase certain investments with the expectation of selling or participating portions or the entirety of such investments to third parties, including other Corbin Funds and co-investors who pay fees to Corbin. A Corbin Fund’s investments may be conducted through one or more subsidiaries for tax, regulatory or other reasons. In addition to investing in Portfolio Funds, Corbin implements Corbin Funds’ investment programs by establishing managed accounts with Investment Managers and by making investments upon the advice or recommendation of, or alongside as a co-investor with, or otherwise in partnership with or with the involvement of, Investment Managers. Investment discretion and trade execution may be retained or ceded by Corbin depending on the investment opportunity, structure and/or the Investment Manager that Corbin is implementing the investment(s) with. Corbin may make investment decisions that differ from an Investment Manager’s recommendation and may take different actions or positions with respect to the same investment than that of an Investment Manager, including with respect to the manner and timing of a Corbin Fund’s exit from such an investment. Corbin also implements Corbin Funds’ investment programs by making investments independently without the involvement of any Investment Managers. In general, there are no limitations as to how a particular investment may be accessed. Investments may be accessed through a direct holding (including pursuant to an assignment), a special purpose vehicle, a participation agreement, a derivative or otherwise. Corbin uses a number of key sources and networks to identify potential Investment Managers with which Corbin Funds might invest. In the sourcing process, Corbin uses hedge fund databases, consultants, capital introduction desks of major prime brokerage groups, industry networks, other Investment Managers, peer institutions, as well as other avenues. Following due diligence conducted by Corbin on Investment Managers and, to the extent applicable, their associated Portfolio Funds, Investment Managers are chosen from a universe of investment managers. For investments in Portfolio Funds, such due diligence will generally include a qualitative investment component, a quantitative and risk component, and an operational component. Focus areas of due diligence include, but are not limited to, experience, performance records, volatility, risk management, portfolio management, management stability, investment philosophy, trading and research capabilities, and operational infrastructure including policies, practices and procedures. Corbin has varied, and may in the future continue to vary, its approach to due diligence to suit specific Investment Managers and/or Portfolio Funds or categories thereof or specific investments. Corbin’s approach depends upon a number of factors, including, without limitation, the expected holding period of an investment, the size of an investment, the nature of the structure and implementation of an investment, the lifecycle stage and/or size of the Investment Manager and/or Portfolio Fund, the asset class represented by an investment, the strategy underlying such investment, the liquidity of an investment, Corbin’s prior experience, if any, in making investments in Portfolio Funds managed by the Investment Manager and whether Corbin or the Investment Manager retains investment discretion over the investment and other considerations that Corbin believes to be relevant. These variances affect the scope, type, nature and/or amount of due diligence undertaken by Corbin. As described above, investing in Portfolio Funds is not the only way that Corbin implements the investment programs of Corbin Funds. The scope, type, nature and/or amount of diligence that Corbin will perform with respect to certain of these other types of investment implementation modes will differ depending on a number of factors, including how the investment opportunity has been presented to Corbin, the nature and structure of the investment, whether Corbin has been provided with access to independent information regarding the investment, the experience and diligence of other investors evaluating the investment, and certain of the factors set forth in the paragraph above. In certain

circumstances, including when these investments are made upon the advice or recommendation of, or alongside as a co-investor with, or otherwise in partnership with or with the involvement of, an Investment Manager, Corbin expects to take into account and may rely heavily on the investment analysis and diligence conducted by the Investment Manager, and also expects to rely to varying degrees on the Investment Manager for ongoing monitoring of such investments. In these circumstances, Corbin will review and assess the Investment Manager’s investment analysis, diligence and reporting that has been shared with Corbin and Corbin will determine the extent to which it supplements such analysis, diligence and reporting with its own independent work. Corbin will also perform its own diligence on the Investment Manager which will also differ in scope, type, nature and/or amount depending on various factors. When Corbin has sourced an investment independently (i.e., without the involvement of an Investment Manager), Corbin will conduct its own investment analysis and diligence, which also may vary depending upon the nature and structure of the investment, and Corbin will monitor such investments on an ongoing basis. In conducting its own investment analysis and diligence, Corbin may employ the services of third parties. Corbin’s investment process is informed by various research and analytical tools which include, among other things, a database containing detailed performance history as well as portfolio exposures of investment managers, performance and exposure analytics, a deal management system and a multimanager allocation system. Depending on the Corbin Fund to which investment advice is rendered, Corbin may select Investment Managers that individually and/or collectively invest in a variety of investment strategies and Corbin may directly employ a variety of investment strategies. Specific strategies that may be utilized include, but are not necessarily limited to: long/short equity, long-biased equity, credit strategies, private equity investments, structured and/or asset-backed investments, litigation finance, real estate-related debt or equity, convertible bond arbitrage, event-driven investing, relative value strategies, distressed securities, specialty finance, direct lending, emerging markets, fixed income arbitrage, statistical equity arbitrage, commodities, sustainability, digital assets and global macro trading. Corbin’s portfolio monitoring process incorporates the ongoing evaluation of return and risk characteristics and factor exposures of Corbin Funds and Portfolio Funds, and continuous re-evaluation of the qualitative aspects of Investment Managers. For investments other than those made in Portfolio Funds, Corbin’s monitoring process incorporates the ongoing evaluation of the qualitative elements of such investments and includes ongoing dialogue with Investment Managers, if any, who are associated with such investments as well as direct engagement with borrowers or issuers in certain instances. Corbin implements a hedge overlay program for certain of the Corbin Funds principally to address certain natural limitations specific to managing portfolios that include investments in Portfolio Funds. The terms of an investment in a Portfolio Fund, including the lack of real-time investment information and the limitations on withdrawals/redemptions, make it difficult to respond in a timely and capital-efficient manner to a rapidly changing market landscape. Thus, Corbin believes that a portfolio-level hedge aimed at reducing what Corbin believes to be undesirable portfolio-level exposures is a valuable tool for the risk management and portfolio construction process. While Corbin does not aim to neutralize Portfolio Fund exposures, the goal of the program is to marginally reshape existing risk exposures to bring them in line with Corbin’s desired posture given particular portfolio objectives and exposures. Corbin generally believes that implementing hedges directly (rather than paying a third-party asset manager) offers benefits in capital efficiency, transparency, liquidity and expected costs. Corbin deploys a broad range of instruments to implement the hedge overlay program. Historically, the primary instruments utilized have included listed equity options and credit default swaps. In addition, Corbin may engage in hedging transactions targeted at reducing exposure with respect to a particular investment held by a Client.

An investment in Corbin Funds is speculative, illiquid and involves significant risk. Only persons who understand, and are willing and financially able to assume, the risks of such an investment, including the risk of losing all or substantially all of their investment, should consider investing. The following is a summary of some of the significant risks associated with investing in Corbin Funds. This summary does not attempt to describe all risks associated with an investment in a Corbin Fund or, indirectly, in Portfolio Funds. It is critical that Investors and prospective Investors refer to the Constituent Documents for a more comprehensive understanding of the material risks involved in relation to an investment in Corbin Funds, including risks relating to the strategies employed by Corbin Funds and Portfolio Funds and the securities and other instruments in which Corbin Funds and Portfolio Funds may invest. The information contained herein is a summary only and is qualified in its entirety by such documents. While the risks identified below often reference Portfolio Funds, many of these risks also apply to investments that are implemented in other ways, such as through managed accounts with Investment Managers, or investments that are made upon the advice or recommendation of, or alongside as a co-investor with, or otherwise in partnership with or with the involvement of, Investment Managers, or investments that are made independently by Corbin without the involvement of any Investment Managers.

A. Certain Multi-Manager Fund Risks Tiered Fee Structure. A Corbin Fund’s fees and expenses, including both performance-based and asset-based fees as well as organizational and operating expenses, will result in Investors bearing greater expense than if such Investors made direct investments in Portfolio Funds. These fees and expenses borne by Investors in Corbin Funds will be in addition to the fees and expenses borne by Corbin Funds themselves in connection with investments made by Corbin Funds in Portfolio Funds and other structures whereby Investment Managers are compensated, which fees and expenses typically include performance-based and asset-based fees as well as organizational and operating expenses. Further, a Corbin Fund may also invest in Portfolio Funds that invest in other investment vehicles, thereby subjecting a Corbin Fund and its Investors to an additional level of fees and expenses. In the aggregate, these fees and expenses can be substantial and will adversely affect the value of any investment in a Corbin Fund. Limited Liquidity of Investment. An Investor in a Corbin Fund may withdraw or redeem from such Corbin Fund only in accordance with the terms set forth in such Corbin Fund’s Constituent Documents, which terms typically provide for very limited liquidity. Similarly, Portfolio Funds in which Corbin Funds may invest also generally provide for very limited liquidity pursuant to the terms of their governing documents. There is no secondary market for an investment in a Corbin Fund and none is expected to develop. There may be restrictions on transferring interests in a Corbin Fund. In general, if underlying assets of Portfolio Funds become illiquid or difficult to value and/or Portfolio Funds face significant withdrawals, or if other circumstances prevail that may adversely impact Portfolio Funds, Investment Managers may choose from among a wide range of actions typically available to them to manage the liquidity and withdrawals or redemptions of Portfolio Funds, including, but not limited to, invoking a gate, creating a side pocket or a liquidating vehicle, suspending withdrawals or redemptions, or implementing a restructuring. Any such actions will limit the ability of a Corbin Fund to withdraw or redeem its investments from such Portfolio Funds, and in turn limit the ability of Investors in Corbin Funds to withdraw or redeem from such Corbin Funds. Additionally, Portfolio Funds may hold back some percentage of full withdrawals or full redemptions until such Portfolio Funds complete their annual audits. In addition, Corbin may similarly choose from

among a wide range of actions to manage the liquidity and withdrawals or redemptions of Corbin Funds. Consequently, Corbin Funds may be highly illiquid. Subscriptions and Withdrawals/Redemptions. A Corbin Fund that is continuously offered will generally permit subscriptions to occur monthly. Certain Portfolio Funds in which a Corbin Fund may invest, however, do not permit investment on the same basis. As a result, a Corbin Fund will be delayed in investing subscriptions in Portfolio Funds. This delay may in turn act to dilute the interests of the Investors in a Corbin Fund. Further, certain Portfolio Funds do not permit withdrawals or redemptions at the same times and/or with the same notice provisions as a particular Corbin Fund. Therefore, payment of all or part of an Investor’s withdrawal or redemption proceeds may be delayed until appropriate withdrawals or redemptions from Portfolio Funds can be effected. When a Portfolio Fund’s and a Corbin Fund’s permitted withdrawal or redemption dates are different, a Corbin Fund may, but is not required to, make withdrawals or redemptions from a Portfolio Fund in anticipation of funding withdrawals or redemptions of its Investors. In addition, Corbin Funds generally may suspend calculation of their net asset values and, therefore, withdrawals/redemptions in the event that, among other things, the value of a Portfolio Fund cannot be ascertained. Independent Investment Managers. Investment Managers invest wholly independently of one another and may at times hold economically offsetting positions. To the extent that Investment Managers do, in fact, hold such positions, a Corbin Fund, considered as a whole, cannot achieve any gain or loss on the offsetting positions despite incurring expenses. In addition, an Investment Manager may be compensated based on the performance of its portfolio. Accordingly, a particular Investment Manager may receive incentive compensation in respect of its portfolio during a period when the value of a Corbin Fund’s overall portfolio depreciated. It is also possible that Investment Managers will establish positions in the same markets or instruments at the same time, which could adversely affect a Corbin Fund’s ability to achieve its diversification objectives. Dependence on Corbin and Investment Managers. The success of a particular Corbin Fund depends upon the ability of Corbin and Investment Managers to develop and implement investment strategies that achieve a Corbin Fund’s investment objectives, and the ability of Corbin and each Investment Manager to select individual securities and other instruments, interpret market data correctly, predict future market movements and otherwise implement its investment strategy. In general, neither Corbin Funds nor Investors will have the ability to direct or influence the management of Portfolio Funds or the investment of their assets. Subjective decisions made by Corbin and/or Investment Managers may cause a Corbin Fund to incur losses or to miss profit opportunities on which it would otherwise have capitalized. The success of a Corbin Fund is also affected by turnover in Corbin’s or an Investment Manager’s personnel who are responsible for the Portfolio Fund’s investment activities. While turnover is expected in the industry, Investors should consider the potential effect of past and future turnover on performance. Investors should also consider the experience and success of departing and any new personnel. The loss of services of any such senior officers or other key personnel could have a material adverse effect on a Corbin Fund. Changes in Investment Strategies. Generally, Corbin has discretion to expand, revise or contract certain investment strategies of a Corbin Fund without the consent of its Investors. Similarly, Investment Managers may do the same with respect to Portfolio Funds. Any such decision to engage in a new activity or alter the existing investment strategies of a Corbin Fund or Portfolio Fund could result in the exposure of a Corbin Fund’s capital to

additional risks that may be substantial. Moreover, a Corbin Fund will face the risk of an Investment Manager’s misrepresentation, material strategy alteration or poor judgment. Although Investment Managers are required to adhere to the offering documents for the respective Portfolio Fund, Corbin cannot control the investments made by an Investment Manager. Corbin’s sole remedy in the event of a deviation by an Investment Manager from its offering documents may be to cause a Corbin Fund to withdraw or redeem capital from the Portfolio Fund, subject to any applicable withdrawal or redemption restrictions. Other Accounts of Investment Managers. Investment Managers have exclusive responsibility for making trading decisions on behalf of a Portfolio Fund. Investment Managers also manage other accounts (including funds and accounts in which the same Investment Managers may have ownership interests) which, together with accounts already managed by such Investment Managers, could compete for the same investment opportunities an Investment Manager might otherwise invest in on behalf of a Corbin Fund, including competition for priority of order entry. This could make it difficult or impossible for a Corbin Fund to take or liquidate a position in a particular security, futures contract or other instrument at a price indicated by an Investment Manager’s strategy. Variation among Investment Managers. Investment Managers have varying levels of experience and expertise. Investment Managers and their principals may employ trading methods, policies and strategies which may differ from those of other Investment Managers, and which may deviate from Corbin’s expectations concerning such methods, policies and strategies. Therefore, the results of any Investment Manager’s investments on behalf of a Corbin Fund may differ from those of the other accounts operated by Investment Managers and from results anticipated by Corbin. Various Investment Manager Risks. Investment Managers are subject to various risks, including, but not limited to, operational risks such as the ability to provide the adequate operating environment for a Portfolio Fund such as back-office functions, trade processing, accounting, administration, risk management, valuation services and reporting. Investment Managers will also face competition from other investment funds which may be more established and have larger capital bases and have larger numbers of qualified management and technical personnel. Additionally, certain Investment Managers may over time pursue different investment strategies which may limit a Corbin Fund’s ability to assess an Investment Manager’s ability to achieve its long-term investment objective. Furthermore, an Investment Manager may face additional risks as the assets of a Portfolio Fund increase over time. In such instances, an Investment Manager may not be able to handle properly the operating volumes of a Portfolio Fund with an increased capital base. Also, an Investment Manager may be unable to manage a Portfolio Fund’s increased assets effectively because it may be unable to maintain such Portfolio Fund’s current investment strategy or source and manage the types of investments better suited for a Portfolio Fund with an increased capital base. Portfolio Concentration. Unlike some investment funds employing a “fund-of-funds” or ”multi-manager” strategy that, as a matter of investment policy, diversify their allocation of assets among Investment Managers and Portfolio Funds that pursue a variety of investment strategies, certain Corbin Funds may concentrate their allocation of assets exclusively among Investment Managers and Portfolio Funds that pursue a particular investment strategy. The investment risk of a portfolio that allocates its assets to a single investment strategy is greater than if the portfolio had allocated its assets in a more diversified manner among various

investment strategies. Moreover, because the number of Investment Managers and Portfolio Funds in a Corbin Fund may be limited, the portfolio of a Corbin Fund may be highly concentrated in particular companies, industries or countries. As a consequence, a Corbin Fund’s returns as a whole may be adversely affected by the unfavorable performance of even a single company, industry, country or Portfolio Fund. Custody Risk. When a Corbin Fund invests assets in a Portfolio Fund, such Corbin Fund will not have custody of the invested assets or control over its investment. Therefore, despite due diligence and monitoring, there is always the risk that an Investment Manager could divert or abscond with the assets, fail to follow agreedupon investment strategies or engage in other misconduct. Portfolio Funds in which a Corbin Fund’s assets will be invested likely will not have registered their securities under federal or state securities laws. In addition, Investment Managers may not be registered as investment advisers under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). This lack of regulatory oversight may enhance the risk of misconduct by Investment Managers. Additionally, bankruptcy or fraud at institutions, such as brokerage firms, banks or administrators, into whose custody Portfolio Funds have placed their assets could impair the operational capabilities or the capital position of Portfolio Funds and may, in turn, have an adverse impact on a Corbin Fund. A Corbin Fund’s assets may be held in one or more accounts maintained for a Corbin Fund by counterparties, including their prime brokers. The stability and liquidity of repurchase agreements, swap transactions, forward transactions and other over-the-counter derivative transactions depend in large part on the creditworthiness of the parties to the transactions. Corbin will attempt to monitor on an ongoing basis the creditworthiness of firms with which it will enter into repurchase agreements, swaps, or other over-the-counter derivatives. If there is a default by the counterparty to such a transaction, a Corbin Fund will, under most circumstances, have contractual remedies pursuant to the agreements related to the transaction. However, exercising such contractual rights may involve delays or costs which could result in the net asset value of a Corbin Fund being less than if that Corbin Fund had not entered into the transaction. Furthermore, there is a risk that any such counterparties could become insolvent and/or the subject of insolvency proceedings. The insolvency of a Corbin Fund’s counterparty is likely to impair the operational capabilities of the assets of that Corbin Fund. Although Corbin monitors the financial condition of the counterparties it uses, if one or more of a Corbin Fund’s counterparties were to become insolvent or the subject of insolvency proceedings in the U.S. (either under the Securities Investor Protection Act or the United States Bankruptcy Code), there exists the risk that the recovery of that Corbin Fund’s securities and other assets from such prime broker or broker-dealer or other counterparty will be delayed or be of a value less than the value of the securities or assets originally entrusted to such prime broker or broker-dealer or other counterparty. In addition, a Corbin Fund may have counterparties located in various jurisdictions outside the U.S. Such local counterparties are typically subject to various laws and regulations in various jurisdictions that are generally designed to protect their customers in the event of their insolvency. However, the practical effect of these laws and their application to a Corbin Fund’s assets are subject to substantial limitations and uncertainties. Because of the large number of entities and jurisdictions involved and the range of possible factual scenarios involving the insolvency of the counterparty, it is impossible to assess the impact of their insolvency on a Corbin Fund and its assets. Investors should assume that the insolvency of any counterparty would result in a loss to a Corbin Fund, which could be material. Under certain circumstances, including certain transactions where a Corbin Fund’s assets are pledged as collateral for leverage from a non-broker-dealer custodian or a non-broker-dealer affiliate of a prime

broker, or where a Corbin Fund’s assets are held at a non-U.S. custodian, the securities and other assets deposited with the custodian or broker may not be clearly identified as being assets of that Corbin Fund and that Corbin Fund could be exposed to a credit risk with regard to such parties. Custody services in certain non-U.S. jurisdictions remain undeveloped and, accordingly, there is a transaction and custody risk of dealing in certain non-U.S. jurisdictions. Managed Account Allocations. Corbin may place assets with a number of Investment Managers through opening discretionary managed accounts rather than investing in Portfolio Funds. The assets of each Corbin Fund, however, are typically held as a single pool, and all of the assets of each Corbin Fund are available to meet all of its liabilities, regardless of whether the liabilities are attributable to a particular managed account. Given the leverage which certain Investment Managers may employ, a managed account may expose Corbin Funds to theoretically unlimited liability. In order to limit the liability of Corbin Funds solely to the assets Corbin places in a particular managed account, Corbin Funds may make managed account allocations through a separate investment vehicle. Corbin may also contractually limit leverage of certain managed accounts. Additionally, because Investment Managers may have authority to trade and settle managed account assets, there is a risk that such Investment Managers could divert or abscond with the assets, fail to follow agreed upon investment strategies or engage in other misconduct. Defaults by Affiliated Funds. A Corbin Fund may be subject to the credit risk of other Corbin Funds to the extent that one or more of such Corbin Funds were to default under an agreement or obligation. A default by such other Corbin Fund may in certain instances constitute a default by the Corbin Fund or otherwise adversely impact the Corbin Fund. Indemnification of Investment Managers. It is expected that each Portfolio Fund in which Corbin Funds invest will be required to indemnify its general partner, Investment Manager and other entities or individuals involved in managing the Portfolio Fund for certain losses arising out of their activities on behalf of such Portfolio Fund. Such indemnification obligations, if required to be paid, could potentially reduce the returns to investors. These indemnification obligations would be payable from the assets of Corbin Funds. Portfolio Funds may purchase insurance to cover such potential liabilities although there can be no assurance that any such insurance will be sufficient, available to satisfy the claims that may arise or generally available on commercially reasonable terms. Lack of Investment Manager Capacity. Investment Managers and Portfolio Funds they manage may have limited capacity or may close to new or additional investments. There is no guarantee that an Investment Manager with whom Corbin seeks to invest on behalf of Corbin Funds will have available capacity for investment by any or all Corbin Funds wishing to invest. Access to Information from Investment Managers. Corbin selects Investment Managers based upon various factors. When it carries out diligence on Investment Managers, Corbin may not always be provided with information it requests because this information may in certain instances be considered proprietary information by the particular Investment Manager. This lack of access to information may make it more difficult for Corbin to select, allocate

assets among, and evaluate Investment Managers. In addition, Corbin may not learn of significant structural events, such as personnel changes, major asset withdrawals or substantial capital growth, until after the fact. In addition, one or more Investment Managers may engage in improper or fraudulent conduct, including unauthorized changes in investment strategy, misappropriation of assets and unsupportable valuations of portfolio securities. Corbin Funds may rely upon representations made by Investment Managers, accountants, attorneys and other investment professionals. If any such representations are misleading, incomplete, or false, this may result in the selection of or continued investment with Investment Managers that might otherwise have been eliminated from consideration or terminated had more accurate and complete information been made available. The processes of identifying and conducting due diligence on an Investment Manager and negotiating and executing agreements can be time consuming and burdensome and result in significant transaction costs, which generally are borne by Corbin Funds. Investment Manager Accounting and Reporting. Corbin Funds may seek to make seed capital investments that entitle them to revenue or income participations, including from management and performance fees received by Investment Managers from managing seed capital investments. If an Investment Manager under-reports the amount of revenues or income (as applicable) that it has generated or attempts to use other accounting or other methods in order to avoid its obligations to share revenues or income (as applicable), Corbin Funds may be adversely affected. In connection with seed capital investments, Corbin Funds may seek to obtain certain investment terms designed to avert any such under-reporting or similar circumvention of their economic participation. However, there is no assurance that such investment terms will fully protect Corbin Funds from such risks.

B. Structural and Operational Risks Effects of Substantial Withdrawals/Redemptions. If a large Investor, including a principal or affiliate of Corbin, or another Corbin Fund, withdraws or redeems all or a substantial portion of its assets from a Corbin Fund, or if a Corbin Fund receives substantial requests for withdrawals or redemptions by other Investors within a limited period of time, a Corbin Fund may be required to liquidate investments and/or interests or shares in Portfolio Funds sooner than would otherwise be desirable, which could adversely affect the performance of such Corbin Fund. In addition, regardless of the period of time in which withdrawals or redemptions occur, the resulting reduction in a Corbin Fund’s net assets, and thus in its equity base, could make it more difficult for a Corbin Fund to diversify its holdings and achieve its investment objective and will result in a less liquid portfolio. Further, the remaining Investors may experience higher pro rata operating expenses, thereby producing lower returns. Under certain circumstances, CCPM or the board of directors of a particular Corbin Fund may suspend or limit withdrawals or redemptions (in whole or in part), or take other action to manage the liquidity, withdrawals and redemptions of a Corbin Fund, as they deem necessary in their sole discretion. Conflicts of Interest and Other Activities of CCPM, Corbin and Their Affiliates. Conflicts of interest exist in the structure and operation of Corbin Funds, including the duty of CCPM, Corbin and the Affiliated Persons to act in the best interests of Corbin Funds and the competition for investment opportunities with the Affiliated Persons and other collective investment vehicles or accounts (including single investor investment vehicles and accounts) organized, managed, advised, sub-advised or owned by CCPM, Corbin or Affiliated Persons. See the Conflicts Table in Item 11.

Borrowing and Use of Leverage. Corbin Funds borrow money for investment leverage purposes and/or for cash management purposes. Cash management leverage is used principally to manage timing mismatches between investments in and withdrawals or redemptions from Portfolio Funds and Investor cash flows, as well as to reduce the need to call capital from Investors in Corbin Funds that are closed-end. Portfolio Funds may employ leverage for various reasons, including for the purpose of making investments and hedging their exposure to market and credit risk. Leverage may take various forms, including borrowed money, loans generated by a prime broker for the purchase or sale of securities, uncovered short positions, uncovered put positions, repurchase and reverse repurchase agreements, derivative instruments that are inherently leveraged, credit facilities, letters of credit, and other forms of direct and indirect borrowing. The use of leverage creates special risks and may significantly increase investment risk. Leverage can create an opportunity for greater yield and total return but, at the same time, can accelerate and magnify declines in the value of a Corbin Fund’s or a Portfolio Fund’s investments. Leverage will also increase Corbin Funds’ exposure to interest and other costs incurred by Portfolio Funds. Any investment income and gains earned on investments made through the use of leverage that are in excess of the interest costs associated therewith may cause the net asset value of a Corbin Fund and/or Portfolio Fund to increase more rapidly than would otherwise be the case. Conversely, where the associated interest costs are greater than such income and gains, the net asset value of a Corbin Fund and/or Portfolio Fund may decrease more rapidly than would otherwise be the case. Prime Brokers; Clearing Brokers; Futures Commission Merchants. Securities and cash held in customers’ accounts at prime brokers that are U.S.-registered broker-dealers will not be available to the non-customer creditors of the prime broker. Nonetheless, if a prime broker became insolvent and there were not sufficient customer assets to pay all customers in full, then the securities and cash held in customers’ accounts at the prime broker would be distributed pro rata among customers. Different results may occur in the event that a U.S. prime broker sub-custodies its assets with a foreign sub-custodian outside the United States. Different results, including loss of U.S. regulatory protections, may also occur in the event that the customer of a U.S. prime broker permitted the prime broker to (i) rehypothecate or lend its assets or (ii) transfer its assets to a prime broker or other entity that is not a U.S.-registered broker-dealer. If assets are held by a prime broker that is not a U.S.-registered broker-dealer, the U.S. regulatory protections do not apply. In certain jurisdictions, with authority from the customer, such assets may be borrowed, lent or otherwise used by the prime broker for its own purposes. Corbin Funds’ assets held in these depositories are also subject to the risk that events could occur that would hinder or prevent the availability of these funds for distribution to customers including Corbin Funds. Such events might include actions by the government of the jurisdiction in which the depository is located, including expropriation, taxation, moratoria and political or diplomatic events. In the event of the insolvency of the prime broker, customers may rank as unsecured creditors and may not be able to recover equivalent assets in full. Corbin Funds may consent to the transfer and reuse of their assets on customary terms under their service agreements with custodians or prime brokers. Such transfer and reuse are restricted by regulatory limitations imposed upon such custodians and prime brokers. The U.S. Commodity Exchange Act, as amended (the “CEA”), requires a futures commission merchant to segregate funds deposited in a customer’s commodity futures account. If a futures commission merchant fails to properly segregate customer funds, the customer may be subject to a risk of loss of its funds on deposit in the event of such futures commission merchant’s bankruptcy or insolvency. In addition, under certain circumstances, such as the inability of another customer of a futures commission merchant or its own inability to satisfy substantial deficiencies in such other customer’s account, the customer may be subject to a risk of loss of its funds on deposit even if such funds are properly segregated. In the case of

any such bankruptcy or customer loss, the customer might recover only a pro rata share of all property available for distribution to all of the futures commission merchant’s customers. If no property is available for distribution, the customer would not recover any of its assets. In the event of the insolvency of a broker or futures commission merchant, the customer may encounter delays in establishing its rights to assets held by the insolvent prime broker and/or futures commission merchant. Moreover, pursuant to the contracts entered into between Corbin Funds and/or Portfolio Funds and their prime brokers and/or futures commission merchants, Corbin Funds and/or Portfolio Funds may be required to post significant margin amounts under certain circumstances. If unable to meet such requirements, the prime broker and/or futures commission merchant would be authorized to close out the positions of Corbin Funds and/or Portfolio Funds, as the case may be. An immediate closing of such positions would expose Corbin Funds and/or Portfolio Funds, as the case may be, to the risk that its positions would be liquidated at unfavorable prices. Loan Facilities. Corbin Funds may utilize loan facilities with the result of creating leverage. Such facilities, therefore, generate the same risks attendant to purchasing securities on margin. Corbin Funds generally provide collateral to the banks providing the loan facilities by registering the interests of Portfolio Funds and/or Corbin Funds that they own in the names of such banks, their nominees or a custodian or by pledging other assets as security for such loans. This procedure exposes Corbin Funds to the risk that for whatever reason, including without limitation the default, insolvency, negligence, misconduct or fraud of such banks, their nominees or a custodian, Corbin Funds will not reacquire the ownership of such interests upon the repayment by Corbin Funds of such loans. Also, Corbin Funds will be unable to reacquire such interests if they default on such loans. Corbin Funds’ failure or inability to reacquire such interests from the banks in whose name the interests are registered in support of the loan facilities could entangle them in protracted litigation and, potentially, result in the complete loss of such interests. While Corbin Funds will enter into loan facilities only with banks they believe to be of international repute, lenders’ credit risk could deteriorate extremely rapidly and unexpectedly under certain circumstances, and there can be no absolute certainty that such banks will return such interests to Corbin Funds upon the repayment of such loans. The cost and availability of leverage is highly dependent on the state of the broader credit markets, which is difficult to accurately forecast. At times, it may be difficult to obtain or maintain the desired degree of leverage. In addition, there can be no assurance that a Corbin Fund will be able to obtain leverage on favorable terms and/or terms available to competitors in the market or otherwise, including with respect to interest rates. In the event that any such loan facility is terminated by a bank or by the Corbin Fund and the Corbin Fund is unable to secure a new loan facility from another bank, or in the event that the Corbin Fund defaults on any such loan facility, investments of the Corbin Fund may be liquidated and/or sold at unfavorable prices. The rights of creditors to the assets of a debtor are prior to those of equity investors. As a creditor, the bank would have a first priority claim on any cash and assets held by the Corbin Fund, which could reduce or eliminate the liquidity available. “Master-Feeder” Structure. Certain Corbin Funds present risks typical of a “master-feeder” fund structure to Investors. Smaller Investors in a Corbin Fund may be materially affected by the actions of larger Investors in that Corbin Fund. For example, if a larger Investor withdraws from a Corbin Fund, the remaining Investors may experience higher pro rata operating expenses, thereby resulting in lower net returns. A Corbin Fund may

become less diverse due to redemption by a larger Investor, resulting in increased risk for that Corbin Fund. A conflict of interest among Investors may also exist in that U.S. taxable investors in Corbin Funds may benefit from the recognition of dividend income or long-term capital gains, whereas investors in Corbin Funds domiciled outside the U.S. would be in the same U.S. tax position if the gains were shortterm or long-term and may be in a worse position if Portfolio Funds realize dividend income. Trade Errors. Although Corbin exercises due care in making and implementing investment decisions, employees of Corbin may from time to time make trading errors. When a trade error is made on behalf of a Client, Corbin will use its best efforts to terminate the trade or otherwise correct the error. Any trading losses, liabilities, damages, expenses or costs resulting from trade errors are generally borne by the Client unless an error is the result of Corbin’s gross negligence or intentional misconduct, or, if applicable, the result of conduct by Corbin that is inconsistent with a different standard of care. Investment Managers generally have adopted similar policies with respect to trade errors and as such, trade errors made by them in the course of managing Portfolio Funds may be borne, in part, by Corbin Funds that invest in the Portfolio Fund. Estimates. In most cases, Corbin has little or no ability to assess the accuracy of the valuations received from an Investment Manager or the administrator of a Portfolio Fund. Certain securities in which Portfolio Funds invest may not have a readily ascertainable market price. Furthermore, the valuations received by a Corbin Fund from such Investment Managers may typically be estimates only, subject to revision through the end of each Portfolio Fund’s annual audit. Revisions to a Corbin Fund’s gain and loss calculations will be an ongoing process, and no appreciation or depreciation figure can be considered final until a Corbin Fund’s annual audit is completed. Valuations. For Commingled Funds, Corbin, CCPM or the Commingled Fund’s board of directors, as applicable, is responsible for determining the fair value of the Commingled Fund’s assets and liabilities in accordance with the Constituent Documents of the respective Commingled Fund, U.S. generally accepted accounting principles and Corbin’s valuation policies in effect from time to time. The value of assets and liabilities of the Commingled Funds shall be determined in good faith and such determination shall be conclusive and binding on all Investors. Corbin, CCPM or a Commingled Fund’s board of directors, as applicable, has delegated the calculation of the value of the Commingled Funds’ assets and liabilities to their respective administrators, subject to the supervision, control and discretion of Corbin. In calculating the value of a Commingled Fund’s assets and liabilities, the administrator will rely on financial information provided by (i) Portfolio Funds and their service providers, (ii) service providers of the Commingled Fund, including Corbin, (iii) Investment Managers and/or (iv) other independent third parties. For certain Customized Funds, Corbin’s involvement in the valuation process often differs. Investment Managers as well as Corbin, CCPM and certain directors will generally face a conflict of interest in valuing assets and liabilities because the value thereof will affect their compensation. Accounting Standards. Various accounting standards, including, without limitation, Accounting Standards Codification Topic 740, could cause a Corbin Fund to be required to reserve for certain expenses or taxes or could otherwise impact the net asset value of a Corbin Fund. These accounting standards could have a material adverse effect on the periodic calculations of the net asset value of a Corbin Fund, including reducing the net asset

value of a Corbin Fund to reflect reserves for expenses or taxes that may be payable in respect of prior periods by a Corbin Fund. This could adversely affect certain Investors, depending upon the timing of their contribution to, and withdrawal from, a Corbin Fund. Systems and Operational Risks. Corbin Funds depend on Corbin to develop and implement appropriate systems for Corbin Funds’ activities. Corbin Funds rely heavily on financial, accounting and other data processing systems to execute, clear and settle transactions, to monitor its portfolio and capital, and to generate risk management and other reports that are critical to the oversight of Corbin Funds’ activities. Certain Corbin Funds’ and Corbin’s activities will be dependent upon systems operated by third parties, including prime brokers, the administrator, market counterparties and other service providers, and Corbin may not be in a position to verify the risks or reliability of such third-party systems. Failures in the systems employed by Corbin, prime brokers, the administrator, counterparties, exchanges and similar clearance and settlement facilities and other parties could result in mistakes made in the confirmation or settlement of transactions, or in transactions not being properly booked, valued or accounted for. Disruptions in Corbin Funds’ operations may cause Corbin Funds to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing failures or disruptions could have a material adverse effect on Corbin Funds and the Investors’ investments therein. Cyber-Security Risk. Like other business enterprises, the use of the Internet and other electronic media and technology exposes Corbin, Corbin Funds, their service providers and their respective operations to potential risks from cyber-security attacks or incidents (collectively, “Cyber-Events”). Cyber-Events may include, for example, unauthorized access to systems, networks or devices (such as, for example, through “hacking” activity), infection from computer viruses or other malicious software code, and attacks which shut down, disable, slow or otherwise disrupt operations, business processes or website access or functionality. In addition to intentional Cyber-Events, unintentional Cyber-Events can occur, such as, for example, the inadvertent release of confidential information due to, for example, damage or interruption from computer viruses, network failures, computer and telecommunication failures, usage errors, power outages and catastrophic events such as fires, tornadoes, floods hurricanes and earthquakes. Any Cyber-Event could adversely impact Corbin, Corbin Funds and their Investors and cause Corbin, Corbin Funds and their Investors to incur financial loss and expense, as well as face exposure to regulatory penalties, reputational damage, and additional costs associated with corrective measures. A cyber-security breach could also result in the loss or theft of Investor data, including personal identifiable information. A Cyber-Event may cause Corbin, Corbin Funds or their service providers to lose proprietary information, suffer data corruption, lose operational capacity (such as, for example, the loss of the ability to process transactions, calculate Corbin Funds’ net asset value, or allow Investors to transact business), and/or fail to comply with applicable privacy and other laws. Among other potentially harmful effects, Cyber-Events also may result in theft, unauthorized monitoring and failures in the physical infrastructure or operating systems that support Corbin, Corbin Funds or their service providers. In addition, Cyber-Events affecting issuers or Portfolio Funds in which Corbin Funds invest could cause Corbin Funds’ investments to lose value. The nature of malicious cyber-attacks is becoming increasingly sophisticated, and despite efforts to confirm the existence of adequate controls, Corbin cannot control the cyber systems and cyber-security systems of Investment Managers, issuers or third-party service providers. Lack of Control Over Management. Investors are generally precluded from participation in the management of Corbin Funds. Investors must rely on Corbin or CCPM to manage and conduct the affairs of Corbin Funds. Corbin has wide latitude in

making investment decisions. If an Investor becomes dissatisfied with the operation of a Corbin Fund or the investment of its assets, the Investor’s only recourse will be to withdraw/redeem from the Corbin Fund in accordance with the applicable withdrawal/redemption terms, if available. Similarly, Corbin Funds will generally be precluded from participation in the management of Portfolio Funds. Corbin Funds must rely on Investment Managers to manage and conduct the affairs of Portfolio Funds. Investment Managers have a wide latitude in making investment decisions. If a Corbin Fund becomes dissatisfied with the operation of a Portfolio Fund or the investment of its assets, the Corbin Fund’s only recourse will be to redeem/withdraw from the Portfolio Fund in accordance with the Portfolio Fund’s redemption/withdrawal terms or seek a purchaser of its interest in such Portfolio Fund. Co-Investments. Corbin expects to make co-investments with third parties (including Investment Managers, other parties advised by Corbin, or other related persons of Corbin) through consortiums of Investors, partnerships, joint ventures, or other similar arrangements. Such investments will involve risks in connection with such third-party involvement, including the possibility that any such third party may have financial, legal, or regulatory difficulties that have a material adverse effect on such investment, may have economic or business interests or goals that are inconsistent with those of Corbin Funds, may pursue interests inconsistent with those of Corbin Funds, may default on their obligations, and/or may be in a position to take (or block) action in a manner contrary to the relevant investor’s investment objective. In addition, an investor may in certain circumstances be liable for the actions of its co-investors. On occasion, Corbin Funds may fund, or commit to fund, an investment on behalf of certain co-investors in order to consummate a transaction, ensure Corbin Funds are afforded an investment opportunity or otherwise. In the event that Corbin is not able to syndicate a portion of the investment, Corbin Funds may have an allocation to an investment that is larger than originally anticipated. Such investments may involve performance charges, incentive compensation arrangements, and/or other fees payable to such third parties. There may be instances in which Corbin desires to pursue a co-investment opportunity but is unable to find an Investment Manager with whom to co-invest or is unable to come to an economic agreement with the Investment Manager on the terms of the co-investment. Warehoused Investments Corbin may, from time to time, cause one or more Corbin Funds to warehouse an investment that is expected to be sold, in whole or in part, to one or more Portfolio Funds in the future. These Corbin Funds may (or may not) be or become an investor in any such Portfolio Fund(s). Corbin will have a conflict of interest when determining when to sell warehoused investments to such Portfolio Fund(s) because the amount of interest (in the case of a loan) that will accrue to and be paid to such Corbin Funds upon their eventual sale will be affected. In addition, because the value of warehoused investments may decrease prior to their anticipated sale by such Corbin Funds or for other reasons, there can be no assurance that such Portfolio Fund(s) will proceed with the purchase of such investments, and as a result, Corbin Funds may ultimately own investments beyond the expected holding period and in larger-than-expected size. Indemnification. Corbin Funds are generally required to indemnify Corbin, CCPM and/or certain affiliated persons, as well as certain of their agents. The indemnification obligations, if required to be paid, could potentially reduce the returns to Investors. The indemnification obligations would be payable from the assets of the applicable Corbin Fund. If the assets of such Corbin Fund are insufficient, Investors may be required to return distributions previously made to them. Furthermore, as a result of the exculpation provisions contained in the Constituent Documents, Investors may have a more limited right of action in certain

cases than they would in the absence of such limitations. Corbin Funds may purchase insurance but there can be no assurance that any such insurance will be sufficient, available to satisfy the claims that may arise or generally available on commercially reasonable terms. Possibility of Fraud or Other Misconduct of Employees and Service Providers. Misconduct by employees and principals of Corbin, officers or employees of Investment Managers and Portfolio Funds, and service providers to the foregoing and/or their respective affiliates could cause significant losses to Corbin Funds. Misconduct may include entering into transactions without authorization, the failure to comply with operational and risk procedures, including due diligence procedures, misrepresentations as to investments being considered by a Corbin Fund, the improper use or disclosure of confidential or material non-public information, which could result in litigation or serious financial harm, including limiting a Corbin Fund’s business prospects or future marketing activities, and non-compliance with applicable laws or regulations and the concealment of any of the foregoing. Such activities may result in reputational damage, litigation, business disruption and/or financial losses to Corbin Funds. No assurances can be given that Corbin will be able to identify or prevent such misconduct. Public Health Epidemic Risk. Pandemics, such as the COVID-19 pandemic, and the resulting quarantines and travel restrictions imposed by governments, can have major negative impacts on the global economy and the economies of particular countries or regions, including the United States, and thereby may adversely affect the performance of Corbin Funds, Portfolio Funds and their underlying investments. The likelihood, timing, severity, and possible resurgence of outbreaks of infectious disease, including COVID-19 variants, are unpredictable. The extent to which any outbreak of infectious disease, including COVID-19 variants, will impact Corbin Funds will depend on many factors beyond Corbin’s control, including the speed of contagion, the development and implementation of effective preventative measures and possible treatments, the scope of governmental and other restrictions on travel and other activity, and public reactions to these factors. Any plans and preparations for such eventualities, by Corbin, Investment Managers or any other person, may not be adequate or effective for their intended purpose. Force Majeure. Assets may be affected by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fires, floods, earthquakes, outbreaks of infectious disease, pandemics or any other serious public health concerns, wars, terrorism and labor strikes). Natural disasters, epidemics and other acts of God, which are beyond the control of Corbin Funds and Portfolio Funds, may negatively affect the economy, infrastructure and livelihood of people throughout the world. For example, southeast Asia and many countries in Asia, including China, Japan, Indonesia and Australia have been affected by earthquakes, floods, typhoons, drought, heat waves or forest fires. Disease outbreaks have occurred throughout the world in the past, and any prolonged occurrence of infectious disease, or other adverse public health developments or natural disasters, in any country related to a Corbin Fund’s or a Portfolio Fund’s investments may have a negative effect on the Corbin Fund or the Portfolio Fund. In addition, there are increased risks relating to Corbin’s and Investment Managers’ reliance on each of their computer programs and systems if Corbin’s and Investment Managers’ personnel are required to work remotely for extended periods of time as a result of events such as the outbreak of infectious disease or other adverse public health developments or natural disasters, including an increased risk of cyber-attacks and unauthorized access to a Corbin Fund’s, a

Portfolio Fund’s, Corbin’s or an Investment Manager’s computer systems. Additionally, there is a risk of terrorist attacks on the United States and elsewhere, which could cause a significant loss of life and property damage and disruptions in global markets. For example, as a result of any terrorist attack, economic and diplomatic sanctions may be in place or imposed on certain countries and military action may be commenced. Some force majeure events may negatively affect the ability of a party (including a Corbin Fund, a Portfolio Fund or a counterparty to either of them) to perform its obligations until it is able to remedy the force majeure event. In addition, the cost to a Corbin Fund and the Portfolio Fund of repairing or replacing damaged assets resulting from such force majeure event could be considerable. Certain force majeure events (such as war or an outbreak of infectious disease) could have a broader negative impact on the world economy and international business activity generally, or otherwise negatively impact any country related to a Corbin Fund’s or Portfolio Fund’s investments. Any of the foregoing may therefore negatively affect the performance of Corbin Funds or Portfolio Funds. Losses resulting from any of the foregoing may either be uninsurable or only insurable at such high rates as to make such coverage impracticable. If any major uninsured loss were to occur with respect to any of a Corbin Fund’s or a Portfolio Fund’s investments, the Corbin Fund and/or the Portfolio Fund could incur substantial losses. Artificial Intelligence and Machine Learning Risks. The emergence of recent technology developments in artificial intelligence and machine learning such as OpenAI and ChatGPT (collectively, "Machine Learning Technology") can pose risks to Corbin, Corbin Funds and Portfolio Funds. Corbin has begun to use Machine Learning Technology in various processes, including in connection with its investment research process. Corbin is likely to be further exposed to the risks of Machine Learning Technology through third parties (including, but not limited to, Corbin’s or Portfolio Funds’ service providers or counterparties) that use Machine Learning Technology, and Corbin may not always be aware of such use. Corbin cannot necessarily control the manner in which products created and/or utilized by third parties are developed or maintained. Furthermore, due to the rapidly evolving nature of Machine Learning Technology and its widespread potential uses, Corbin expects that its policies and procedures will continue to evolve in response to such unique challenges. Machine Learning Technology is often highly reliant on the collection and analysis of large amounts of data, and in many instances, it may not be possible or practicable to incorporate all potentially relevant data into the dataset that Machine Learning Technology utilizes or to evaluate the source and the reliability of the data being analyzed. Further, the outputs of Machine Learning Technology may be inaccurate or unreliable and are also susceptible to errors in such outputs' creation or subsequent analysis. Additionally, the use of Machine Learning Technology may involve (i) cybersecurity risks (including, but not limited to, the increased likelihood that Corbin, Investment Managers, Corbin Funds or Portfolio Funds’ investments become a victim of cybercrime), (ii) threats to proprietary and confidential information, (iii) intellectual property violations, (iv) access to, or disclosure of, personal information in violation of applicable data protection laws, and (v) other risks that are not currently foreseen. Such inaccuracies, errors, risks, threats, and/or violations could have adverse impacts on Corbin, Investment Managers, Corbin Funds or Portfolio Funds’ investments. Machine Learning Technology continues to develop rapidly, making it difficult to predict the future risks that may arise from such developments.

C. Market and Investment Risks ➢ Past Performance Is Not Indicative of Future Performance ➢ Securities to Be Purchased ➢ Illiquid Investments

➢ Equity Risks ➢ Long/Short Risks ➢ Investments in Initial Public Offerings ➢ Investments in Special Purpose Acquisition Companies(“SPACs”)

Investments in Private SPACs or Investments Prior to an IPO

Potential Claims Against SPAC Trust Funds

Risks Related to Warrants

Risk of a SPAC Being Deemed an Investment Company

SPAC Sponsor Shares

➢ Securities Believed to Be Undervalued or Incorrectly Valued ➢ Unlisted Securities ➢ Exchange-Traded Funds ➢ Private Investment in Public Companies ➢ Systematic Trading ➢ Leverage ➢ Counterparty Risk ➢ Securities on Margin ➢ Call Options ➢ Put Options ➢ Stock Index Options ➢ Forward Contracts and Other Principal Transactions and Derivatives ➢ Hedging ➢ Credit Derivative Transactions ➢ Swap Agreements ➢ Futures Trading ➢ Currencies

➢ Investment in Fixed-Income Securities ➢ Debt Securities ➢ Distressed and High-Yield Securities ➢ Short Selling ➢ Defaulted Securities ➢ Mortgage-Backed Securities

Residential Mortgage-Backed Securities

Commercial Mortgage-Backed Securities

➢ Asset-Backed Securities ➢ Structured Credit Instruments ➢ Lender Liability Consideration and Equitable Subordination ➢ Post-Reorganization Securities ➢ Sale or Assignment of Originated Loans ➢ Private Lending

General Credit Risks of Loan Origination

Lower Credit Quality Loans

Nature of Mezzanine and Other Subordinated Investments

Risks Associated with Originating Loans to Companies in Distressed Situations

Ability to Originate Loans on Advantageous Terms; Competition and Supply

Nature of Investments in Secured Loans

Second-Lien Debt

Covenant-Lite First-Lien Loans

Bank Loans and Participations

Trade and Other General Unsecured Claims

Unfunded Loans

Nature of Bankruptcy Proceedings

Fraud

Lender Liability Considerations and Equitable Subordination

Marketplace/Peer-to-Peer Lending

➢ Litigation Finance

Evolving Nature of Litigation Finance Rules and Regulations

Court Approval Process and Delays

Investment Selection and Structuring – Cases Subject to Adverse Outcomes

Risk of Subpoena or Discovery

Subsequent Events

Terminated or Rejected Settlements Risk

Reliance on Lawyers

Delinquency, Default or Foreclosed Investments

Publicity Risks

Usury and Regulation

Volatility Risks

Uncertain Tax Positions

➢ Collateralized Loan Obligations ➢ Collateralized Debt Obligations ➢ Repurchase and Reverse Repurchase Agreements ➢ Specialty Finance Investments ➢ Special Purpose Acquisition Companies ➢ Risks of Real Estate Investments Generally ➢ Warehoused Investments ➢ Risks related to Real Estate Debt and Preferred Equity ➢ Bankruptcy Involving Non-U.S. Companies ➢ Municipal Obligations

➢ Commercial Paper ➢ Variable and Floating Rate Securities ➢ Creditor’s Committee and/or Board Participation ➢ Non-Controlling Investments ➢ Over-Commitment ➢ Seed and Anchor Investments ➢ Risks Related to Continuation Funds ➢ Risks Related to Investments in Land/New Development ➢ Information Restrictions ➢ Off-Balance Sheet Risk ➢ Resale and Transfer Restrictions ➢ Regulatory Intervention ➢ Portfolio Fund Liquidity ➢ Investing in Non-U.S Securities ➢ Trading on Non-U.S Exchanges ➢ Need for Follow-On Investments ➢ Foreign Exchange Controls ➢ Alternative Investment Funds Managers Directive ➢ EU Sustainable Finance Disclosure Regulation ➢ European Market Infrastructure Regulation ➢ Pay-to-Play Laws, Regulations and Policies ➢ Suspensions of Trading ➢ Risk of Litigation ➢ General Economic Conditions ➢ Systemic Risk ➢ Sustainability or Impact Investing Risk

Newness of Strategy

Impact on Performance Due to Exclusion of Certain investments

Ability to source investments

Dependence on Third Party Data and Information

Lack of Standardization of Sustainability and/or Impact Criteria, Frameworks, Methodologies

Lack of Regulation

➢ Public Health Epidemic Risk ➢ Government Policies and Changes in Laws ➢ Monetary Policy and Government Intervention ➢ Regulation and Enforcement; Litigation ➢ Geo-Political ➢ Lack of Liquidity in Markets ➢ ERISA Restrictions ➢ Availability of Investment Opportunities ➢ Small and Medium Capitalization Companies ➢ Arbitrage Strategies ➢ Diversification ➢ Merger Arbitrage ➢ Appraisal Arbitrage ➢ Event Driven Investments ➢ Cryptocurrency/Digital Assets ➢ Secondary Market Purchases ➢ Prime Brokers; Clearing Brokers; Futures Commission Merchants ➢ Risks Associated with “Side Pockets” The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment in a Corbin Fund. An investor in a Corbin Fund must be able to bear the risk of a complete loss of the investment.

Item 9. Disciplinary information

Corbin does not have any legal, financial or other “disciplinary” item to report to you. Corbin is obligated to disclose any disciplinary event that would be material to you when evaluating a client/adviser relationship.

Item 10. Other financial industry activities and affiliations

Corbin and Corbin Affiliates As noted above, CCPM, an affiliate of Corbin, is the general partner of each Corbin Fund that is a limited partnership and is the manager of a Corbin Fund that is a limited liability company. CCPM receives performance-based compensation from certain Corbin Funds. Payment of compensation that is based on the performance of Corbin Funds may create an incentive for Corbin (because of the potential benefit to its affiliate, CCPM) to select riskier or more speculative investments than would be the case in the absence of such compensation. Corbin is exempt from registration with the Commodity Futures Trading Commission (the “CFTC”) as a commodity trading advisor.

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With respect to certain Corbin Funds, Corbin has claimed temporary no-action relief from registration with the CFTC as a commodity pool operator, and with respect to other Corbin Funds, Corbin relies on the so-called “de-minimis” exemption to registration as a commodity pool operator. With respect to certain Corbin Funds, CCPM has claimed temporary no-action relief from registration with the CFTC as a commodity pool operator, and with respect to other Corbin Funds CCPM relies on the “de-minimis” exemption to registration as a commodity pool operator. Corbin has also claimed registration exemptions from certain Canadian provinces. Corbin Employees Two of the directors of the offshore Corbin Funds are owners and officers of Corbin. Other Counterparties Subject to applicable law, Corbin or certain Corbin Funds may engage service providers including administrators, custodians, credit facility providers, brokers, dealers and other counterparties, including ISDA counterparties that have relationships, including fiduciary relationships, with certain Investors or other Corbin Funds. Corbin negotiates all counterparty agreements in good faith. (See Item 11 – Code of Ethics for a further discussion of potential conflicts of interest and Item 14 – Client Referrals and Other Compensation for discussion on Solicitors (as defined below) that refer Investors to Corbin Funds.)

Item 11. Code of ethics, participation in client transactions and personal trading

Personal Trading Corbin has adopted a Code of Ethics (the “Code”) that obligates all of Corbin’s supervised persons to put the interests of Clients before their own personal interests and to act honestly and fairly in all respects in their dealings with Clients. Corbin’s supervised persons are also required to comply with all applicable

federal securities laws. Corbin’s access persons (“access persons”) are required to disclose their holdings in reportable securities and provide reports regarding personal trading. The Code imposes certain restrictions on trading conducted by access persons in their personal accounts and such trading is reviewed by Corbin’s chief compliance officer (the “Compliance Officer”) or his designee.

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The Code also contains policies relating to, among other things, outside business activities, political contributions, charitable donations, service on boards of directors or similar governing bodies of other organizations, and gifts and entertainment. Investors and prospective investors may obtain a copy of the Code by contacting Corbin via email at clientservices@corbincapital.com or by telephone at (212) 634-7373. Corbin offers many different products and services and there are several potential conflicts of interest which may arise, including, but not limited to, those identified below. Clients and Investors should be aware that conflicts will not necessarily be resolved in favor of their interests. Corbin will attempt to resolve such matters fairly and equitably, but even fair and equitable resolution can produce outcomes in favor of some Clients versus others. In this regard, Corbin has adopted, and continues to adopt, policies and procedures intended to prevent and mitigate such potential conflicts of interest. In all cases, Clients are made aware of the conflicts below as well as other conflicts through delivery of this Brochure and the Constituent Documents.

Potential Conflict

Mitigating Policy

Corbin may take an investment position or action for one or more Clients that may be different from, or inconsistent with, an action or position taken for one or more Client(s) having similar or different investment objectives. Clients may invest in different instruments or classes of securities of the same issuer. One or more Clients may have different investment objectives or pursue or enforce different rights with respect to a particular issuer in which it has invested, and those activities may have an adverse effect on other Clients. Clients may buy and/or sell the same securities at different prices and/or times and/or through different means.

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. A subset of Corbin’s compliance and risk assessment committee (the “CRAC”), which consists of Corbin’s chief financial officer, general counsel, Compliance Officer and director of operational due diligence, reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with Corbin’s Allocation Policy and consistent with applicable Constituent Documents. Corbin maintains detailed proxy voting policies and procedures and records of all votes. The Compliance Officer (or his designee) will seek to identify any conflicts that exist between the interests of Corbin and its clients to ensure that proxies are voted in the best interests of Corbin’s clients.

Capacity with an Investment Manager secured by a Client may inure to the benefit of other Clients. Similarly, co-investment opportunities or other investment opportunities that arise out of a Client’s investment with an Investment Manager have been and may continue to be allocated to other Clients or other third parties. A Client may make an investment that provides future benefits (e.g., a share of revenues) or other rights to other Clients. Such

Corbin maintains a detailed Allocation Policy. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with the Allocation Policy and consistent with applicable Constituent Documents. Corbin allocates expenses on a

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Client may share in such rights or other basis that it considers fair and equitable and in benefits, or such rights or other benefits may accordance with Constituent Documents and Corbin’s only inure to other Clients. However, such expense allocation policy. rights or other benefits may depend in whole or in part on investments being maintained, additional investments being made, or other obligations being assumed, by such Clients or other Clients. Corbin therefore has a conflict between the interests of Clients to which the benefits and rights accrue and the interests of Clients to which the benefits and rights do not accrue but whose investments are a condition to receiving such benefits. In addition, to the extent a particular Client’s eligibility for such rights and benefits, including reduced fees and other terms granted pursuant to most favored nations status, is dependent on the aggregate investment made by one or more other Clients, Corbin has an incentive to cause certain Clients to maintain and/or increase their investment. Certain access persons, through their position with Corbin, might come into possession of material non-public information. These access persons are in a position to trade in their personal accounts and may be in a position to trade on behalf of Clients in violation of the law.

Corbin maintains a policy on insider trading and Corbin also has a Code which requires all access persons to certify, at least annually, that they are in compliance with its policies. The Compliance Officer or a designee monitors the personal trading and personal holdings of access persons to ensure compliance with applicable policies. These policies include the use of a restricted list which is distributed to all access persons as well as controls to prevent access persons from trading in restricted issuers. Corbin also conducts and arranges for internal and/or external training that, among other things, addresses the proper procedures to be followed should an access person encounter material non-public information. Corbin maintains a robust policy on expert network usage, which includes call monitoring by the Compliance Officer or his designee for all non-group calls. The Compliance Officer, in conjunction with a regulatory consultant, conducts periodic electronic communication monitoring to identify potential insider trading risk.

To the extent that Portfolio Funds or other investments have limited capacity, Corbin may be required to choose among Clients in allocating such investment opportunities. Clients have different management and incentive fee structures. Corbin could choose

Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are

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to allocate a limited investment opportunity to a Client that has a more favorable fee structure. Corbin could also choose not to allocate Client expenses to a Client that has a more advantageous fee structure and instead allocate that portion of such expense to a Client with a less advantageous fee structure. Corbin incurs common expenses on behalf of Clients. Corbin may have an incentive to allocate ERISA or other valuable capacity that becomes available in certain Portfolio Funds or Commingled Funds to certain Clients or Investors who are deemed strategically important to Corbin. These Clients or Investors may pay higher fees for similarly situated investments compared to other Clients, Investors or prospects. Corbin may designate access persons to serve as representatives on an advisory committee or member of a board of directors, or participate in an equivalent body, of Portfolio Funds or an issuer. These representatives could have a conflict of interest between their duties and responsibilities to the Client(s) that invest in such Portfolio Fund or issuer and the duties and responsibilities, if any, such representatives have to the other investors in such Portfolio Fund or issuer. These representatives could also have a conflict of interest to the extent that Clients invested in such Portfolio Fund or issuer have different objectives. Corbin may cause a Client to purchase investments from, to sell investments to, to exchange investments with, or to transfer investments to, another Client. These cross transactions may benefit certain Clients at the expense of other Clients, and may, depending on the ownership profile of the particular Client, constitute principal transactions that would be prohibited under Section 206(3) of the Advisers Act without effective disclosure and consent.

fair and equitable over time in accordance with Corbin’s Allocation Policy and consistent with applicable Constituent Documents. Corbin allocates expenses on a basis that it considers fair and equitable and in accordance with Constituent Documents and Corbin’s expense allocation policy.

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with Corbin’s Allocation Policy and consistent with applicable Constituent Documents. Principal transactions must be approved or directed on a transaction-by-transaction basis by Investors, by an independent third party or as otherwise may be consistent with the Advisers Act. Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may

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Access persons may invest in companies engaged in managing and/or providing investment advice to Corbin Funds or one or more Portfolio Funds or in issuers owned by Corbin Funds or such Portfolio Funds. Such investments may create an incentive for such access persons to maintain and/or increase Clients’ investments in such Portfolio Funds or issuers, or to cause Corbin Funds to continue such engagements.

All limited offerings/private placements to be purchased or sold by access persons must be precleared with the Compliance Officer and reported annually thereafter. All other securities (subject to a few statutory exceptions) must be reported to the Compliance Officer through a secure electronic feed or by having brokerage statements provided to Corbin. Without the express prior written approval of the Compliance Officer, an access person may not in the aggregate for personal accounts acquire or dispose of 1% or more beneficial ownership in any security of a publicly traded company that is, or that has an affiliate that is, an investment manager of a Portfolio Fund in any of the Client portfolios. Any access person looking to conduct certain personal transactions in equities or corporate bonds must receive sign-off from Corbin’s chief investment officer or director of research and approval from the Compliance Officer or his designee prior to transacting. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with Corbin’s Allocation Policy and consistent with applicable Constituent Documents. Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Subject to requirements of applicable law, Corbin may from time to time cause a Client to redeem, withdraw or transfer all or part of its investment in a Corbin Fund where a particular Client needs liquidity, where investment objectives differ, to reduce or eliminate transaction costs or market impact, in order to combine accounts or otherwise. Such a redemption, withdrawal or transfer will cause a conflict for Corbin between the interests of the Client and the Corbin Fund as these actions may cause the net asset value of the Client or the net asset value of the Corbin Fund, as the case may be, to decrease or may reduce the Client’s or the Corbin Fund’s

All withdrawals, redemptions, and transfers are conducted in accordance with applicable policies and Constituent Documents. Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over

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liquidity. Corbin may cause a Client to redeem from a Corbin Fund in which other Clients are invested potentially resulting in reduced liquidity for these other Clients. Further, certain characteristics of Corbin Funds in which the Client invests or may invest may limit Corbin’s ability to withdraw the Client’s investments from Corbin Funds. Corbin may have a conflict of interest between its responsibility to act in the best interests of Clients and any benefit, monetary or otherwise, that may result to it or to its affiliates from the operation of the Client. For example, a Client will pay Corbin a management fee which is based on the net assets of the Client. Consequently, Corbin might have an interest in engaging in relatively safe investments in order to receive its management fee. On the other hand, Corbin and/or its affiliates may receive a performance-based fee from the Client. Corbin might have an interest in engaging in riskier investments in order to increase this potential compensation, and Corbin has an interest in timing the realization of certain investments in order to attain the most immediate receipt of this potential compensation and/or to optimize its tax outcomes.

time in accordance with Corbin’s Allocation Policy and consistent with applicable Constituent Documents.

Corbin may have an incentive to allocate Client assets to other Corbin Funds since Corbin or CCPM has a direct or indirect financial interest in the success of such Corbin Funds.

Corbin’s ability to cause Clients to invest in other Corbin Funds is disclosed in Constituent Documents, and such investments are typically disclosed as part of Corbin’s standard reporting package. To avoid fee duplication, Corbin typically waives the advisory fees it would otherwise receive from the Corbin Fund in which such investment was made. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with Corbin’s Allocation Policy and consistent with applicable Constituent Documents. Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with Corbin’s Allocation Policy and consistent with applicable Constituent Documents.

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Three of the directors of the offshore Corbin The directors’ powers are set forth in Corbin Funds’ Funds are unaffiliated with Corbin; however, Constituent Documents, and the board is comprised of two of the directors of the offshore Corbin a majority of unaffiliated directors. Funds are also owners and officers of Corbin. Affiliated directors of Corbin Funds may have a conflict of interest between their responsibility to serve Corbin Funds for the benefit of Corbin Funds’ Investors and their interest in continuing to have Corbin act as the investment manager to Corbin Funds and earn fees for its services. Access persons may trade for their own accounts and may make investments in nonaffiliated companies, including entities engaged in trading and investment activities that may compete with Clients for investment opportunities or companies engaged in providing services to the financial services industry with which Clients may transact business. Access persons may invest in different instruments or classes of securities of issuers in which Corbin Funds are invested.

All limited offerings/private placements to be purchased or sold by access persons must be precleared with the Compliance Officer and reported annually thereafter. Any access person looking to conduct certain personal transactions in equities or corporate bonds must receive sign-off from Corbin’s chief investment officer or director of research and approval from the Compliance Officer or his designee prior to transacting. All access person securities holdings (subject to statutory exceptions) must be reported to the Compliance Officer through a secure electronic feed or by having brokerage statements provided to Corbin. Without the express prior written approval of the Compliance Officer, an access person may not, in the aggregate, for personal accounts acquire or dispose of 1% or more beneficial ownership in any security of a publicly traded company that is, or that has an affiliate that is, an investment manager of a Portfolio Fund in any of the Client portfolios.

There is competition for investment opportunities between, and co-investment by, Clients, access persons and other collective investment vehicles or accounts organized, advised, sub-advised or owned by Affiliated Persons. For example, other investment vehicles and/or accounts managed or owned by Affiliated Persons (including access persons) may invest in the same security or instrument in which one or more Portfolio Funds or Clients may invest. Conversely, Clients and Portfolio Funds may invest in the same securities or instruments in which access persons may invest.

All limited offerings/private placements to be purchased or sold by access persons must be precleared with the Compliance Officer and reported annually thereafter. Any access person looking to conduct certain personal transactions in equities or corporate bonds must receive sign-off from Corbin’s chief investment officer or director of research and approval from the Compliance Officer or his designee prior to transacting. All access person securities holdings (subject to a few limited exceptions) must be reported to the Compliance Officer through a secure electronic feed or by having brokerage statements provided to Corbin. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for

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Financial institutions, executives of public companies and other “value-added investors” may be Investors in Corbin Funds. These persons and their employees are a potential source of information and ideas that could benefit Corbin Funds.

Corbin has detailed policies and procedures relating to information sharing and the use of private information. The compliance team reviews subscription documents and periodically communicates with the investment team in order to identify potential “value-added investors.” The compliance team, in conjunction with its regulatory consultant, conducts focused email searches periodically to monitor for potential inappropriate information sharing.

Subject to applicable law, Corbin is generally responsible for determining the fair value of Client investments. Corbin may be motivated to over-value such investments to increase the fees payable by the Client, to conceal poor performance or to enhance performance. Alternatively, Corbin may be motivated to undervalue such investments in order to reduce the amount of proceeds payable to an investor upon redemption or withdrawal or reduce the percentage of the illiquid assets.

Corbin maintains a detailed valuation policy and has established a valuation committee which has responsibility for establishing and reviewing Corbin’s valuation policies and procedures and providing oversight of the valuation process. Additionally, a third-party administrator or custodian generally performs the calculation of the value of the Client accounts, subject to the supervision, control and discretion of Corbin. Corbin utilizes third-party valuation experts to assist in valuing certain assets. Each Commingled Fund is audited annually. Certain Customized Funds are also audited annually.

Access persons may wish to serve as a director (or similar position) on the board of a company or charitable organization, which board may include other individuals in the financial industry and could lead to an inappropriate sharing of information. Corbin may, from time to time, donate to charitable organizations that are supported by Clients, Investors, prospective investors or unaffiliated consultants. Access persons may give and/or receive gifts and entertainment to and/or from others in the industry and may make political contributions, all of which could be done with the purpose of influencing the award of an advisory contract or the decision to become a Client or an Investor.

Each conflict is addressed in the Code and additional policies are contained in Corbin’s compliance manual. An access person may not serve as a director (or similar position) on the board of any company or charitable organization unless the access person has received approval from the Compliance Officer. The provision or receipt of certain gifts and entertainment as well as all political contributions are required to be pre-cleared with the Compliance Officer. Corbin-level donations are approved by its chief executive officer and/or director of marketing and client relations and are reviewed by the Compliance Officer. Access persons receive compliance training annually that covers conflicts of interest and pre-clearance requirements.

Corbin’s interests may conflict with the interests of a Client when determining how to vote a proxy. Certain Corbin Funds may vote differently than others on proxies for a number

Corbin maintains detailed proxy voting policies and procedures. The Compliance Officer (or his designee) will seek to identify any conflicts that exist between the interests of Corbin and its clients to ensure that

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of reasons, including, but not limited to, differing investment objectives, guidelines, or portfolio constraints. Further, access persons may invest in Corbin Funds, Portfolio Funds or direct equities and may vote their interests differently than the Corbin Fund(s). These opposing votes may materially impact the ability of a Corbin Fund from realizing the proxy result it desires.

proxies are voted in the best interests of Corbin’s clients.

Unethical or illegal conduct by access persons can damage Corbin’s ability to meet its fiduciary duties to Clients.

The provisions of the Code are based upon the following general fiduciary principles: (a) the duty at all times to place the interest of the Clients first; (b) that all personnel of Corbin shall become aware and maintain knowledge of and shall comply strictly with all applicable federal and state laws and regulations of any governmental agency or self-regulatory organization governing his or her activities; (c) that all personal securities transactions of Corbin’s personnel be conducted consistent with Corbin’s policies and in such a manner as to avoid any actual, potential, or perceived conflict of interest or any abuse of an individual’s position of trust and responsibility; and (d) that Corbin’s personnel should not take inappropriate advantage of their positions. Access persons are required to report to management any actual or suspected illegal or unethical conduct of other access persons of which they become aware or any situations in which they are concerned about the “appropriate course of action” and are protected under Corbin’s Whistleblower Policy. If management is suspected of illegal or unethical conduct, access persons are required to report to the Compliance Officer or his designee. In addition, access persons are required to certify annually that they are in compliance with the Code. A violation of the Code may be cause for immediate dismissal.

Corbin, CCPM and certain Corbin Funds have entered into and may enter into agreements with certain Investors whereby such Investors may be subject to terms and conditions that differ from those set forth in the applicable Constituent Documents. Certain of these agreements contain a so-called “most favored nation” provision. Legal, regulatory or other characteristics or circumstances relating to Investors may result in the modification of such Investors’ rights and obligations with respect to their investments in Corbin Funds.

Prior to execution, all agreements are negotiated by Corbin’s legal group, other applicable Corbin teams and, when necessary, outside counsel. Certain terms of such agreements are monitored and reviewed by the risk, legal and compliance, client services and operations teams to ensure adherence. Corbin’s agreement to provide certain Investors with certain detailed information with respect to Corbin Funds or Corbin that is not ordinarily provided to all Investors is disclosed in applicable Constituent Documents and other formats as required. Corbin will not provide information that could have a material negative impact

Corbin has entered into an agreement with Institutional Shareholder Services Inc. to assist with the monitoring and voting of proxies.

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In connection with investment in Corbin Funds, certain Investors have requested, and Corbin, CCPM and Corbin Funds have agreed to provide such Investors with, certain detailed information with respect to Corbin Funds or Corbin that is not ordinarily provided to all Investors. Such information may include, but not be limited to, capital activity, enhanced portfolio analysis, strategy, geographic and other exposure, detailed characteristics with respect to Portfolio Funds, holdings, and notification of certain events regarding a Corbin Fund, Corbin, CCPM or Affiliated Persons.

on other Investors. Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client.

Corbin Funds, Portfolio Funds and/or Investment Managers may be represented on the boards of directors of certain of the issuers of their investments or may have their representatives serve as observers to such boards of directors. Although such positions in certain circumstances may be important to the investment strategy of certain Corbin Funds, Portfolio Funds, and/or Investment Managers and may enhance Corbin’s and/or the Investment Manager’s ability to manage their investments, they may also have the effect of impairing (as a result of securities laws, contractual terms or other reasons) Corbin’s and/or the Investment Manager’s ability to transact in the related securities when, and upon the terms, they may otherwise desire and may subject Corbin, Corbin Funds, Portfolio Funds and/or Investment Managers to claims they would not otherwise be subject to as an investor, including claims of breach of duty of loyalty, securities claims and other directorrelated claims. In general, Corbin Funds will indemnify Corbin from such claims.

An access person may not serve as a director (or similar position) on the board of any company or charitable organization unless the access person has received approval from the Compliance Officer. Access persons will not be permitted to accept compensation for approved board roles in connection with investments made by Corbin Funds. Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Corbin or CCPM may, in its sole discretion, offer one or more Investors and/or other thirdparty investors (including affiliates of Corbin) opportunities to invest with Corbin Funds in certain Corbin Funds’ investments. Corbin is generally under no obligation to arrange such co-investment opportunities, and no Investor will be obligated to participate in such opportunities. Corbin has sole discretion as to the amount (if any) of a co-investment

Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with Corbin’s Allocation Policy and consistent with applicable Constituent Documents. In accordance with Corbin’s expense allocation policy, the co-investor

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opportunity that will be offered to a particular may or may not bear its proportionate share of Investor and may offer co-investment expenses associated with the co-investment. opportunities instead to other Investors, including Investors in other Corbin Funds or to other third parties. When a trade error is made on behalf of a Corbin Fund, Corbin will use its best efforts to terminate the trade or otherwise correct the error. Any trading losses, liabilities, damages, expenses or costs resulting from trade errors are generally borne by the Corbin Fund unless an error is the result of Corbin’s gross negligence or intentional misconduct, or, if applicable, the result of conduct by Corbin that is inconsistent with a different standard of care. Corbin has a conflict of interest in determining whether the error resulted from its violation of the applicable standard of care.

Corbin maintains detailed trade error policies and procedures. All trade errors are reviewed by the CRAC to ensure that determinations are fair, equitable and consistent with Corbin’s policy. When necessary, Corbin may seek advice from outside counsel. Determinations are documented by the Compliance Officer.

After a Corbin Fund invests in a Portfolio Fund, another Corbin Fund may subsequently invest in the same Portfolio Fund or engage in co-investments with the same Investment Manager/Portfolio Fund. Since expense determinations and allocations will be made taking into account facts, circumstances and judgments prevailing at the time the relevant expense is incurred, the initial investing Corbin Fund may pay all or the majority of the due diligence and research expenses which other Corbin Funds will benefit from.

Corbin has designed policies and procedures to ensure that expenses are allocated in accordance with the expense allocation policy. Corbin allocates expenses on a basis that it considers fair and equitable and in accordance with Constituent Documents and Corbin’s expense allocation policy. (See Item 5 - Fees and Expenses for a more detailed discussion of brokerage and transaction costs.)

Certain Corbin Funds and Portfolio Funds may not be able to establish accounts with, or otherwise engage, certain brokers, dealers and other counterparties identified by Corbin and/or Investment Managers to effect the Corbin Fund’s and/or the Portfolio Fund’s investments. One or more affiliated Corbin Funds, however, may establish accounts with, or otherwise engage, such brokers, dealers or other counterparties. Further, the terms of the agreements entered into with brokers, dealers and other counterparties may vary across Corbin Funds.

Before Corbin may enter into a new brokerage, custodial or credit/financing relationship with a counterparty that will maintain custody of Client assets or require the posting of collateral or margin, such potential relationship must first be presented to, and reviewed and ultimately approved by, the Brokerage and Counterparty Risk Committee (the “BCRC”). The BCRC, which consists of Corbin’s chief financial officer, general counsel, Compliance Officer and director of operational due diligence, conducts periodic monitoring of the performance and creditworthiness of certain trading counterparties. The BCRC is also responsible for a periodic review of trading activity and the commissions paid to counterparties as well as for ensuring that no services or information that could be perceived as soft dollars are received from counterparties.

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Access persons may have a family member who (i) is employed by or has an ownership interest in any company with which Corbin or a Corbin Fund may or does transact business and (ii) would be in a position to benefit directly or indirectly from such business arrangement.

Disclosure of certain familial financial industry relationships must be made upon commencement of employment and quarterly thereafter. The Compliance Officer reviews these disclosures. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Principals of Investment Managers with whom Corbin invests Client capital may invest in Corbin Funds or co-invest alongside Corbin Funds. Corbin could be inclined or incentivized to invest Client capital or maintain investments with those Investment Managers whose principals invest in Corbin Funds.

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with Corbin’s Allocation Policy and consistent with applicable Constituent Documents.

From time to time, Corbin personnel speak at conferences and programs for potential hedge fund investors which may be sponsored by third-party service providers with whom Corbin and/or Clients may do business. Through these and other events, prospective hedge fund investors or their representatives have the opportunity to meet with Corbin. Such events and other services (including, without limitation, capital introduction services) provided by service providers, including prime brokers, custodians and administrators, may influence Corbin. Corbin has placement agreements/relationships with broker-dealers and/or their affiliates (i) that sponsor hedge fund conferences or similar events, (ii) that act as a broker, dealer, or other counterparty with respect to transactions entered into by Clients, and (iii) that are engaged to provide services to Clients. Although Corbin selects counterparties and service providers it believes are most appropriate in the circumstances, the relationship of certain service providers to Corbin may influence Corbin in deciding whether to select or recommend a service

Neither Corbin nor Clients compensate these service providers for sponsoring and arranging these events or allocate brokerage business with the goal of securing invitations to such conferences or programs. Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client, including in Corbin’s selection of service providers and counterparties.

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provider or counterparty, the cost of which may be borne directly or indirectly by Clients. Certain Corbin personnel invest in Corbin Funds. Typically, no advisory fees are charged to such investors. Corbin personnel invested in Corbin Funds may be individuals responsible for allocating investment opportunities among Corbin Funds and may have an interest in such allocations.

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Corbin maintains a detailed Allocation Policy. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with the Allocation Policy and consistent with applicable Constituent Documents.

Corbin provides investment advice to Clients that have similar, overlapping or identical investment objectives and strategies and that, therefore, can have similar, identical or overlapping portfolio holdings. The liquidation of certain Clients may be permitted on terms that are preferential to the terms under which other Clients are permitted to withdraw or redeem from, or otherwise liquidate, certain holdings. Clients may liquidate at a time when such investment actions may or could reasonably be expected to be adverse to other Clients.

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Corbin maintains a detailed Allocation Policy. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with the Allocation Policy and consistent with applicable Constituent Documents.

Some Clients have access to a credit facility or other financing arrangement which facilitates bridge financing for short-term and other cash needs. The lack of a credit facility or other financing arrangement may prevent other Clients from participating in certain investment opportunities.

Cash availability is a critical input in the allocation process and Clients understand the possibility of missing certain investment opportunities on account of cash constraints. The establishment of a credit facility or other financing arrangement is considered for each Client in light of multiple criteria deemed relevant by Corbin, and in the case of a Customized Fund, by the applicable Investor as well.

Corbin may have a conflict of interest in determining whether to disclose certain information not otherwise required to be disclosed by the relevant Constituent Documents, applicable laws, or regulations

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties,

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concerning Corbin to existing or prospective Investors. In certain cases, Corbin may conclude that such disclosure could negatively impact its business, which would give Corbin an incentive to determine that such information is not material and need not be disclosed to Investors or prospective investors even though it might be of interest to them. Corbin may have a conflict of interest between acting in what might be the best interest for Clients and ensuring that Corbin avoids negative publicity or any reputational harm.

Corbin carefully considers the interests of each Client. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Corbin and its personnel can be expected to receive certain intangible and/or other benefits and/or perquisites arising or resulting from their activities on behalf of Corbin Funds that will neither be subject to an offset against any advisory fees that are payable by Corbin Funds to Corbin or its affiliates nor will otherwise be shared with Corbin Funds. For example, airline travel or hotel stays incurred as Corbin Fund expenses typically result in cash rebates, “miles,” credit card “points” or credit in loyalty/status programs, and such benefits and/or amounts will, whether or not de minimis or difficult to value, inure exclusively to Corbin and/or such personnel (and not Corbin Funds) even though the cost of the underlying service is borne by Corbin Funds.

Corbin maintains a travel and entertainment policy which establishes applicable guidelines. Expenses that are incurred are monitored for reasonableness and compliance with the guidelines. Corbin has policies and procedures reasonably designed to ensure that expenses are allocated in accordance with the expense allocation policy. Corbin allocates expenses on a basis that it considers fair and equitable and in accordance with Constituent Documents and Corbin’s expense allocation policy.

In the course of its business, Corbin will be required to interpret the terms of applicable legal documentation, including but not limited to Constituent Documents of Clients. Corbin has an incentive to favor certain interpretations over others if one interpretation is more favorable for Corbin or certain Clients. There will be times when Corbin interprets legal and regulatory restrictions in a way that may be more favorable to Corbin than to the Clients or their Investors.

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Corbin may take an investment position or action for one or more Clients earlier in a Portfolio Fund’s or investment’s life cycle that is different from, grants rights and economics preferential to, or is generally more protected than, an action or position taken for one or

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client.

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more Client(s) later in such life cycle. For example, certain Clients may make earlystage investments with preferential terms, rights, and/or benefits. Other Clients may invest later with less favorable terms, protections and/or rights. Later-stage investments made by certain Clients may benefit earlier-stage investments made by other Clients. In some cases, later-stage investments made by certain Clients could provide those Clients with certain rights that are senior to those of earlier-stage investors. Clients may invest in different instruments or classes of securities of the same issuer. One or more Clients may have different investment objectives, risk appetites, liquidity profiles or investment time horizons than other Clients, and the actions of one Client may be inconsistent with the investment objectives of, or have an adverse effect on, other Clients. For example, certain Clients may pursue or enforce rights with respect to a particular issuer that could negatively impact other Clients In addition, the interests of certain Clients with respect to the management, investment decisions or operations of an issuer may at times be in direct conflict with those of other Clients, which may not have the same level of control over the issuer. For example, the interests of senior secured debt holders of an issuer may be adverse to those junior debt and equity holders of such issuer. As a result, Corbin may face actual or apparent conflicts of interest, in particular in exercising powers of control over such issuers.

A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with the Allocation Policy and consistent with applicable Constituent Documents. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Certain Clients may make seed investments in Portfolio Funds and may enter into revenue sharing agreements with Investment Managers. Revenues generated from such arrangements accrue only to such Corbin Clients. Clients providing seed capital to, making an anchor investment in or otherwise acquiring an ownership interest or revenue share in, and/or having other economic arrangements with respect to, an Investment Manager and associated investment funds (collectively, an “economic interest”) creates the potential for certain conflicts of interest.

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Corbin maintains a detailed Allocation Policy. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are

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For example, if a Client has an economic interest in an Investment Manager, such Client would have a financial interest in hiring such Investment Manager. Moreover, if multiple Clients have provided seed capital to a Portfolio Fund, such Clients will benefit from another Client making or maintaining an investment in such seeded Portfolio Fund (or other funds covered by the particular seeding arrangement). Relatedly, if a Client has provided seed capital to a Portfolio Fund, benefits (such as lower fees) may accrue to other Clients investing in such Portfolio Fund (or other funds covered by the particular seeding arrangement). In addition, Corbin would have an incentive to favor the engagement of an Investment Manager in which one or more Clients has an economic interest (thereby generating fees and/or revenue shares for such Clients), including to manage assets on behalf of a different Client even if that Client does not have an economic interest in such Investment Manager. Further conflicts could arise if an Investment Manager engaged by one or more Clients breaches its servicing agreement, or otherwise fails to perform its responsibilities adequately, resulting in harm or damages to such Clients. In such circumstances with third-party Investment Managers, such Clients are free to seek such recourses as are appropriate, up to and including litigation. Where one or more Clients has an economic interest in such Investment Manager, Corbin has a potential conflict in determining what action to take against the Investment Manager.

fair and equitable over time in accordance with the Allocation Policy and consistent with applicable Constituent Documents. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Clients may pay different fees to Investment Managers for the same or similar services. Investment Managers have an incentive to favor Clients paying the potentially higher fees (e.g., in allocating investment opportunities).

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Corbin maintains a detailed Allocation Policy. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s

Potential Conflict

Mitigating Policy Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with the Allocation Policy and consistent with applicable Constituent Documents. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Certain Clients may make loans to Portfolio Funds, Investment Managers and/or their principals. In order to maximize the return on such loans, Clients making the loan may be incentivized to invest a greater amount of assets in such Portfolio Funds or with such Investment Managers than it otherwise would have. In addition, these loans may create favorable relationships with such Investment Managers, the benefits of which (e.g., capacity and co-investment opportunities) may inure to other Clients, rather than Clients that made the loan. Corbin therefore has a conflict between the interests of Clients to which the benefits of the loan accrue and the interests of Clients to which the benefits of the loan do not accrue when making investment decisions related to such loans and the related Portfolio Funds. In addition, from time-to-time Clients directly or indirectly (through derivatives or otherwise) purchase investments from or sell investments to Portfolio Funds in which Clients invest, or to Investment Managers or the principals of such Investment Managers. Corbin may have a conflict between obtaining the best price and terms for the Clients engaged in such transaction and/or acting in the best interest of the Portfolio Fund in which other Clients are invested. Certain benefits may also accrue to other Clients or Corbin as a result of these transactions. Subject to requirements of applicable law, Corbin may from time to time cause a Corbin Fund to transfer all or part of its capital commitment to a Portfolio Fund or other investment to another Corbin Fund where a particular Client seeks liquidity or determines that the investment amount initially committed to is no longer in the best interest of the Corbin Fund that made the commitment. Such

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with the Allocation Policy and consistent with applicable Constituent Documents. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of

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a transfer will cause a conflict for Corbin between the interests of the Corbin Fund that made the commitment and the Corbin Fund that will assume the commitment.

investment opportunities in accordance with Corbin’s Allocation Policy. A subset of the CRAC reviews all allocation decisions to ensure that such allocations are fair and equitable over time in accordance with the Allocation Policy and consistent with applicable Constituent Documents. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Investment Managers with which Clients have a business relationship (including by virtue of their having made an investment in Portfolio Funds sponsored or managed by such Investment Managers or their affiliates, or otherwise having its or their capital managed by Investment Managers or their affiliates), the principals of such Investment Managers, and/or Portfolio Funds sponsored or managed by such Investment Managers may from time to time provide equity and/or debt capital to Corbin and/or its affiliates. Any such provision of capital could create a conflict of interest between Corbin’s responsibility to act in the best interests of Clients, and the benefits, monetary or otherwise, that may result to Corbin or to its affiliates from such provision of capital. A Portfolio Fund in which a Corbin Fund invests may enter into arrangements with such Corbin Fund or other Corbin Funds that could provide a financial benefit to Corbin. Any such arrangement could create a conflict of interest between Corbin’s responsibility to act in the best interests of Clients, and the benefits, monetary or otherwise, that may result to Corbin or to its affiliates from such arrangement.

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Corbin may benefit from investments that a Corbin Fund makes. For example, the Investment Manager of a Portfolio Fund in which a Corbin Fund invests may offer Corbin the opportunity to sub-advise a portion of such Portfolio Fund’s assets. Such an arrangement will cause a conflict for Corbin between the

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Portfolio managers, in consultation with Corbin

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

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interests of the Corbin Fund that made the investment committees and investment team members, investment and Corbin’s economic interests. are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

In order to consummate a transaction, ensure that a Corbin Fund is afforded an investment opportunity or otherwise, certain Corbin Funds may fund, or commit to fund, an investment, or portion of an investment, on behalf of an Investment Manager with the expectation of selling a portion of such investment to an investment vehicle managed by such Investment Manager on a future date. In the event the Investment Manager does not procure sufficient liquidity required to purchase the agreed upon portion of the investment from the Corbin Fund, the Corbin Fund may have an allocation to an investment that is larger than originally anticipated.

Subject to limited exceptions, Corbin is typically granted full discretionary authority to manage the investment programs of its Clients in accordance with applicable Constituent Documents. In exercising such discretion, and in discharging its fiduciary duties, Corbin carefully considers the interests of each Client. Portfolio managers, in consultation with Corbin investment committees and investment team members, are responsible for determining the allocation of investment opportunities in accordance with Corbin’s Allocation Policy. The CRAC or a subset of the CRAC meets as frequently as required to address conflicts in real time and when necessary, may seek advice from outside counsel.

Item 12. Brokerage practices

To the extent that Corbin makes direct investments on behalf of a Client or a Client otherwise directly engages in transactions, Corbin generally shall have full power and authority, which is delegated in certain circumstances to Investment Managers, to establish and maintain accounts on behalf of the Clients with, and issue orders for the purchase or sale of securities for the Clients directly to, a broker, dealer or other person, as well as to exercise or abstain from exercising any option, privilege or right held by the Client.

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Corbin will seek to allocate portfolio transactions for Clients to brokers and dealers on the basis of best execution and in consideration of a broker’s or dealer’s ability to effect such transactions, its facilities, reliability and financial responsibility, custodial arrangements, the scope and quality of research services, execution capability and other factors considered relevant by Corbin. Accordingly, the commissions and other transaction costs (which may include dealer markups or markdowns) charged to the Clients by brokers or dealers in the foregoing circumstances may be higher than those charged by other brokers or dealers that may not offer such products or services, so long as, in the good faith judgment of Corbin, the amount of the commission is reasonable in relation to the value of the brokerage and research services provided by such broker, viewed in terms of that particular transaction or Corbin’s overall investment management business. To the extent that Corbin enters into soft dollar arrangements in the future, Corbin intends to stay within Section 28(e) of the Securities Exchange Act of 1934, as amended (“Exchange Act”). Portfolio Funds may use soft dollars both within and outside of the safe harbor of Section 28(e) of the Exchange Act to obtain both research and non-research products and services. Aggregation of Portfolio Fund Investments. As purchase and sale orders of Portfolio Funds are generally effected directly with the Portfolio Fund issuer, orders are not generally aggregated but are negotiated and effected independently. However, when more than one Client is investing in the same Portfolio Fund (whether participating at the same or a later time), Corbin will attempt to ensure that the investments are entered into on the same terms, if possible and if desirable. A number of factors will affect Corbin’s ability to obtain the same terms for all Clients, including, without limitation, (i) the willingness of a Portfolio Fund to provide, or continue to provide, favorable terms to all or any of the Clients (e.g., favorable liquidity terms); (ii) prospective changes to the terms of an investment in a Portfolio Fund that do not affect existing Investors (e.g., management fee increase, change in liquidity); and (iii) the needs of the Client (e.g., greater liquidity to meet that Client’s redemption terms or contractual obligations, such as the terms of a credit facility). Aggregation of Other Investments. Purchase and sale orders of other investments generally will be aggregated. Corbin will generally follow the guidelines set forth below in aggregating orders for other investments:

Corbin will not aggregate transactions unless it believes such aggregation is consistent with its duty to seek best execution for Clients and the terms of the investment advisory agreement in effect with each Client;

Corbin will document the proposed allocation of the aggregated order prior to execution;

if the aggregated order is partially filled or filled in its entirety, it will be allocated among Clients pro rata based on each Client’s desired participation, determined by evaluation of the factors set forth in the Allocation Policy;

Corbin will deviate from the proposed allocation of the aggregated order only if it determines that all Clients will be treated in a fair and equitable manner; and

each Client that participates in an aggregated order will participate at the average share price for all of Corbin’s transactions in that investment on a given business day, and transaction costs will be shared pro rata based on each Client’s participation in the transaction.

Item 13. Review of accounts

On an ongoing basis, Corbin’s chief investment officer and director of portfolio solutions and risk management work with the other members of the investment and risk teams, through formal committee structures and otherwise, to monitor and review the portfolios of Clients. They use the information provided by Investment Managers, public filings made by Investment Managers, information developed by Corbin and other information to monitor individual Client’s and Portfolio Fund risks. A subset of the CRAC reviews all allocations executed by Corbin across all Clients.

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These reviews are conducted in several ways, including but not limited to, daily monitoring of the trade blotter, review of trade allocation instructions, and through involvement by CRAC members in the structuring, implementation and review of certain investments throughout the month. Investors in Corbin Funds will generally receive (or have access through a secure FTP network to) written unaudited monthly and/or quarterly reports describing the performance of such Corbin Fund(s) and written annual reports containing audited financial statements and other indicia of performance. Investors may also receive tax reporting information.

Item 14. Client referrals and other compensation

Corbin pays a portion of its management fee, and Corbin and CCPM each pays a portion of its performancebased compensation, to individuals or entities that refer Investors to Corbin Funds (“Solicitors”). Where applicable, each such Solicitor has entered into a written agreement with Corbin pursuant to which each prospective Investor is to be provided with a disclosure document setting forth the terms of the solicitation arrangement, including the nature of the relationship between the Solicitor and Corbin and any fees to be paid to the Solicitor. Corbin may also pay Solicitors a fixed fee in connection with their efforts to refer Investors to Corbin or certain Corbin Funds.

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Where applicable, cash payments for Investor solicitations will be structured to comply fully with the Advisers Act and related SEC staff interpretations. In certain circumstances, Solicitors may also have an agreement with an Investor whereby the Solicitor receives an upfront selling commission or fee based on the Investor’s subscription amount. The fact that a Solicitor will be entitled to receive certain compensation for solicitation activities may cause a Solicitor to recommend Corbin Funds instead of investment funds managed by another adviser that does not pay solicitation compensation. Corbin maintains written policies and procedures with respect to the giving and receipt of gifts and entertainment which are reasonably designed to prohibit giving or receiving gifts or entertainment that Corbin determines are lavish or excessive under the circumstances or may violate statutory limitations. Corbin receives referrals of prospective investors from unaffiliated consultants that are retained by such prospective investors. Corbin may make cash payments to these consultants to participate in conferences sponsored by these consultants, in order to, among other things, obtain information about industry trends and prospective investor/Investor investment needs. In addition, Corbin may purchase products or services

from these consultants or their affiliates. No cash payments for conferences, products, or services are made in connection with any prospective investor that consultants refer.

Item 15. Custody

Under the Advisers Act, Corbin or its affiliates may be deemed to have custody of the securities and other assets of certain Commingled Funds even though neither Corbin nor its affiliates physically hold such securities and other assets, and such securities and assets are not held or registered in Corbin’s or its affiliates’ name. For example, CCPM is deemed to have custody of the securities and assets of Commingled Funds for which it serves as general partner. In these circumstances, Corbin and its affiliates are exempt from certain Advisers Act custody requirements because the financial statements of the Commingled Funds are audited in accordance with U.S.

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generally accepted accounting principles on an annual basis by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. Audited financial statements are distributed to each Investor in the Commingled Funds in accordance with the requirements of the Advisers Act. Under certain circumstances, Corbin or its affiliated servicing entity may be deemed to have custody of assets held by such servicing entity in connection with its service of co-investments, which servicing entity may comingle advisory client assets with those of non-clients. In these circumstances, Corbin or its affiliated servicing entity will adhere to the relevant conditions required to obtain relief from certain requirements of the Custody Rule. Corbin and its affiliates will consider the terms of Customized Funds to determine whether Corbin and/or its affiliates have custody of each Customized Fund’s funds or securities and whether Corbin and/or its affiliates will be subject to the surprise examination requirement under the custody rule. For example, if a Customized Fund is established in an Investor’s name at a custodian and neither Corbin, its affiliates nor any related person, has possession of, or the ability to access or withdraw, client funds or securities outside its normal trading authority, then neither Corbin nor its affiliates would be deemed to have custody.

Item 16. Investment discretion

Corbin, in its capacity as investment manager, generally provides discretionary investment advisory services to Corbin Funds. Corbin generally enters into investment management agreements that, among other things, grant Corbin the authority to manage Clients’ assets on a discretionary basis and generally grant Corbin unlimited discretionary trading authorization. Currently, Corbin is a party to one investment management agreement under which Corbin is granted discretionary management authority only after the underlying Investor determines to proceed with a presented investment opportunity.

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As a general matter, other than through Customized Funds, the objectives and guidelines of which would be set forth in the relevant Customized Funds’ Constituent Documents, Corbin does not permit Clients to impose restrictions on investing in certain securities or types of securities. Side Arrangements. Corbin, CCPM and certain Corbin Funds have entered into and may enter into agreements with certain Investors whereby such Investors may be subject to terms and conditions that are different than those set forth in the applicable Constituent Documents. Certain of these agreements contain a so-called “most favored nation” provision. The terms of such agreements are at the discretion of Corbin, CCPM and Corbin Funds, as applicable.

In connection with investment in Corbin Funds, certain Investors have requested, and Corbin, CCPM and Corbin Funds have agreed to provide such Investors with certain detailed information with respect to Corbin Funds or Corbin that is not ordinarily provided to or proactively offered to all Investors, or that is offered in a different format. Corbin has not, and will not, enter into such an arrangement if it determines that the arrangement would have a material adverse effect on the other Investors in Corbin Funds. Such information may include, but may not be limited to, capital activity, enhanced portfolio analysis and disclosure, strategy, geographic and other exposure, detailed characteristics with respect to Portfolio Funds, holdings, and notification of certain events regarding a Corbin Fund or Corbin or its affiliates. Corbin often provides tailored reports to Investors in Customized Funds. Investors that are principals or employees of Corbin or its related persons are generally not charged management or performance fees. In certain circumstances management and/or performance fees charged by Corbin Funds are waived, modified, reduced or rebated. Factors considered in rebating, modifying, reducing or waiving such management and/or performance fees include, but are not limited to, the size of an investment, the stage of an investment (e.g., seed investor), the strategic nature of the investment, investor characteristics, distribution arrangements or structured products relating to the investment, and relationships with financial and/or investment advisers or intermediaries. Legal, regulatory or other characteristics or circumstances relating to Investors may result in the modification of such Investors’ rights and/or obligations with respect to their investments in Corbin Funds.

Item 17. Voting client securities

Corbin generally has the authority to vote the securities held by Clients. In accordance with the Advisers Act, Corbin has adopted Proxy Voting Policies and Procedures (the “Procedures”) reasonably designed to ensure that Corbin votes proxies in the best interest of Clients. The Procedures also require that Corbin identify and address conflicts of interest between Corbin and its Clients, as well as conflicts of interest among Clients. If a material conflict of interest exists, Corbin will determine whether voting in accordance with the guidelines set forth in the Procedures is in the best interests of the Client or take other appropriate action. Portfolio Funds – typically involves votes with respect to terms and structure changes. 1.

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Corbin generally votes in favor of routine corporate housekeeping proposals. 2. For all other proposals, particularly those affecting the investment terms and/or structure associated with Corbin Funds’ investments in Portfolio Funds, Corbin considers the best interests of each affected Corbin Fund when voting on proposed changes. When such vote would serve to increase fees or decrease liquidity to the Corbin Fund or otherwise have an adverse effect on the Corbin Fund, Corbin would vote for such terms only if it were in the best interests of the Corbin Fund. Direct Equities Voted by Corbin 1. Corbin generally votes in favor of routine corporate housekeeping proposals. 2. For all other proposals timely communicated to Corbin’s third-party proxy voting service, Corbin will generally vote in accordance with the recommendation of management unless such vote would have an adverse effect on a Corbin Fund, taking into account the following factors and any others deemed relevant by Corbin:

Whether the proposal was recommended by management and Corbin’s opinion of management;

Whether the proposal acts to entrench existing management; and

Whether the proposal fairly compensates management for past and future performance.

Managed Accounts Managed accounts established by Corbin Funds may engage in direct trading in equities. In cases where the Investment Manager of such an account is granted discretionary trading authority, Corbin typically delegates to the Investment Manager the authority and responsibility to exercise proxy voting rights related to such account in accordance with such Investment Manager’s proxy voting policies. It is possible that more than one Investment Manager managing managed accounts for the same Corbin Fund may have positions in the same security that is subject to a proxy solicitation. In such circumstances, Investment Managers may vote such proxy in a conflicting manner provided that each Investment Manager has determined that its particular vote is consistent with its proxy voting policies. It is also possible that the same security may be owned directly by a Corbin Fund and by an Investment Manager managing a managed account for the same Corbin Fund or a different Corbin Fund and Corbin and the Investment Manager may vote such proxy in a conflicting manner. Voting in General As a general matter, Corbin does not permit Clients to direct votes in a particular solicitation. Certain Corbin Funds may vote differently on proxies for a number of reasons, including, but not limited to, differing investment objectives, guidelines, or portfolio constraints. Further, access persons may invest in Portfolio Funds or direct equities and may vote their interests differently than the Corbin Fund(s). These opposing votes may materially impact the ability of a Corbin Fund to realize the proxy result it desires. Subject to applicable law, Corbin may abstain from voting when it determines an abstention to be in the best interests of the applicable Corbin Fund. Clients or Investors may obtain a copy of Corbin’s Procedures and information about how Corbin voted a Client’s proxies by contacting Corbin via email at clientservices@corbincapital.com or by telephone at (212) 634-7373.

Item 18. Financial information

Corbin does not charge or solicit prepayment of $1,200 in fees per client six or more months in advance. Corbin is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to its Clients.

Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.