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Parallax Volatility Advisers, L.P.: investment adviser

Parallax Volatility Advisers, L.P. is an investment adviser registered with the SEC (file 801-73683, CRD 158143). 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
$6.0B
Discretionary
100%
Accounts
3
Employees
51
In advisory roles
19
Disclosures
1

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 vehicles3$6.0B100.0%

How it is paid

  • A percentage of assets under your management
  • Other: Performance-based allocations

Services

  • Portfolio management for pooled investment vehicles (other than investment companies)

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
Stephen Daniel HutchisonPersonPrincipal portfolio manager, limited partner partnerC 25% to 50%Aug 2003Yes
Jill Caroline GP LLC ArmstrongPersonChief financial officer, chief compliance officer, chief operating officer, limited partnerB 10% to 25%Sep 2000Yes

Indirect owners (Schedule B)

OwnerOwns a stake inTypeStakeControlPublic company
Jill Caroline ArmstrongParallaxPersonF General partner, trustee or managing memberYes
William Frederick BartlettParallaxPersonC 25% to 50%Yes
Stephen Daniel HutchisonParallaxPersonC 25% to 50%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

What the firm disclosed under Item 11 of Form ADV. A disclosure is the firm's own report: pending matters are allegations, not findings, and many settlements are made without admitting or denying them. Text is quoted from the filing, set in sentence case.

Item 11 questions answered Yes

These questions cover the firm and its advisory affiliates.

  • Has any self-regulatory organization or commodities exchange ever: found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)?

Actions about affiliates (1)

  1. Jun 7, 2022
    Regulatory Action: Chicago Board Options Exchange FinalAbout an affiliate: Egan, Justin, AdamSanctions: Censure; None · Begun Jun 7, 2022 · Resolved Jun 7, 2022 · Consent

    The CBOE alleged that MR. Egan engaged in anticipatory hedging on behalf of his then current employer, RBC capital markets LLC, on September 17, 2019, in violation of CBOE rules 8.1 and 5.86 (which were rules 4.1 and 6.9 respectively in 2019).

    Not applicable

    The CBOE initiated an investigation that MR. Egan violated certain CBOE rules as described in item 7 above. MR. Egan accepted a letter of consent that was effective on June 7, 2022, agreeing to a censure to resolve the allegations, without admitting or denying the allegations. No other sanctions were ordered in the letter of consent. No information Filed

Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.

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.

Form ADV, Part 2A, filed Mar 19, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

PVA is a California limited partnership that has been in business since 1996. Its managing principals and principal owners consist of S. Daniel Hutchison, William Bartlett and Jill Armstrong. Mr. Hutchison, as the principal portfolio manager, and Mr. Bartlett, as Chief Executive Officer, are primarily responsible for day-to-day trading activities, and Ms. Armstrong, as Chief Operating Officer, Chief Financial Officer and Chief Compliance Officer, is primarily responsible for business operations and compliance. PVA’s general partner is Parallax Volatility Advisers GP, LLC, and the managing members and owners of that general partner are Mr. Hutchison, Mr. Bartlett, and Ms. Armstrong.

Read the rest of Item 4 (353 more words)

As of December 31, 2025, PVA had total net discretionary assets under management of approximately $1,407,279,000 and regulatory assets under management of approximately $5,979,806,000. PVA only manages assets on a discretionary basis. PVA currently manages a single fund family as described below, but it may launch additional investment funds and may manage additional client accounts or funds in the future. PVA may not update this brochure to reflect additional clients if such change is immaterial. Parallax Core: Parallax Master Fund, L.P., Parallax Fund, L.P., and Parallax Offshore Investors Fund Ltd. are the “Parallax Core” funds. Parallax Core is a master-feeder structure with a Cayman Islands exempted limited partnership master fund (the “Master Fund”), a Cayman Islands corporation offshore feeder and a US limited partnership onshore feeder. In the master-feeder arrangement, the two feeder funds invest substantially all of their assets in the Master Fund. PVA’s affiliate, Parallax Partners, LLC, a California limited liability company (“Parallax Partners”), is the general partner to the limited partnerships in this structure (i.e., the Master Fund and the onshore feeder fund). The Master Fund and each feeder fund is individually referred to as a “Fund,” and they are referred to together as the “Funds.” Parallax Fund, L.P. launched in 1996, and the other Parallax Core Funds launched in 2007. The Master Fund employs an equity volatility relative value strategy that targets the most attractive risk adjusted portfolio of volatility exposures through US and non-US options contracts (including covered and uncovered puts and calls) and other securities instruments. The Master Fund invests in various types of instruments, markets and trading strategies. Additional information about the Master Fund’s investment strategy is in Item 8 of this brochure. PVA is authorized to enter into any type of investment transaction that it deems appropriate under the terms of the Master Fund’s Investment Adviser Agreement. Fund investors have no opportunity to select or evaluate any investments or strategies. PVA selects all Master Fund investments and strategies. PVA does not tailor its advisory services to the individual needs of particular Fund investors and manages the Master Fund only in accordance with its stated strategy.

Item 5. Fees and compensation

Management Fees. Fund investors pay PVA a management fee. The management fee for Parallax Core is equal to 1.65% per year and it is paid monthly. This management fee is allocated to the respective investors of each feeder fund (other than investors for whom PVA has waived the management fee) proportionately based on their respective investment. The management fee is paid to PVA on the first day of each calendar month, based on the net market values of Fund investors’ capital accounts on that date. Performance Allocation. Additionally, Fund investors bear a performance allocation. Fund investors have two performance allocation options, a standard option and a hurdle option.

Read the rest of Item 5 (864 more words)

The performance allocation options also have different lockups, as described below under “Fees Relating to Terminations, Withdrawals and Redemptions.” Parallax Core standard option allocates to Parallax Partners from each Fund investor a performance allocation equal to 25% of net profits (including both realized and unrealized gains and losses) that the Funds would otherwise allocate to such investor. These performance allocations only apply to the portion of profits that exceed the cumulative losses previously incurred by Fund investors, otherwise known as a high water mark. Parallax Core hurdle option investors bear a performance allocation equal to 35% of net profits (including both realized and unrealized gains and losses) that exceed the hurdle amount. The hurdle amount is the balance of the account at the beginning of the measurement period, multiplied by the average daily hurdle rate over that measurement period. The hurdle rate is the Standard Overnight Financing Rate, administered by the Federal Reserve Bank of New York. This hurdle option does not include the high water mark described in the standard option above. All performance allocations are assessed in arrears on an annual basis, on the last day of each fiscal year (December 31), and also upon a Fund investor’s withdrawal or redemption of capital during the year, with respect to the amount withdrawn or redeemed. PVA complies with Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), to the extent applicable. Performance allocations may create an incentive for PVA to make more risky and speculative investments than it would otherwise make. General. If PVA deems it appropriate for the Master Fund to invest in certain investment companies or funds such as mutual funds, exchange traded funds (ETFs), or money market funds, the investment advisory fees to the managers of those investment companies or funds are borne by the Funds that participate in such investment. PVA believes that its fees and performance allocations are competitive with fees charged by other investment advisers for comparable services. However, comparable services may be available from other sources for lower fees. Fees are generally non-negotiable, but the Funds may waive fees and performance allocations for certain Fund investors such as PVA employees and limited partners, and their family members and friends.

The disclosure in this Item 5, together with the disclosure in Item 12, allow a plan that is subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) and that invests in a Fund to use the “alternative reporting option” to report PVA’s compensation as “eligible indirect compensation” on the Schedule C of the plan’s Form 5500 Annual Return/Report of Employee Benefit Plan. Fees Relating to Terminations, Withdrawals and Redemptions. PVA’s relationship with each Fund will terminate on expiration of the Fund’s term, dissolution of that Fund or on PVA’s withdrawal or other termination as investment adviser of that Fund. An investor may withdraw or redeem on the last day of any calendar month (subject to PVA’s right to suspend withdrawals or redemptions in certain unusual circumstances and the 25% gate limitation described below) by giving the respective Fund at least 60 days advance notice. If a Parallax Core standard option investor makes a withdrawal or redemption within the first year of the investor’s investment in that Parallax Core Fund, in most cases that investor must pay the respective Fund a fee of up to 2% of the amount withdrawn or redeemed, and if a Parallax Core hurdle option investor makes a withdrawal or redemption relating to an investment within two years of making that particular investment, in most cases that investor must pay Parallax Partners or PVA a fee of up to 2% of the amount withdrawn or redeemed. The Parallax Core Funds may limit investor withdrawals and redemptions over any period of 3 consecutive months to 25% of the aggregate net assets of the Parallax Core Funds (excluding certain assets), except that a Fund will not apply this restriction to any investor on a month end if that investor’s withdrawal or redemption requests on any 2 of the immediately preceding 6 consecutive permitted withdrawal/redemption dates were not fully satisfied. In all cases for all Funds, investors bear expenses, the management fee and the performance allocations through the date of termination, withdrawal, or redemption. Expenses. Each Fund is responsible for its own costs and expenses, as described in the respective Funds’ offering materials. Because of Parallax Core’s unique strategy, its operating expenses typically are much higher, as a proportion of Parallax Core’s assets, than other investment funds. The Funds bear many operational expenses, such as quotation equipment, computer and data systems, risk systems and reporting, trading execution systems, market data licenses, trade reconciliation tools and software, data storage relating to trades and other trade-related ongoing expenses that other investment advisers may bear instead of passing such expenses through to their clients (including licenses with PVA affiliates). Except as described above, PVA and Parallax Partners each bears its own general, administrative and overhead costs and expenses. Securities brokerage firms and futures commission merchants (“FCMs”) that execute securities and commodities trades for the Master Fund, however, may pay all or part of these costs and expenses, as discussed in Item 12 below.

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

As noted above, PVA currently manages only the private Funds described in Item 4, which provide performance-based allocations to Parallax Partners, as described in Item 5. It does not manage accounts that do not pay performance-based compensation. PVA and Parallax Partners may waive some or all fees for certain Fund investors, such as PVA employees and limited partners, and their family members and friends.

Item 7. Types of clients

PVA currently provides investment advice only to the private Funds described in Item 4. Investors in the any of the Funds are required to invest a minimum of $2,000,000, but PVA may waive this minimum.

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

Investment Strategy. Parallax Core invests in and trades primarily, but not solely, U.S. and non-U.S. options (including covered and uncovered puts and calls), stocks and other equity related securities, futures and options on futures, commodities and options on commodities, bonds, notes, warrants, bills, participating and convertible debt instruments, rights, currency forward contracts, swaps and other derivative instruments and other securities of U.S. and non-U.S. issuers that are traded publicly and privately. It also invests in derivatives listed on US regulated exchanges as well as over-the-counter derivatives relating to cryptocurrency, blockchain-based assets and other cryptofinance assets (together, “Digital Assets”).

Read the rest of Item 8 (5,341 more words)

Parallax does not trade or self-custody underlying Digital Assets. Parallax Core also engages in margin trading and seeks to profit from declines in the value of securities and hedge its positions by short selling, futures trading and other strategies. Parallax Core also uses a variety of relative value trading strategies, predominately capital structure and convertible arbitrage, with an objective to generate consistent returns while managing risk and attempting to preserve capital. Parallax Core seeks to achieve its investment objective by investing in securities that PVA believes present arbitrage opportunities, including, without limitation, opportunities resulting from a disparity in the pricing of related securities and “risk arbitrage” opportunities. An opportunity to take advantage of a disparity in pricing of related securities is present when a selected security or a group of securities is, in the opinion of PVA, undervalued in relation to (a) any other related or unrelated security, index, or group of securities or (b) the selected securities’ theoretical or estimated value as judged by PVA. A “risk arbitrage” opportunity exists when a security or a group of securities is, in the opinion of PVA, undervalued in relation to the anticipated value of the cash, securities or other consideration to be paid or exchanged for such securities in a proposed corporate transaction. The Funds offer a standard tranche of shares which are denominated in U.S. dollars. The Master Fund and Parallax Core offshore feeder fund also offer tranches of shares that include hedging against various non-US currencies, and for which investors may subscribe and redeem their shares in those currencies. This Fund currently offers tranches of shares that hedge against Australian dollars, Canadian dollars and Japanese yen, and it may offer additional currency tranche shares in the future. Each investor in a Parallax Core fund may also elect a portable alpha tranche, which pairs the Master Fund’s principal portfolio with a beta portfolio. The beta portfolio generally will correlate to a market benchmark. General. The investment strategy summarized above represents PVA’s current intentions, is general in nature and is not exhaustive. The Master Fund has no limits on the types of securities or commodities it may hold, the types of positions that it may take, the concentration of its investments or the amount of leverage that it may use. PVA frequently adjusts Parallax Core’s trading and investment techniques, and in any such case the revised or new techniques may present new risks not described below. Investors should expect that over time the Master Fund may use trading or investment techniques other than those

contemplated by the investment strategy described above. In addition, there are limitations in describing any investment strategy due to its complexity, confidentiality and indefinite nature. Depending on conditions and trends in securities and commodities markets and the economy generally, PVA may pursue any objectives or use any techniques that it considers appropriate and in the Master Fund’s interest. Each of the feeder funds invests substantially all its assets in the Master Fund. Risk Factors. Investing in securities and commodities involves risk of loss that investors should be prepared to bear. Below are brief summaries of some of the risks that investors should consider before investing in a Fund. Any or all of such risks could materially and adversely affect investment performance, the value of a Fund or any security or commodity held in the Master Fund, and could cause investors to lose substantial amounts of money. Potential Fund investors should review such Fund’s offering materials carefully and entirely, and consult with their professional advisers before deciding whether to invest. A potential client or Fund investor should discuss with PVA’s representatives any questions that such person may have before investing in a Fund. General

The Funds may not achieve their investment objectives. A strategy may not be successful and investors may lose some or all of their investment.

Messrs. Hutchison and Bartlett and the PVA trading team may devote a significant amount of time to activities other than trading. PVA may change the members of its portfolio management team from time to time without notice. If a significant number of the trading team should cease to participate in PVA’s activities, its ability to select attractive investments and manage its portfolio could be impaired.

Risks Associated with the Funds’ Investment Strategy

PVA and the Funds, and their service providers, rely heavily on internal and third-party computer hardware and software, online services, data feeds, including those focused on market data, trading platforms, and other technology and equipment to conduct the Master Fund’s investment and trading activities, trade settlements, operations and accounting processes. Disruptions or malfunctions in the operation of any such technology or equipment, or the communications, power or infrastructure necessary to operate these systems, may make it difficult or impossible to implement a given Master Fund’s investment strategy and could materially and adversely affect any or all of the Funds. Examples of such circumstances include natural disasters, terrorism, cybersecurity attacks, pandemics, public service or utility disruptions or utility problems such as those caused by fires, floods or earthquakes, market trading halts, systems failures, and other extraordinary events. Disruptions or malfunctions in the operation of any of that technology or equipment could materially adversely affect any or all of the Funds.

The Master Fund’s trades are frequently made on electronic markets or using electronic trade routing, and also may utilize proprietary investment models and/or algorithmic execution strategies and/or signals. Such reliance on technology and software presents risks related to system access, varying response times, security, and system or component failure. In the event of system or component failure, it is possible that for a certain time period, it might not be possible to enter new orders, execute existing orders, or modify or cancel orders that were previously entered. Such an event may result in material losses for any or all Funds.

PVA personnel may use artificial intelligence (“AI”) tools for limited purposes, including to retrieve and sort internal records in support of its investment research process, to review and summarize large quantities of public data, to aid us with certain productivity enhancements and similar administrative purposes, to make certain initial coding suggestions and to project out potential financial models and other forecasts. Errors by the AI tools may adversely affect PVA’s investment analysis and operations. While PVA restricts the use of certain open source third-party AI tools and features, it is possible that PVA’s employees and consultants may incorrectly use such AI tools in a way that creates risks relating to the protection of PVA’s proprietary data, including the potential exposure of Fund investor confidential information to unauthorized recipients and the misuse of PVA’s or other third-party intellectual property, which could adversely affect PVA’s ability to maintain its operations.

PVA’s strategies and techniques are continually evolving, and investment positions reflecting new strategies and trading techniques will be incorporated into Parallax Core’s portfolio from time to time. PVA is not restricted from using Parallax Core’s capital to develop and incubate new strategies, even if PVA has limited experience in the type of strategy or in the markets or instruments involved. New strategies developed at the expense of Parallax Core may be unsuccessful or more speculative than Parallax Core’s established strategies, and the resources allocated to implementing new strategies may adversely affect Parallax Core’s established strategies.

Although PVA does employ various security measures, it and the Funds still may be vulnerable to computer viruses, cybersecurity attacks from viruses, malware, computer hackers, and other forms of malicious corruption of their information technology systems. Cybersecurity breaches of the systems of PVA or the Funds, or their service providers (including accountants, custodians, and administrators) may cause disruptions to business operations, cause losses due to theft or other reasons, interfere with the Funds’ net asset value calculations, impede trading, or lead to violations of applicable privacy and other laws, regulatory fines and penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. PVA cannot control the cybersecurity plans and systems put in place by service providers and the issuers in which the Master Fund invests. System breaches can and do occur. Any cybersecurity breach could materially and adversely affect the Funds.

The Master Fund’s investment strategies may include frequent trading in options, swaps, forwards, contracts for difference, futures, commodities and other derivatives. The prices of these instruments generally are more volatile than the prices of the

underlying securities, and prices of futures and other commodities are particularly volatile. The Master Fund may speculate on the prices of such derivatives of securities, commodities and securities exchange indices while investing only a small percentage of capital in relation to the value of the underlying securities, permitting a high degree of leverage, which is also known as margin trading or borrowing on margin.

Swaps and other securities-linked derivatives may be structured as contracts between the Master Fund and a counterparty. These positions present specials risks to such Master Fund, including that they can be highly leveraged and that such Master Fund has exposure to the counter-party’s creditworthiness. In addition, a Fund may not be able to control when a swap or similar derivative terminates, and a swap that has a relatively long term may be difficult or impossible to liquidate before it terminates. These contracts are not traded on exchanges and present significant liquidity risks, especially in times of market disruption.

The Master Fund may trade in non-U.S. options, swaps, forwards, futures, commodities and other derivatives, which present additional risks of loss. Trades in non-U.S. derivatives execute and clear on non-U.S. boards of trade, and are subject to local laws and regulations and foreign currency exposure. The risks of these investments include political risks, economic conditions of the country in which the issuer is located, limitations on foreign investment in any such country, currency exchange risks, withholding taxes, limited information about the issuer, limited liquidity, and limited or no regulatory oversight. In addition, any variance in the foreign exchange rate of the currency in which the derivative is denominated affects the price of such derivative.

The success of the Mater Fund’s relative value strategy depends on PVA’s ability to exploit relative mispricings among interrelated instruments. This strategy is subject to many risks, including the risks of overall market changes, timing differences in pricing corrections and disruptions in historical pricing relationships. Trading in credit instruments, especially of distressed issuers, in a relative value strategy faces the additional risks of possible lengthy and unpredictable reorganizations, workouts and receiverships.

Using stock index futures contracts involves particular risks. Price movements in the stock index and the underlying securities do not always correlate. Positions in futures contracts may be closed out only on the exchange on which they were entered into or through a linked exchange. There is no secondary market for such contracts. In addition, there may be no active market for the contracts at any particular time. Some exchanges do not permit trading in particular contracts at prices that fluctuate more than a set limit in any day. If prices fluctuate during a single day beyond those limits, the Master Fund may not be able to timely liquidate unfavorable positions and losses could result.

A Fund may use significant leverage by borrowing substantially on margin, entering into swaps, selling securities short and trading options, futures and other derivatives, which increases volatility and risk. Trading on margin also results in interest charges, which can be substantial. By trading financial derivatives, the Master Fund may trade

with the economic equivalent of a substantially leveraged position in the underlying securities portfolio, in comparison to its actual assets. While all of these instruments are exchange traded, they also can be difficult to value. An incorrect valuation could result in losses for the Funds. The Master Fund may frequently sell covered and uncovered options on securities. Option prices generally are more volatile than prices of other securities. The sale of uncovered options could result in unlimited losses.

The Master Fund trades in futures contracts and/or options on futures contracts. The trading market for futures positions may be illiquid, and trading may be suspended for regulatory reasons. Trading in commodity futures contracts and options are highly specialized activities that may entail greater than ordinary investment or trading risks. Furthermore, low margin or premiums normally required in such trading may provide a large amount of leverage, and a relatively small change in the price of a security or contract can produce a disproportionately larger profit or loss.

The currency hedged tranches include positions that seek to minimize the differences between the respective Fund’s performance in US dollars and the performance in the specific currency. Likewise, the portable alpha tranche pairs the Master Fund’s strategy with a beta portfolio. For a variety of reasons, hedging may not be effective in controlling risk due to, for example, unexpected non-correlation (or even positive correlation). There may also be a mismatch in timing of the various trades relating to the hedging positions and the respective Fund’s main portfolio. For the portable alpha tranche, the hedging component may generate negative returns in certain market conditions, which could harm the Fund. Additionally, the costs associated with implementing and maintaining the hedging positions may further erode returns.

The Master Fund may have higher portfolio turnover and transaction costs than a similar account managed by another investment adviser. These costs reduce the capital invested and potential profit, or increase losses.

Any Fund may have significant exposure to short positions. Selling securities short generally poses in a theoretically unlimited risk of loss if the prices of the securities sold short increase. In addition, given the general upward trend of the Securities markets over time, this short exposure poses a significant risk to investors. A Fund may materially underperform the market and could lose money during periods of strong market performance. Management and stockholders of an issuer may sue short sellers to deter short sales of the issuer’s securities. PVA and the Funds could be subject to such actions, even if they are baseless, and the Funds could incur substantial costs defending them. To make a short sale, the Master Fund must borrow the securities being sold short. It may be impossible to borrow securities at the most desirable time to make a short sale, particularly in illiquid securities markets. Special rules, which vary by jurisdiction, apply to short sales. For example, temporary or permanent governmental orders may from time to time prevent the Master Fund from executing short sales of these securities at the most desirable time. If the prices of securities sold short increase, the Master Fund may need to provide additional funds or collateral to maintain the short positions. This could require the Master Fund to liquidate other

investments to provide additional collateral. favorable prices.

Such liquidations might not be at

The Master Fund may invest in registered investment companies, such as mutual funds or exchange traded funds (ETFs). Investments in such investment companies present additional risks other than the risks of directly investing in the underlying investments of such investment companies. For example, an ETF may own a significant portion of securities that deviate from the ETF's stated core purpose, or the bid and ask spread for its shares may become significant if the ETF becomes thinly traded and therefore less liquid. Investors in an ETF generally bear all expenses of the ETF, including fees of its investment adviser and custodian, brokerage commissions and legal and accounting fees. As a result, Fund investors bear two levels of advisory fees—the fees of PVA and Parallax Partners, and advisory fees charged by investment advisers of the investment companies in the Master Fund’s portfolio. The Master Fund also bears its own expenses related to the purchase, sale or transmittal of ETF assets. Such fees and expenses may be expected to result in a higher cost of investment than would be the case if Fund investors were to invest directly in such investment companies.

The Master Fund engages in hedging, which may reduce profits, increase expenses and cause losses. Price movements in a hedging instrument and the security hedged do not always correlate, resulting in losses on both the hedged security and the hedging instrument. PVA is not obligated to hedge any Fund portfolio positions, and it frequently may not do so.

The Master Fund may trade in futures and options on futures in many kinds of nonfinancial commodities, including those relating to natural resources, energy, metals, agricultural products and other sectors. Typically the Master Fund will trade in these derivatives only if they are on a major, established exchange. Depending on the sector, prices of these derivatives may be highly volatile and are affected by numerous factors beyond PVA’s control, including: the adequacy of supply, the price and quantity of imports, political conditions and events in other countries that produce such resources, including embargoes and military campaigns, government regulation, explosions, fires, accidents, mechanical breakdowns and the disruption of information technology and systems, climate change, weather conditions, storms, earthquakes, floods, drought, wildfires, pandemics, disease and similar natural disasters, the level of consumer and business demand, including unanticipated changes, transportation, worldwide conservation measures, technological advances, the price and availability of alternative fuels in the case of energy resources, forward selling by producers, purchases made by producers to unwind hedge positions, central bank purchases and sales, production and cost levels in major producing countries, economic or specific changes in an industry that uses a commodity for industrial applications, and global or regional political, economic or financial events and situations.

The Master Fund may trade in forward contracts and options thereon, which are not traded on exchanges and are not standardized. Instead, banks and dealers act as principals in these markets, negotiating each transaction individually. Forward and “cash” trading is substantially unregulated, there are no limits on position sizes or daily

price movements. The principals who deal in the forward markets are not required to continue to make markets in the currencies they trade and these markets can experience periods of illiquidity, sometimes of significant duration. There have been periods during which certain participants in these markets have refused to quote prices for certain currencies or commodities or have quoted prices with an unusually wide spread between the price at which they would buy and that at which they would sell. Disruptions can occur in any market in which the Master Fund trades due to unusually high trading volume, political intervention or other factors. Government controls might also limit the Master Fund’s desired level of forward trading. Any such market illiquidity or disruption could adversely affect the Master Fund.

The Master Fund invests in Digital Asset derivatives only and does not trade Digital Assets directly. The principal risk of trading in Digital Asset derivatives is the rapid and extreme volatility of the underlying Digital Asset prices. In addition, however, such trading is subject to numerous risks that are materially different from the risks associated with traditional securities, and trading in Digital Asset derivatives involves skills and resources that are different from traditional trading. These risks include significant changes in the underlying Digital Assets themselves due to forks and similar events, difficulties and risks associated with transactions in Digital Assets (such as the lack of transparency and valuation risks) and uncertainty about the applicability of various federal, state and non-US laws. Other unique risks of Digital Asset derivatives are (1) that the Digital Assets are not legal tender in the United States and as such their value is based on their perceived value and the agreement of the parties in the transaction, which make these derivatives highly volatile, potentially subject to rapid and substantial price movements which could result in significant losses, (2) the lack of a centralized pricing source poses valuation challenges for market participants trying to exit a position, particularly during periods of stress, (3) the new and rapidly evolving technology underlying Digital Assets could also have adverse implications for investors, and (4) many Digital Assets allow market participants to introduce fees which may not be defined or known adding to the cost on a pass through basis to investors, which may affect the pricing or liquidity of the Digital Asset derivatives.

Digital Assets also present unique counterparty risks, due in part to the developing and uncertain regulatory status of many of the firms that provide Digital Asset services and trade Digital Asset derivatives. Digital Assets are subject to loss, theft or restrictions on access, security breaches, cyber-attacks and computer breaches that may lead to a complete loss of certain Digital Assets and therefore a complete loss of value related to the Digital Asset derivatives traded by Parallax.

PVA may not obtain complete or accurate information about an investment and may misinterpret the information that it does receive.

Counterparties such as brokers, dealers, FCMs, banks and other custodians with which PVA does business on behalf of the Funds may default on their obligations. For example, the Master Fund may lose its assets on deposit with a broker or bank if the broker, its clearing broker, an exchange clearing house or a bank becomes bankrupt or insolvent. Further, the Master Fund may conduct some transactions, including swaps

as described above, in “over-the-counter” or interdealer markets. These transactions expose the Funds to the risk that a counterparty may default on its agreement with the Master Fund, resulting in losses.

PVA may cause the Master Fund to enter into repurchase agreements or reverse repurchase agreements. These instruments can have effects similar to margin trading and leveraging strategies.

The Master Fund may trade in securities of Asian and other non-U.S., private and government issuers. The risks of these investments include political risks; economic conditions of the country in which the issuer is located; limitations on foreign investment in any such country; currency exchange risks; withholding taxes; limited information about the issuer; limited liquidity; and limited regulatory oversight.

PVA may from time to time identify an investment opportunity that it believes is attractive but either (1) inappropriate at any size, or (2) appropriate for a fund family, but too large for it. In that case, PVA may offer to certain new or existing investors, including PVA’s principals, the opportunity to invest in such an investment separate from the current Funds. A new investment fund for such an opportunity may bear lower (or no) management fees and special profit allocations, as well as less frequent liquidity than the Funds. If PVA sets up a new investment fund for such an opportunity and the new fund invests in the opportunity alongside an existing fund family, the existing Funds may receive less favorable pricing or bear more than their pro-rata share of expenses relating to the opportunity, and sales by the new fund may adversely affect the price at which the existing Master Fund’s position in the same security is bought or sold.

Changes in economic conditions can adversely affect investment performance. At times, economic conditions in the U.S. and elsewhere have deteriorated significantly, resulting in volatile securities and commodities markets, rapid changes in interest rates, high inflation, contracting credit availability and large investment losses. Government actions responding to these conditions could lead to other negative consequences to investors.

PVA may need to modify the Master Fund’s investment strategy in the future to compete in a changing business environment or to respond to regulatory measures (U.S. or foreign government) adopted to address changes in market conditions or respond to a financial crisis. These potential future government measures may have further negative consequences for any Fund and may unpredictably diminish future available opportunities for any Fund. Given the unpredictable nature of the market environment, PVA may not timely anticipate or manage existing, new or additional risks, contingencies or developments, including regulatory developments and trends in new products and services in the current or future market environment.

The Master Fund’s portfolio positions may be or become illiquid at any time, in which case the Master Fund may not be able to sell such positions, at the risk of financial loss or detriment.

Investment Funds’ Structure Risk

PVA consults with the Funds’ administrator to determine the value of securities and commodities held in the Master Fund’s accounts, whether or not a public market exists for those instruments. If this valuation is inaccurate, PVA or Parallax Partners might receive more compensation than that to which they are entitled, or a new Fund investor might receive an interest that is worth more or less than the investor paid and an investor that is withdrawing or redeeming assets might receive more or less than the amount to which the investor is entitled, resulting in a loss for that investor or the other investors in that Fund.

PVA places orders for the purchase and sale of securities with brokers and/or FCMs on behalf of the Master Fund. The trading process is complex and can vary for different types of instruments. PVA may make trade errors. The Funds and not PVA generally are responsible for any trade errors that PVA makes in an account, even when the error hurts the Funds or Fund investors, unless, at any time when the underlying assets of a Fund are treated as “plan assets” under ERISA and if the conduct resulting in such loss results from PVA’s breach of its fiduciary duties under ERISA.

PVA and its affiliates and agents generally are not responsible to any client or investor for losses incurred by a Fund unless the conduct resulting in such loss results from PVA’s gross negligence or willful misconduct. However, if the underlying assets of a Fund are considered to be “plan assets” for purposes of ERISA, the enforceability of these provisions will be subject to the restrictions of ERISA.

The Funds have engaged various service providers, such as the administrator, auditors, prime brokers and custodians. These service providers may not be subject to credit evaluation and regulatory oversight and may default on their contractual obligations to the Funds. Further, some of the contracts with these service providers include provisions that require the Funds to hold them harmless and indemnify them for losses and claims arising from their activities.

Each Fund is a single legal entity, even if the Fund has multiple series or tranches of interests. A Fund’s creditors may enforce claims against all of that Fund’s assets, regardless of whether that liability is attributable to a particular series or tranche of interests.

There is not currently an active market for Fund interests and there likely never will be. It may be impossible to transfer Fund interests, even in an emergency.

A Fund may be unable to generate cash necessary to satisfy investor withdrawals and redemptions. Substantial withdrawals and redemptions in a short period could force the Master Fund to sell portfolio positions too rapidly, and may so reduce the size of such Fund that it cannot generate returns or reduce losses.

If investors seek to withdraw or redeem more than 25% of Parallax Core Funds’ aggregate assets over any 3 consecutive months, those Funds may limit withdrawals and redemptions to such 25%, subject to certain exceptions.

A Fund may establish a reserve for contingencies if PVA or Parallax Partners considers it appropriate. Investors may not withdraw or redeem assets covered by that reserve until it is lifted.

If the assets that PVA manages grow too large, it may adversely affect performance because it is more difficult for PVA to find attractive investments as the amount of assets that it must invest increases.

The attorneys who represent PVA do not represent the Funds or Fund investors. Fund investors must hire their own counsel for legal advice and representation.

The Funds may dissolve or expel any investor at any time, even if such actions adversely affect such investor.

PVA, the Funds’ administrator or any government agency may freeze assets that any of them believes an investor holds in violation of anti-money laundering laws or rules or on behalf of a suspected terrorist, and may transfer such assets to a government agency. None of PVA, the Funds or the Funds’ administrator will be liable for losses related to actions taken in an effort to comply with anti-money laundering regulations.

The Funds do not intend to make distributions, but intend instead to reinvest substantially all income and gain. Therefore, an investor may have taxable income from a Fund without a cash distribution to pay the related taxes.

Federal, state and international governments are increasing regulation of investment advisers, private investment funds and derivative securities, which may increase the time and resources that PVA must devote to regulatory compliance, to the detriment of investment activities. In addition, the Master Fund may be an electronic trading member of any option and/or commodities exchange. Although the Master Fund likely receives trading benefits from these memberships, it faces additional compliance burdens relating to exchange requirements.

PVA currently is not registered as a broker-dealer with the SEC or FINRA. The interests in the Funds are not registered under the Securities Act of 1933, and the Funds are not registered investment companies under the Investment Company Act of 1940. PVA believes that none of these registrations is required because exemptions are available under applicable law. If a regulatory authority deems that any of these registrations is required, PVA and any Fund could be subject to expensive and distracting legal action and potential termination. In addition, investors in the Funds do not have certain regulatory protections that they would have if these registrations were in place.

PVA’s activities could cause adverse tax consequences to clients and investors, including liability for interest, penalties, and withholding. Significant tax legislation has recently been enacted, the interpretation and application of which is still uncertain, and other legislation has been proposed which, if enacted, could modify the tax treatment of Fund investors or the Funds themselves. Similarly, new withholding taxes and other changes to tax regulation, or adoption of new tax legislation or regulation, could adversely affect clients and investors.

PVA’s activities may cause an account that is subject to the ERISA to engage in a prohibited transaction under that Act. Although the assets of the Funds currently are not treated as “plan assets” for purposes of ERISA, PVA does not currently intend to restrict ownership of any Fund by ERISA investors, and PVA expects that benefit plan investors may in the future own over 25% of the Master Fund, which will cause that Master Fund’s assets to become “plan assets” under ERISA. If any Fund’s assets become “plan assets,” ERISA and related tax provisions may limit such Fund’s investments and PVA’s activities.

If a Fund becomes insolvent, investors may be required to return with interest any distributions and forfeit any undistributed profits.

PVA and its affiliates have conflicts of interest between their own interests and the interests of the Funds. For example, they may spend time on activities that compete with a Fund without accountability to investors, including investing for other clients and their own accounts. If PVA receives better compensation and other benefits from managing other assets or client accounts compared to managing a Fund, it has incentive to allocate more time to those other activities. These factors could influence PVA not to make investments on the Master Fund’s behalf even if such investments would benefit the Funds.

PVA may provide certain investors or clients more frequent or detailed reports or notifications, reduced performance allocations, expense caps, special compensation arrangements, withdrawal or redemption rights, and “most favored nations” rights that it does not provide to other investors or clients.

PVA may in the future establish fund families other than Parallax Core. Although a new fund family is expected to have its own unique objectives, risks, and strategy, there may be some overlaps between the fund families’ investment positions, which would present potential conflicts in allocating investment opportunities, and in allocating certain fund-related expenses.

The above is only a brief summary of some of the important risks that a Fund investor may encounter. Before deciding to invest in a Fund, you should consider carefully all of the risk factors and other information in the respective Fund’s offering circular or private offering memorandum.

Item 9. Disciplinary information

Neither PVA nor its management persons have any legal or disciplinary events to disclose that are covered by this item or otherwise material to an investor’s or prospective investor’s evaluation of PVA’s advisory business or the integrity of its management.

Item 10. Other financial industry activities and affiliations

PVA’s affiliate, Parallax Partners, LLC, a California limited liability company (“Parallax Partners”), is the general partner of the Master Fund and the onshore feeder fund.

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

Code of Ethics, Participation or Interest in Client Transactions and Personal Trading PVA has adopted a Code of Ethics in compliance with Rule 204A-1 under the Advisers Act that establishes standards of conduct for its supervised persons. The Code of Ethics requires PVA’s supervised persons to comply with their fiduciary obligations to clients and applicable securities laws, and includes specific requirements relating to personal trading, insider trading, conflicts of interest, confidentiality of client information and other requirements.

Read the rest of Item 11 (254 more words)

The Code of Ethics requires supervised persons to comply with the personal trading restrictions described below and to report their personal securities transactions and holdings periodically to PVA’s Chief Compliance Officer, and requires the Compliance Department to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to PVA’s Compliance Department. PVA provides a copy of the Code of Ethics and any amendments to it to its supervised persons, each of whom must acknowledge having received the materials. Periodically, each supervised person must certify that he or she complied with the Code of Ethics. Clients and prospective clients may obtain a copy of PVA’s Code of Ethics by contacting Jill Armstrong at jarmstrong@parallaxfund.com or (415) 445-6646. Under PVA’s Code of Ethics, PVA’s officers and employees may personally invest in equities or other securities (including Digital Assets such as cryptocurrencies) only with prior approval from PVA's Compliance Department. In addition, such persons generally may execute only a limited number of pre-approved trades in a calendar month and generally must hold positions for a minimum number of days, unless PVA waives these restrictions. PVA uses tracking software to compare all employees’ trades against these restrictions, but trades in Digital Assets generally are not held in accounts that PVA can track, so PVA relies on employees to self-report these transactions. These persons also must submit to the Compliance Department quarterly reports regarding transactions and active accounts, as well as annual confirmations of holdings, active accounts and various compliance acknowledgements.

Item 12. Brokerage practices

PVA has complete discretion in selecting the broker or FCM that it uses for client transactions and the commission rates that a Fund pays. PVA strives to allocate portfolio transactions to brokers and FCMs based primarily on best execution, including net price and other factors. These other factors include, for example:

clearance, settlement and reputation; financial strength and stability; efficiency of execution and error resolution; the availability of stocks to borrow for short trades; special execution capabilities; block trading and block positioning capabilities; willingness to execute related or unrelated difficult transactions in the future; order of call; custody, recordkeeping and similar services; offering to PVA on-line access to computerized data regarding clients’ accounts; and other matters involved in the receipt of brokerage services generally.

Read the rest of Item 12 (960 more words)

PVA may also receive from a broker or FCM or allow a broker or FCM to pay for the following (each a “soft dollar” benefit):

research reports, services, industry conferences and economic and market information; investment opportunity idea generation; performance measurement data; on-line pricing; industry and company comments; and technical data and recommendations.

PVA may cause the Master Fund to pay a brokerage commission that exceeds that which another broker or FCM might charge for effecting the same transaction in recognition of the value of the brokerage and other services and relationships provided to PVA by that broker or FCM. PVA may purchase (via a formal soft dollar 28(e) safe harbor account or other similar arrangement) from a broker or FCM or allow a broker or FCM to pay for research, information and other services described above, and all or a portion of the costs and expenses of operation of PVA or the Funds, such as computer hardware and software, newswire and data processing charges, quotation services, periodical subscription fees and the like, although PVA does not engage in those practices at this time. If it did purchase or obtain these items through brokers or FCMs, the Funds may be deemed to be paying for these other services with “soft” or commission dollars as well as profits that brokers make on principal trades.

Federal law provides a “safe harbor” to investment advisers who use commission dollars of their advised accounts to obtain investment research and brokerage services that provide lawful and appropriate assistance to the adviser in performing investment decision-making responsibilities. Conduct outside of the safe harbor is subject to the traditional standards of fiduciary duty under state and federal law. If PVA receives soft dollar goods and services with respect to a Fund’s brokerage transactions in the future, they are expected to be within this safe harbor, and, during the time that the assets of a Fund are considered to be “plan assets” under ERISA, the soft dollar goods and services are required to be within this safe harbor. In addition, PVA may in the future receive soft dollar credits on principal, as well as agency, securities transactions with brokers and FCMs. The relationships with brokers and FCMs that provide services to PVA influence PVA’s judgment in allocating brokerage transactions and create a conflict of interest in using the services of those brokers and FCMs to execute a Fund’s brokerage transactions. The brokerage fees that a Fund pays benefit PVA at the expense of such Fund, to the extent that the brokers provide service to PVA that are not otherwise reimbursable by the Funds. PVA believes that these relationships benefit it and the Funds, but Fund trades executed through these firms or any other broker or FCM may or may not be at the best price otherwise available. PVA addresses these conflicts of interest by periodically evaluating the trade execution services that it receives from the brokers and FCMs that it uses to execute trades for clients. Such evaluation includes comparing those services to the services available from other brokers and FCMs. PVA considers, among other things, alternative brokers, market makers and market centers, the quality of execution services, the value of continuing with various services and adding or removing brokers or FCMs, increasing or decreasing targets for each broker or FCM and the appropriate level of commission rates. PVA also may direct Fund brokerage transactions to brokers and FCMs that refer prospective investors to the Funds. PVA has retained J.P. Morgan Securities LLC, Goldman Sachs & Co. LLC, Goldman Sachs International, Barclays Capital Inc. and Marex Capital Markets Inc. to serve as the Parallax Core’s prime brokers. In general, these prime brokers, and in some cases their affiliates, also serve as the custodians of substantially all the assets of the Funds, and as mentioned above all feeder funds invest substantially all of their assets in the Master Fund. PVA may replace any firm or appoint one or more additional prime brokers at any time for any Fund. The services that these firms currently provide as prime brokers may include custody, margin financing, trade execution, clearing, settlement and stock borrowing in accordance with the terms of the prime brokerage agreements entered into between the Funds and these firms. These firms may provide other services to PVA, including news and stock market information systems and connections, consulting services, capital introduction services and access to electronic communications networks. PVA uses a substantial portion of these services for research and trading on behalf of the Master Fund, but if any is used for administrative purposes that use would not be within the federal safe harbor described above. Although many prime brokers provide similar services to investment advisers in exchange for brokerage, custody and clearance fees and other

charges, if PVA did not receive these services from a broker or FCM, PVA would be required to pay for all or some portion of them. PVA is not required to direct a particular number of trades to any prime broker or to continue to use that firm as a custodian, but it has an incentive to do so based on such services. The prime brokers’ addresses are listed below. All custodians of the Funds (including affiliates of the Funds’ prime brokers) are listed in Item 25 of Section 7.B(1) of Schedule D of PVA’s Form ADV, Part 1A. J.P. Morgan Securities LLC

383 Madison Avenue, New York, NY 10179

Goldman Sachs & Co. LLC

200 West Street, New York, NY 10282

Goldman Sachs International

133 Fleet Street, London EC4A 2BB, United Kingdom

Barclays Capital Inc.

745 7th Avenue, New York, NY 10019

Marex Capital Markets Inc.

140 East 45th Street, 10th Floor, New York, NY 10017

None of PVA’s clients may direct brokerage selection.

Item 13. Review of accounts

S. Daniel Hutchison, PVA’s principal portfolio manager, reviews the Master Fund’s portfolios daily, or more frequently as appropriate. Those reviews take into account such matters as concentrations, risk exposure and capital usage. PVA provides a monthly summary report estimating performance results, annual tax information, and audited financial statements to Fund investors.

Item 14. Client referrals and other compensation

PVA has no arrangements to compensate any person directly or indirectly specifically for investor or client referrals. If it does enter into any such arrangement, PVA will disclose in writing to the client and comply with the other requirements of Rule 206(4)-1 under the Investment Advisers Act of 1940, to the extent required by applicable law.

Item 15. Custody

The explanation required by this item does not apply to PVA’s custody or account arrangements. Under the SEC’s custody rule, PVA is deemed to have custody of all Fund assets because its affiliate, Parallax Partners, serves as the general partner of the Master Fund. In accordance with the SEC’s custody rule, PVA has arranged that:

Each Fund’s financial statements are audited on an annual basis in accordance with the U.S. generally accepted accounting principles by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board,

Such audited financial statements are distributed to each Fund’s investors within 120 days of the end of that Fund’s fiscal year, and

Read the rest of Item 15 (61 more words)

All Fund assets, with the exception of certain private securities that are held in accordance with the August 2013 Custody Rule guidance from the SEC's Division of Investment Management, are held at prime brokers and/or in custodial bank or trust accounts, all of which are deemed qualified custodians under the SEC’s custody rule. All Digital Assets are held at qualified custodians.

Item 16. Investment discretion

PVA has discretionary authority to manage the Master Fund investment portfolio pursuant to a grant of authority in the Master Fund’s Investment Adviser Agreement.

Item 17. Voting client securities

The Master Fund generally trades derivative instruments (such as options) and holds, periodically, long and short positions in non-derivative equity securities to hedge investments in derivative instruments. Such equity investments are generally held for less than two months. Because equity positions are generally held for such a short time, when the Master Fund holds an equity security on the record date for an annual shareholder meeting, it usually has traded out of that security before the meeting occurs. PVA believes that voting equity securities in which the Master Fund no longer holds a position may not be in the best interest of the Master Fund. PVA generally monitors the markets and information available about these equity securities.

Read the rest of Item 17 (187 more words)

This monitoring often includes corporate events such as proposed mergers, acquisitions, and other significant matters for which the issuer will request shareholder approval, or ballot measures contested at shareholder meetings. If an issuer gives notice for a shareholder meeting (other than an annual shareholders meeting at which compensation, non-contested elections of directors and other ballot items that are not expected to affect the price or volatility of the equity security or related derivatives), PVA considers whether holding that equity security (and the related derivatives, as appropriate) continues to be appropriate within the Master Fund’s investment strategy, and it will trade that security as it determines is in the interest of the Master Fund. Even in these situations, PVA generally does not vote proxies distributed in connection with these events because it does not expect to hold the equity securities long enough for the event to affect the Master Fund’s investment. A client can obtain a copy of PVA’s proxy voting policy and a record of votes cast by PVA on behalf of that client by contacting the CCO at the contact information shown in Item 11 above.

Item 18. Financial information

PVA does not require prepayment of advisory fees and is therefore not required to include a balance sheet for its most recent fiscal year. PVA is not the subject of any financial condition that is reasonably likely to impair its ability to meet its contractual obligations to the Funds or the subject of any bankruptcy petition, nor has it been the subject of any bankruptcy petition at any time during the past 10 years.

Read the rest of Item 18 (1,585 more words)

Privacy Notice Parallax Volatility Advisers, L.P. (“PVA”) and its affiliate, Parallax Partners, LLC (“Parallax”), and the private funds to which PVA serves as the investment adviser (the “Funds,” together with PVA and Parallax, “we,” “us” and “our”) have adopted a policy to safeguard the confidential information provided to them by their limited partners and shareholders, former limited partners and shareholders, and persons who have applied to be limited partners and shareholders (together, “Investors”) and other persons who provide Personal Information to us by contacting us, or whose information has been provided to us (“Contacts,” together with Investors, “you”). This Privacy Notice explains the manner in which we collect, utilize and maintain nonpublic personal information and personal data about the Investors and Contacts. We are providing you with this Privacy Notice to help you understand how we handle and use your nonpublic personal information (“Personal Information”) that we collect. As used herein, the term “Personal Information” refers to non-public personal information, as defined in the Gramm-Leach-Bliley Act and personal information as defined in the California Consumer Privacy Act (“CCPA”). Our collection, use, storage and disclosure of Personal Information is limited to what is necessary to provide you with the services you have requested or authorized. We do not collect, store, use or disclose Personal Information for any other purpose. Information We Collect and Disclose. We only collect, use, store and disclose your Personal Information where we have a lawful basis to do so, and we do not knowingly collect or solicit Personal Information from anyone under the age of 16 without parental or guardian consent. We, including parties acting on our behalf or on behalf of the Funds (such as the Funds’ administrator) collect and disclose (for the purposes described below) several types of Personal Information, including:

Information you or your financial representatives have provided on forms used in connection with your investments, such as personal information that we may use to communicate with you, some or all of which may not be publicly available (your name, residential and business addresses, e-mail address, telephone numbers and other contact information), certain identifying information such as your social security number, and information necessary for us to market our services to you or comply with laws and regulations that apply to our Funds;

Information concerning your financial circumstances, such as your investment qualifications, household income and net worth;

Information you have provided orally to us or to any of our affiliates, including information from and about you if you interact with us by phone, email or other electronic communication;

Information about the amounts you have invested in a Fund, such as your initial investment, current capital account balances and any purchases and redemptions from a Fund;

Information necessary to conduct financial transactions associated with investments in the Funds, such as information about any bank account used to transfer between your investment in a Fund and your bank, including information provided when effectuating wire transfers; and

Information we receive from third parties, including information from referral sources and that is generated by our service providers, such as administrators, accountants, bankers and custodians, to service our investors and accounts (such as account statements, tax information reports, transaction records and confirmations of contributions and withdrawals and similar information).

If you provide Personal Information about any person other than yourself, you must ensure they understand how their Personal Information will be used and that they have given their permission for you to disclose their Personal Information. Use of Your Personal Information. We use your Personal Information for the following limited business purposes and as otherwise described in this Privacy Policy: To evaluate and effect investment transactions and contracts, manage the investment services we provide you and help maintain the safety, security and integrity of our business and assets;

To ascertain your ability to invest in the Funds;

To comply with any applicable legal and regulatory obligations and the compliance obligations required by our service providers; To communicate with you about your investments, our other services and products, and updates regarding our firm; and On occasion, we may ask for your consent to use your Personal Information for purpose(s) we explain at that time. Information We Disclose. We disclose the Personal Information collected to provide clients with service and to comply with law. We do not disclosure nonpublic Personal Information with anyone except as permitted or required by law. We may disclose nonpublic Personal Information to our affiliates, including those who are involved in the operation, administration or management of, or the sale of interests in the Fund of which you are an Investor, and nonaffiliated service providers and regulators as permitted by law. This may include sharing nonpublic Personal Information to:

Our legal counsel, accountants, brokers, administrators, auditors or other companies that assist us with mailing statements or processing transactions;

Facilitate administrative and operative functions of the Fund, such as in connection with periodic financial reports;

Maintain our internal administrative, communication, marketing and contact records, investor records, communication and data management software, including using outside data storage and software for these functions;

Respond to a subpoena or a court order, judicial process or regulatory inquiry;

In the case of a proposed or actual merger, acquisition by another company or sale of all or part of our business; and

Persons acting as a fiduciary or representative capacity on your behalf with your consent and upon your authorization.

We do not sell or otherwise disclose your Personal Information for monetary or other valuable consideration. Data Retention. We retain your Personal Information during the period you are an Investor in a Fund, and for as long thereafter as is permitted by applicable law, necessary to resolve disputes or necessary for legitimate business purposes. Confidentiality and Information Security. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your Personal Information. We have always considered protecting sensitive information to be a sound business practice. As such, we restrict access to Personal Information about you to those employees who need to know that information to provide products or services to you. Additional California State Privacy Protections. Residents of California may have certain rights with respect to their Personal Information that is protected by applicable state law, including the following rights (subject to certain exceptions and limitations): Right to Know. You have the right to request (a) the categories and specific pieces of Personal Information we collect and disclose; (b) the categories of sources from which we have collected your Personal Information; (c) the categories of third parties to whom your Personal Information was shared or disclosed for a business purpose; and (d) the business purposes for such collection and disclosure of your Personal Information. Right to Request. You have the right to request a list of the Personal Information (if any) disclosed to third parties for direct marketing purposes in the prior 12 months. Right to Delete. You have the right to access and then delete your Personal Information that we have collected from you or maintained about you (except to the extent we are required by law to retain any record). Right to Correct Inaccurate Information. If we maintain inaccurate information about you, you have the right to request correction of that inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of the Personal Information processing. We will use commercially reasonable efforts to correct this information.

Right to Limit. We do not use or disclose sensitive Personal Information for purposes other than those permitted by CCPA regulations section 7027(m). Right to Opt-Out. You have the right to opt-out of the sale or sharing of Personal Information for targeted advertising purposes. However, we do not sell or share your Personal Information. California residents also have the right to not be discriminated against for exercising any of the rights described above. However, to the extent your Personal Information is required to meet anti-money laundering or other legal requirements, failure to provide that information or a request that we delete such information may make you ineligible to do business with us or to continue investing with us. To help protect your privacy and maintain security, we will verify your identity before granting access to your Personal Information or complying with your request. If you request to access or delete your Personal Information, we will verify your identity by comparing information we have on file against information you may provide us. If you designate an authorized agent to make a request to access or delete your Personal Information on your behalf, we may require you to (1) provide the authorized agent written permission to do so, and (2) verify your own identity directly with us (as described above). Changes to this Privacy Notice. We reserve the right to change our privacy policy in the future. If we make changes that affect your Personal Information, we will notify you. Additional Information or Requests. If you have any questions about this privacy notice, or if you wish to make any requests as listed above for California residents, please contact us at compliance@parallaxfund.com, or by collect call to 415-445-6646. There are circumstances where we are not required to comply with consumer requests and we will let you know if one of those situations applies. We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

04518\013\10605964.v2 04518\013\10851913.v4

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