Pantera Capital: investment adviser

2. Pantera Advisors LLC Pantera Advisors LLC (“Pantera Advisors”) is a Delaware limited liability company that was formed in 2004. DMDM Ventures is the managing member of and controls Pantera Advisors LLC.

3. Pantera Capital Management LP Pantera Capital Management LP (“PCM LP”), is a Delaware limited partnership that was formed in 2004. Pantera Capital Management LP is controlled by its general partner, Pantera GP LLC, which is wholly owned by DMDM Ventures.

4. Pantera HK Limited Pantera HK Limited (collectively with Pantera Advisors and PCM LP, the “Relying Advisers” and, the Relying Advisers together with the Filing Adviser, the “Investment Adviser”, “we”, “us”, and similar terms) is a Hong Kong corporation formed in 2024. Pantera HK Limited is controlled by its general partner, Pantera GP LLC, which is wholly owned by DMDM Ventures.

5. Fund General Partner Entities Our registration on Form ADV also covers Pantera Venture GP LLC (the “Venture General Partner”), Pantera Venture II GP LLC (the “Venture II General Partner”), Pantera Venture III GP LLC (the “Venture III General Partner”), Pantera Blockchain GP LLC (the “Blockchain General Partner”), Pantera Blockchain Venture GP LLC (the “Blockchain Venture General Partner”), Pantera Liquid and Early-Stage Token GP LLC (the “Liquid and Early-Stage Token General Partner”),Pantera Opportunities GP LLC (the “Opportunities General Partner”), and Pantera Fund V GP LLC (the “Fund V General Partner”, collectively with the Venture General Partner, the Venture II General Partner, the Venture III General Partner, the Blockchain General Partner, the Blockchain Venture General Partner, the Liquid and Early-Stage Token General Partner, and the Opportunities General Partner, the “Fund General Partners”), which are all limited liability companies organized under the laws of the state of Delaware. The Fund General Partners are affiliates of the Investment Adviser and serve or may serve as the general partner of

Funds (as defined below) that are U.S. or offshore partnerships. The Fund General Partners’ facilities and personnel are provided by the Investment Adviser. The Principal Owner is the principal owner of, and controls, the Fund General Partners, which are directly owned by DMDM Ventures. B. Description of Advisory Services This Brochure generally includes information about us and our relationships with our clients and affiliates. While much of this Brochure applies to all such clients and affiliates, certain information included herein applies to specific clients or affiliates only.

6. Advisory Services We serve as the investment adviser, with discretionary trading authority, to private pooled investment vehicles, the securities of which are offered to investors on a private placement basis (each, a “Fund” and collectively, the “Funds”). Our “clients” are discussed herein. The Funds include:

Pantera Venture Fund LP, a Delaware limited partnership (the “Venture I Fund”);

Pantera Venture Fund II LP, a Delaware limited partnership (the “Venture II Fund”),

Pantera Venture Fund III LP, a Delaware limited partnership (the “Venture III Fund”);

Pantera Venture Fund III A LP, a Delaware limited partnership (the “Venture III A Fund”);

Pantera Venture Offshore Fund III LP, a Cayman Islands exempted limited partnership (the “Venture III Offshore Fund”, and together with the Venture I Fund, the Venture II Fund, the Venture III Fund and the Venture III A Fund, the “Venture Funds”);

Pantera Early-Stage Token Fund Ltd, a Cayman Islands exempted company (the “Early-Stage Token Offshore Fund”);

Pantera Early Stage Token Master Fund LP, a Cayman Islands exempted limited partnership (the “Early Stage Token Master Fund”, and together with the EarlyStage Token Offshore Fund, the “Early-Stage Token Offshore Funds”);

Pantera Early-Stage Token Fund LP, a Delaware limited partnership (the “EarlyStage Token Fund I”);

Pantera Early-Stage Token Fund II LP, a Delaware limited partnership (the “EarlyStage Token Fund II”, and together with the Early-Stage Token Fund I, the “Early- Stage Token Funds”);

Pantera Bitcoin Feeder Fund Ltd., a Cayman Islands exempted company (the “Bitcoin Feeder Fund”);

Pantera Bitcoin Fund Ltd., a Cayman Islands exempted company (the “Bitcoin Fund”, and together with the Bitcoin Feeder Fund, the “Bitcoin Funds”);

Pantera Liquid Token Fund LP, a Delaware limited partnership (the “Liquid Token Fund”);

Pantera Liquid Token Offshore Fund Ltd, a Cayman Islands exempted company (the “Liquid Token Offshore Fund”);

Pantera Liquid Token Offshore Master Fund LP, a Cayman Islands exempted limited partnership (the “Liquid Token Master Fund”, and together with the Liquid Token Fund, and the Liquid Token Offshore Fund, the “Liquid Token Funds”);

Pantera Blockchain Fund LP, a Delaware limited partnership (the “Blockchain Fund”);

Pantera Blockchain Venture Fund LP, a Delaware limited partnership (the “Blockchain Venture Fund”);

Pantera Blockchain Offshore Fund LP, a Cayman Islands exempted limited partnership (the “Blockchain Offshore Fund”);

Pantera Fund V LP, a Delaware limited partnership (the “Fund V Master Fund”);

Pantera Fund V Offshore LP, a Cayman Islands exempted limited partnership (the “Fund V Offshore Fund” and together with the Fund V Master Fund, the Blockchain Offshore Fund, and the Blockchain Fund, the “Blockchain Funds”);

Pantera Solana Offshore Fund LP, a Cayman Islands exempted limited partnership (the “Solana Offshore Fund”);

Pantera Solana Fund LP, a Cayman Islands exempted limited partnership (the “Solana Master Fund”, and together with the Solana Offshore Fund, the “Solana Funds”);

Pantera Token-25 Fund LP, a Delaware limited partnership (the “Token-25 Fund”);

Pantera Token-25 Offshore Fund LP, a Cayman Islands exempted limited partnership (the “Token-25 Offshore Fund”);

Pantera Token-25 Master Fund LP, a Cayman Islands exempted limited partnership (the “Token-25 Master Fund”, and together with the Token-25 Fund, and the Token- 25 Offshore Fund, the “Token-25 Funds”);

Pantera Fund V Beta Bridge LP, a Delaware limited partnership (the “Beta Bridge Fund”);

Pantera Fund V Beta Bridge Offshore LP, a Cayman Islands exempted limited partnership (the “Beta Bridge Offshore Fund” and together with the Beta Bridge Fund, the “Beta Bridge Funds”);

Pantera Opportunities Fund LP, a Delaware series limited partnership (the “Opportunities Domestic Fund”);

Pantera Opportunities Fund SPC, a Cayman Islands exempted limited company registered as a segregated portfolio company (the “Opportunities Offshore Fund”);

Pantera Opportunities Master Fund SPC, a Cayman Islands exempted limited company registered as a segregated portfolio company (the “Opportunities Master Fund” and together with the Opportunities Domestic Fund and the Opportunities Offshore Fund, the “Opportunities Umbrella Funds”);

Pantera Opportunities Fund LP Ton, a Delaware registered series (the “TON Fund”);

Pantera Opportunities Fund TON SP1, a Cayman Islands segregated portfolio (the “TON Offshore Fund”);

Pantera Opportunities Master Fund TON SP. a Cayman Islands segregated portfolio (the “TON Master Fund”, and together with the TON Fund and TON Offshore Fund, the “TON Funds”);

Pantera Opportunities Fund LP WLD, a Delaware registered series (the “WLD Fund”);

Pantera Opportunities Fund WLD SP1, a Cayman Islands segregated portfolio (the “WLD Offshore Fund”);

Pantera Opportunities Master Fund WLD SP. a Cayman Islands segregated portfolio (the “WLD Master Fund”, and together with the WLD Fund and WLD Offshore Fund, the “WLD Funds”);

Pantera Opportunities Fund LP DAT, a Delaware registered series (the “DAT Fund”);

Pantera DAT Opportunities Fund SP1, a Cayman Islands segregated portfolio (the “DAT Offshore Fund”); and

Pantera DAT Opportunities Master Fund SP, a Cayman Islands segregated portfolio (the “DAT Master Fund”, and together with the DAT Fund and the DAT Offshore Fund, the “DAT Funds”, and together with the Opportunities Umbrella Funds, the WLD Funds, and the TON Funds, the “Opportunities Funds”).

The Venture General Partner serves as the general partner of the Venture I Fund, the Venture II General Partner serves as the general partner of the Venture II Fund, the Venture III General Partner serves as the general partner of the Venture III Fund, the Venture III A Fund and the Venture III Offshore Fund, and the Liquid and Early-Stage Token General Partner serves as the general partner of the Liquid Token Funds, the Early-Stage Token Funds, the Early-Stage Token Offshore Funds, the Token-25 Funds and the Beta Bridge Funds. The Blockchain General Partner serves as the general partner to the the Blockchain Offshore Fund, the Blockchain Fund, and the Solana Funds. The Blockchain Venture General Partner serves as the general partner to the Blockchain Venture Fund. The Opportunities General Partner serves as the general partner to the Opportunities Funds.

The Fund V General Partner serves as the general partner to the Fund V Offshore Fund and the Fund V Master Fund.

7. Investment Strategies and Types of Investments We have included below summaries of the investment strategies for all of our clients. Please see Item 8 for additional information. (a) Venture Funds The Venture Funds pursue venture capital investments in businesses that seek to use blockchain technology and other less-liquid investments (excluding Early-Stage Token Offerings (as defined below) and digital assets (“Digital Assets”)) (“Blockchain Technology Venture Assets”). The Investment Adviser seeks to capitalize on the highly disruptive migration the Investment Adviser believes is about to occur, from existing ledger systems and communication channels that rely on centralized third-party trust, to blockchain technology that will allow peer-to-peer (enterprises and individuals) connection across myriad industries and geographies to directly transfer information and value. The Venture Funds generally plan to lead seed and Series A deals, taking board seats where appropriate. The Investment Adviser expects to have access to superior deal flow, by virtue of its active presence in the blockchain industry. The Venture Funds will seek to build a diversified portfolio to balance risk. Certain Venture Funds may, from time to time, hold tokens through earlystage token offerings (“Early-Stage Token Offerings”) that potentially convert into equity where the applicable Venture Fund invests in the underlying issuing company. Such Venture Funds will also be open to ancillary spaces, such as fintech, artificial intelligence, and machine learning. (b) Early-Stage Token Funds The investment objective of the Early-Stage Token Funds is to achieve capital appreciation and maximize absolute returns by participating in early-stage token opportunities within the blockchain space, with the ultimate goal of holding Liquid Tokens (defined below) resulting from such opportunities. The Early-Stage Token Funds seek to secure Liquid Tokens and access to Liquid Tokens using a wide variety of means and arrangements. In prior years, early-stage token opportunities arose primarily from new tokens, blockchain protocols or related services, financed and launched through Early-Stage Token Offerings of digital assets, virtual currencies, cryptocurrencies and/or other coins and tokens expected to have acceptable liquidity characteristics (collectively “Liquid Tokens”). Today, as the landscape for early-stage token opportunities is evolving, the Investment Adviser is adapting to market practices and novel ways of obtaining Liquid Tokens and the rights to Liquid Tokens, including in connection with or through preferred equity stakes in portfolio companies, Simple Agreements for Future Equity (“SAFEs”), warrants for tokens and purchase agreements for existing Liquid Tokens. (c) Early-Stage Token Offshore Funds The investment objective of the Early-Stage Token Offshore Funds is to achieve capital appreciation and maximize absolute returns by participating in Early-Stage Token Offerings of Liquid Tokens. The Investment Adviser will rely on various approaches to obtaining Liquid Tokens and the rights to Liquid Tokens, including in connection with or through preferred equity stakes in portfolio companies, SAFEs, warrants for tokens and purchase agreements for existing Liquid Tokens. The Early-Stage Token Offshore Funds generally intend to hold each investment for longterm appreciation over a period of not less than 12 months.

(d) Bitcoin Funds The investment objective of the Bitcoin Funds is to invest substantially all of its assets in Bitcoin. The Investment Adviser will only cause the Bitcoin Funds to sell Bitcoin to fund redemptions and pay expenses and liabilities. The Bitcoin Funds will not trade, buy, sell or hold Bitcoin derivatives for any purpose. Transactions in Bitcoin will not be made on a leveraged, margined, or offerfinanced basis. The Bitcoin Funds may engage in Bitcoin lending transactions, in the sole discretion of the Filing Adviser. (e) Liquid Token Funds The investment objective of the Liquid Token Funds is to achieve capital appreciation and maximize absolute returns by investing in a diversified portfolio consisting primarily of liquid digital assets, liquid virtual currencies, cryptocurrencies and/or other liquid coins and tokens. The Liquid Token Fund may also invest in related equity assets that exhibit strong market acceptance and liquidity. The Liquid Token Fund does not (i) expect to participate in Early-Stage Token Offerings, (ii) intend to invest in assets that have limited liquidity or (iii) intend to invest extensively (and in no instance over 40%, measured at the time of investment, of the Liquid Token Fund’s investments) in assets that have been determined to be securities for purposes of U.S. laws and regulations. (f) Blockchain Funds and Blockchain Venture Fund The investment objective of the Blockchain Funds is to offer investors the opportunity to make a single allocation and receive professionally-managed exposure to multiple facets of the emerging blockchain and cryptocurrency markets. The Blockchain Funds will invest in (i) venture capital investments in blockchain assets (including Early-Stage Token Offerings that are not Digital Assets) (collectively, “Blockchain Venture Assets”) and (ii) Digital Assets. The investment objective of the Blockchain Venture Fund is substantially similar to the investment objective of a certain class of interests of the Blockchain Fund. Additionally, the Fund V Master Fund and Fund V Offshore Fund will invest in special opportunities (“Special Opportunity Investments”) consisting of investments outside of the typical scope of Blockchain Venture Assets, Early-Stage Token Offerings, and liquid Digital Assets. These investment opportunities may include, and are not limited to, acquiring assets out of distressed companies or bankruptcy estates, direct investments in primary and secondary issuances of widely traded Digital Assets with lockup provisions, onchain participation related to blockchain-related businesses and blockchain-enabled protocols, equity and/or debt investments in blockchain-related or Digital Asset-related companies, including private and public companies that establish digital asset treasury portfolios, and any other investments that the Investment Adviser determines do not qualify as Blockchain Venture Assets. (g) Solana Funds The Investment Adviser causes the Solana Funds to invest substantially all of their assets in Solana, cryptographic blockchain tokens with the ticker symbol SOL (“SOL”), purchased from the bankruptcy estate of FTX Trading Ltd. (“FTX”) (such SOL purchased by the Solana Funds, the “Purchased SOL” and the SOL being sold by the FTX estate, the “FTX SOL”). The Solana Funds purchased the FTX SOL at a discounted price and subject to lock-up periods in accordance with the terms of a purchase agreement (the “Purchase Agreement”) entered into by, among others, the Solana Funds, the FTX estate and a certain broker on behalf of the FTX estate (the “Broker”). The FTX SOL was sold in blocks (each, an “SOL Block”) at a purchase price of $25 million per SOL

Block, or such other amount as determined by the Broker (such amount, the “SOL Block Threshold Amount”). The Solana Funds hold Purchased SOL under the terms of the Purchase Agreement in accordance with the lock-up period and vesting schedule applicable to each SOL Block and may sell such Purchased SOL following the end of such period. (h) Token-25 Funds The investment objective of the Token-25 Funds is to track the performance of the 25 largest Liquid Tokens. The components of the Token-25 Master Fund’s portfolio will be weighted based on their respective market capitalizations. Portfolio composition and rebalancing decisions driven by market capitalization determinations will be made in accordance with the Investment Adviser’s internal policies, as may be amended from time to time. The Investment Adviser may choose not to invest in a Liquid Token that otherwise satisfies the investment criteria if the Investment Adviser believes that such Liquid Token is fraudulent or is otherwise significantly flawed and, in that case, may substitute the Liquid Token with the next largest Liquid Token by market capitalization that the Investment Adviser believes does not possess these flaws or may reduce the number of Liquid Tokens held in the portfolio. (i) Beta Bridge Funds The investment objective of the Beta Bridge Funds is substantially similar to the investment objective of the Token-25 Funds. To effectuate the investment objective of the Beta Bridge Funds, the Beta Bridge Funds invest all of its investable assets in the Token-25 Master Fund. An investor’s capital contribution to the Beta Bridge Funds constitutes an irrevocable capital commitment to the Fund V Offshore Fund and the Fund V Master Fund . The amount of such Fund V Offshore Fund and Fund V Master Fund’s capital commitment shall be equal to the net asset value of an investor’s interests in the Beta Bridge Funds as of the date of the initial closing of the Fund V Offshore Fund and the Fund V Master Fund (or the Fund V Offshore Fund and the Fund V Master Fund’s closing date after the initial closing of the Fund V Offshore Fund and the Fund V Master Fund); provided that in the event that the net asset value of an investor’s interests in the Beta Bridge Funds as of the date of the initial closing of the Fund V Offshore Fund and the Fund V Master Fund (or the Fund V Offshore Fund and the Fund V Master Fund’s’ closing date after the initial closing of the Fund V Offshore Fund and the Fund V Master Fund) is greater than the amount of their aggregate capital contributions to the Beta Bridge Funds, such investor may elect to reduce their Fund V Offshore Fund and the Fund V Master Fund’ capital commitment to an amount no lower than their aggregate capital contributions to the Beta Bridge Funds. (j) TON Funds The Investment Adviser causes the TON Funds to invest substantially all of their assets in the purchase of Toncoin, cryptographic blockchain tokens with the ticker symbol TON (“TON”) of The Open Network, from either Telegram or certain miners, (such TON purchased by the TON Funds, the “Purchased TON”). The TON Funds purchased the TON at a discounted price and subject to lock-up periods in accordance with the terms of a purchase agreement (the “TON Purchase Agreement”) entered into by, among others, the TON Funds, a counterparty and a certain broker on behalf of the counterparty. The TON Funds hold Purchased TON under the terms of the TON Purchase Agreement in

accordance with the lock-up period and the applicable vesting schedule and intends to stake its locked Purchased TON to generate yield. Once Purchased TON becomes unlocked and freely tradeable in accordance with the terms of the TON Purchase Agreement (“Unlocked Purchased TON”), the TON Funds may sell such Unlocked Purchased TON at such times as the Fund General Partner determines, including to satisfy withdrawals, or may otherwise continue to stake such Unlocked Purchased TON. (k) WLD Funds The Investment Adviser causes the WLD Funds to invest substantially all of their assets in the purchase of Worldcoin, cryptographic blockchain tokens with the ticker symbol WLD (“WLD”), from the bankruptcy estate of FTX Trading Ltd. (“FTX”) (such WLD purchased by the WLD Funds, the “Purchased WLD” and the WLD being sold by the FTX estate, the “FTX WLD”). The WLD Funds purchased the FTX WLD at a discounted price and subject to lock-up periods in accordance with the terms of a purchase agreement (the “WLD Purchase Agreement”) entered into by, among others, the WLD Funds, the FTX estate and a certain broker on behalf of the FTX estate (the “Broker”). The FTX WLD was sold in blocks (each, a “WLD Block”) at a purchase price of $2.5 million per WLD Block, or such other amount as determined by the Broker (such amount, the “WLD Block Threshold Amount”). The WLD Funds hold Purchased WLD under the terms of the WLD Purchase Agreement in accordance with the lock-up period and vesting schedule applicable to each WLD Block and intends to stake its locked Purchased WLD to generate yield. Once Purchased WLD becomes unlocked and freely tradeable in accordance with the terms of the WLD Purchase Agreement (“Unlocked Purchased WLD”), the WLD Funds may sell such Unlocked Purchased WLD at such times as the Fund General Partner determines, including to satisfy withdrawals, or may otherwise continue to stake such Unlocked Purchased WLD. (l) DAT Funds The Investment Adviser causes the DAT Funds to invest substantially all of their assets into Digital Assets Treasury (“DAT”) companies. DAT companies are companies that integrate Digital Assets into their corporate treasury strategies to diversify holdings and potentially enhance returns beyond traditional cash reserves. By using proceeds from equity and debt financings, as well as cash flows from traditional operations, DAT companies strategically accumulate Digital Assets. Investments in DAT companies are expected to provide a range of economic exposure to Digital Assets through the DAT Funds’ acquisition of DAT company securities, including equity and fixed-income instruments. Investments in DAT companies offer the potential to achieve greater value than direct investments in Digital Assets when the stock price of a DAT company is higher than what the mark-to-market value of its portfolio would suggest, but carry the risk of stock values that are lower than the mark-to-market value of such portfolio. The descriptions set forth in this Brochure of specific advisory services that we offer to our clients, and investment strategies pursued and investments made by us on behalf of our clients, should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate, subject to each client’s investment objectives and guidelines. The investment strategies we pursue are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any client will be achieved. (m) Other Clients

The Investment Adviser. provides investment management services to clients other than the Funds, including, without limitation, investment funds, separately managed accounts, proprietary accounts and other investment vehicles (collectively, “Other Clients”). For example, the Investment Adviser serves as investment manager with discretionary authority with respect to a separately managed account that is beneficially owned by a private fund sponsored by a third-party. The investment strategies applicable to Other Clients are detailed in those clients’ governing documents. C. Availability of Customized Services for Individual Clients Our investment decisions and advice with respect to each Fund will be subject to each Fund’s investment objectives and guidelines, as set forth in its respective offering documents. D. Wrap Fee Programs We do not currently participate in any Wrap Fee Programs. E. Assets Under Management We manage, on a discretionary basis, approximately 3,961,135,217 of client assets, determined as of December 31, 2025, calculated on the basis of regulatory assets under management. We do not manage any assets on a non-discretionary basis.

(b) Carried Interest Generally, net proceeds of the investments of the Venture Funds will be distributed to the investors upon realization. The Fund General Partner is entitled to carried interest as follows (for certain Venture Funds the terms of the accrual of carried interest, including the distribution percentages listed below, may vary for certain investment classes). For the Venture Funds, the carried interest generally equals ten to twenty percent (10-20%) until such investor in the Venture II Fund, Venture III A Fund, or Venture III Fund receive aggregate distributions sufficient to provide it with a forty percent (40%) internal rate of return on its capital contributions. Thereafter the carried interest will equal 30% for the Venture II Fund, Venture III A Fund, and Venture III Fund. In the sole discretion of the applicable Fund General Partner, the carried interest may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviserrelated investor.

2. The Early-Stage Token Funds (a) Management Fee Generally, the Early-Stage Token Funds pays the Investment Adviser a Management Fee for each fiscal quarter equal to .75% (3% per annum) of the beginning balance of each capital account of an investor for such fiscal quarter. The Management Fee is calculated and paid in advance but is amortized monthly by the Early-Stage Token Funds over the quarter for which such Management Fee is paid. The Management Fee will be prorated for any capital contribution or withdrawal by an investor that is effective other than as of the first day of a quarter. In the event of a withdrawal by an investor other than as of the last day of a quarter, the Investment Adviser will pay to the applicable Fund an amount equal to the pro rata portion of the Management Fee, based on the actual number of days remaining in such quarter, and the applicable Fund will distribute such amount to the withdrawing investor. In the sole discretion of the Fund General Partner, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any

Investment Adviser-related investor. The Fund General Partner’s capital account will not be debited with any Management Fee. (b) Incentive Allocation Generally, at the end of each fiscal year of the Early-Stage Token Funds, the Liquid and EarlyStage Token General Partner is entitled to an incentive allocation of an amount equaling 30% of the net capital appreciation (which includes both realized gains and losses and unrealized appreciation and depreciation of securities held in the applicable Fund’s portfolio) allocated to an investor’s capital account for such fiscal year after deducting the Management Fee debited to such investor’s capital account for such fiscal year, subject to a loss recovery account mechanism. In the event that an Early-Stage Token Fund is terminated or an investor withdraws other than at the end of a fiscal year, then for purposes of determining the incentive allocation allocable at such time to the Liquid and Early-Stage Token General Partner, net capital appreciation will be determined as if such dates were the end of the fiscal year, subject to certain adjustments. In the sole discretion of the Liquid and Early-Stage Token General Partner, the incentive allocation may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser- related investor.

3. The Early-Stage Token Offshore Funds (a) Management Fee Generally, Pantera Early-Stage Token Fund Ltd pays the Investment Adviser a Management Fee for each fiscal quarter equal to .75% (3% per annum) of the gross asset value of each series of shares as of the beginning of such fiscal quarter. The Management Fee is calculated and paid in advance but is amortized monthly by the Pantera Early-Stage Token Offshore Fund Ltd over the quarter for which such Management Fee is paid. The Management Fee will be prorated for any subscription or redemption by an investor that is effective other than as of the first day of a quarter. In the event of a redemption by an investor other than as of the last day of a quarter, the Investment Adviser will pay to the Early-Stage Token Offshore Fund Ltd (or the Pantera Early-Stage Token Master Fund LP) an amount equal to the pro rata portion of the Management Fee, based on the actual number of days remaining in such quarter, and the Early-Stage Token Offshore Fund will distribute such amount to the redeeming investor. In the sole discretion of the Investment Adviser, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. (b) Incentive Allocation Generally, at the end of the 12-month period ending on June 30, Early-Stage Offshore Incentive Allocation Year of the Early-Stage Token Master Fund, the Liquid and Early-Stage Token General Partner is entitled to an incentive allocation of an amount equaling 30% of the net realized and unrealized appreciation in the net asset value of each series of shares, adjusted for any redemption of shares in the series made during the year and any accruals of the incentive allocation and subject to a loss recovery account mechanism. In the event that shares are redeemed other than at the end of a fiscal year, the incentive allocation

will be determined solely with respect to the shares so redeemed as of the redemption date. In the sole discretion of the Liquid and Early-Stage Token General Partner, the incentive allocation may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor.

4. The Bitcoin Funds (a) Management Fee Generally, the Bitcoin Funds pays the Filing Adviser a Management Fee for each month equal to the aggregate of a daily accrual equal to 0.00205% (0.75% per annum) of the net asset value of each series of shares of the fee-paying class (before taking into account any investor-related taxes that are accrued but not yet paid as of the applicable calculation date) calculated as of the beginning of each day (including, for the avoidance of doubt, non-business days). Certain share classes are not subject to the Management Fee. Payment of the Management Fee will be made upon redemption or within 10 days of the last day of each month. In the sole discretion of the Investment Adviser, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. (b) Realization Fee Generally, amounts distributed to investors in the Bitcoin Funds upon redemption (whether voluntary or compulsory), other than upon dissolution of the Bitcoin Funds, will be reduced by a realization fee (“Realization Fee”) equal to 1.0%. Certain share classes are not subject to a Realization Fee. The Filing Adviser may, in its sole discretion, reduce or waive the Realization Fee with respect to any investor or share class, including, without limitation, any Investment Adviserrelated investor. The Realization Fee may be paid in Bitcoin or in its cash equivalent.

5. The Liquid Token Funds (a) Management Fee Generally, the Liquid Token Funds pay the Investment Adviser a Management Fee for each fiscal quarter equal to .5% (2% per annum) of the beginning balance of each capital account of an investor for such fiscal quarter. The Management Fee is calculated and paid in advance but is amortized monthly by the Liquid Token Funds over the quarter for which such Management Fee is paid. The Management Fee will be prorated for any capital contribution or withdrawal by an investor that is effective other than as of the first day of a quarter. In the event of a withdrawal by an investor other than as of the last day of a quarter, the Investment Adviser will pay to the applicable Fund an amount equal to the pro rata portion of the Management Fee, based on the actual number of days remaining in such quarter, and the applicable Fund will distribute such amount to the withdrawing investor. In the sole discretion of the Liquid and Early-Stage Token General Partner, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. The Liquid and Early-Stage Token General Partner’s capital account will not be debited with any Management Fee. (b) Incentive Allocation Generally, at the end of each fiscal year of each Liquid Token Fund, the Liquid and Early-Stage

Token General Partner is entitled to an incentive allocation of an amount equaling 20% of the net capital appreciation (which includes both realized gains and losses and unrealized appreciation and depreciation of securities held in the applicable Fund’s portfolio) allocated to an investor’s capital account for such fiscal year or March 31, (the “LTF Incentive Allocation Year”) after deducting the Management Fee debited to such investor’s capital account for such fiscal year, subject to a loss carryforward mechanism. In the event that the Liquid Token Funds are terminated or an investor withdraws other than at the end of a fiscal year, then for purposes of determining the incentive allocation allocable at such time to the Liquid and Early-Stage Token General Partner, net capital appreciation will be determined as if such dates were the end of the LTF Incentive Allocation Year, subject to certain adjustments. In the sole discretion of the Liquid and Early-Stage Token General Partner, the incentive allocation may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. Fees and compensation paid to the Investment Adviser or its affiliates by the Funds are generally deducted from the assets of such clients. As discussed above, Management Fees are generally deducted on a quarterly basis and performance compensation is generally deducted on an annual basis.

6. The Blockchain Funds (a) Management Fee Generally, the Blockchain Funds pay the Investment Adviser a Management Fee for each fiscal quarter (or, in the case of the Fund V Master Fund and Fund V Offshore Fund, each calendar quarter) ranging from .25%- .5% (1% - 2% per annum) of the aggregate capital commitments of certain investors for such fiscal quarter. The Management Fee is calculated and paid in advance but is amortized monthly by the Blockchain Funds over the quarter for which such Management Fee is paid. In the sole discretion of the Investment Adviser, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. The Blockchain General Partner’s capital account will not be debited with any Management Fee. The Blockchain Funds will be responsible for all expenses incurred in organizing the Blockchain Funds up to an operational expense cap, as described in the Blockchain Funds’ governing documents. Any amounts incurred by the Blockchain Funds in excess of such expense cap shall reduce the Management Fee of Management Fee-paying investors pro rata to their capital commitments. (b) Carried Interest Generally, net proceeds of the investments of the Blockchain Funds will be distributed to the investors upon realization. The applicable general partner is generally entitled to carried interest from certain investors in the Blockchain Funds as follows. First, one hundred percent (100%) of the capital invested shall be returned to the investor, after which eighty percent (80%) will be distributed to such investor and twenty percent (20%) will be distributed to the applicable general partner, until such investor has received aggregate distributions sufficient to provide it with a forty percent (40%) internal rate of return on its capital contributions (or in the case of the Fund V

Offshore Fund and Fund V Master Fund, until such investor has received aggregate distributions equal to five times (5.0x) multiple of such investor’s capital contributions). Thereafter, seventy percent (70%) of the remaining proceeds are paid to the investor and thirty percent (30%) are paid to the applicable general partner. In the sole discretion of the applicable general partner, the carried interest may be waived, reduced or calculated differently with respect to certain investors or with respect to certain classes of investors, including, without limitation, any Investment Adviserrelated investor. The Blockchain Fund will make certain investments through the Blockchain Venture Fund, which has fee structures. Where the Blockchain Fund invests through other Funds, such as the Blockchain Venture Fund, fees with respect to such investments will be assessed at the Blockchain Venture Fund level.

7. The Blockchain Venture Fund (a) Management Fee Generally, the Blockchain Venture Fund pays the Investment Adviser a Management Fee for each fiscal quarter at a rate of up to .5% (2% per annum) of the aggregate capital commitments of certain investors for such fiscal quarter. The Management Fee is calculated and paid in advance. In the sole discretion of the applicable Fund General Partner, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. (b) Carried Interest Generally, net proceeds of the investments of the Blockchain Venture Fund will be distributed to the investors upon realization. The Fund General Partner is entitled to carried interest from certain investors in the Blockchain Venture Fund as follows. First, one hundred percent (100%) of the capital invested shall be returned to the investor, after which eighty percent (80%) will be distributed to such investor and twenty percent (20%) will be distributed to the applicable Fund General Partner, until such investor has received aggregate distributions sufficient to provide it with a forty percent (40%) internal rate of return on its capital contributions. Thereafter, seventy percent (70%) of the remaining proceeds are paid to the investor and thirty percent (30%) are paid to the applicable Fund General Partner. In the sole discretion of the applicable Fund General Partner, the carried interest may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor.

8. The Solana Funds (a) Management Fee Generally, until January 31, 2028, the Solana Funds pay the Investment Adviser a Management Fee for each fiscal quarter equal to .1875% (.75% per annum) of the capital commitment of each investor. After January 31, 2028 the Solana Funds will pay the Investment Adviser a Management Fee for each fiscal quarter equal to .1875% (.75% per annum) of the balance of each investor’s capital account (marked to market) as of the beginning of such fiscal quarter. Payment of the Management Fee will be made within the first 10 days of each fiscal quarter (prorated for partial periods). In the sole discretion of the Investment Adviser, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, investors that

are members, directors, shareholders, partners, affiliates or employees of the Fund General Partner, the Investment Adviser, members of the immediate families of such persons and trusts or other entities for their benefit. (b) Carried Interest The Blockchain General Partner is entitled to carried interest as follows. First, one hundred percent (100%) of the capital invested shall be returned to the investor, after which, ninety percent (90%) will be distributed to such investor and ten percent (10%) will be distributed to the Blockchain General Partner.

9. The Token-25 Funds (a) Management Fee Generally, the Token-25 Funds pay the Investment Adviser a Management Fee for each month at a rate of 0.0833% (1% per annum) of the beginning net asset value of each capital account of an investor for such month. The Management Fee is calculated and paid in advance. The Management Fee will be prorated for any capital contribution or withdrawal by an investor that is effective other than as of the first day of a month for any capital contribution and the last day of a month for any withdrawal. In the sole discretion of the applicable Fund General Partner, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor.

10. The Beta Bridge Funds The investors in the Beta Bridge Funds are not subject to a management fee or a performance fee.

11. The TON Funds (a) Management Fee Generally, the TON Funds pay the Investment Adviser a Management Fee for each fiscal quarter at a rate of 0.25% (1% per annum) of the beginning net asset value of each capital account of an investor for such fiscal quarter. The Management Fee is calculated and paid in advance. The Management Fee will be prorated for any capital contribution or withdrawal by an investor that is effective other than as of the first day of a quarter. In the sole discretion of the applicable Fund General Partner, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. (b) Carried Interest The Fund General Partner is entitled to carried interest as follows. First, one hundred percent (100%) of the capital invested shall be returned to the investor, after which, ninety percent (90%) will be distributed to such investor and ten percent (10%) will be distributed to the Fund General Partner.

12. The WLD Funds (a) Management Fee

Generally, the WLD Funds pay the Investment Adviser a Management Fee for each fiscal quarter at a rate of 0.25% (1% per annum) of the beginning net asset value of each capital account of an investor for such fiscal quarter. The Management Fee is calculated and paid in advance. The Management Fee will be prorated for any capital contribution or withdrawal by an investor that is effective other than as of the first day of a quarter. In the sole discretion of the applicable Fund General Partner, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. (b) Carried Interest The Fund General Partner is entitled to carried interest as follows. First, one hundred percent (100%) of the capital invested shall be returned to the investor, after which, ninety percent (90%) will be distributed to such investor and ten percent (10%) will be distributed to the Fund General Partner.

13. The DAT Funds (a) Management Fee The DAT Funds pay a one-time fee at closing to the Investment Adviser equal to 1- 2% of each investor’s total capital contributions. In the sole discretion of the applicable Fund General Partner, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. (b) Carried Interest The Opportunities General Partner is entitled to carried interest as follows. First, one hundred percent (100%) of the capital invested shall be returned to each investor until such investor has received cumulative distributions equal to its unreturned capital contributions, after which eighty percent (80%) will be distributed to such investor and twenty percent 20% will be distributed to the Opportunities General Partner.

14. Other Clients The fees and expenses of Other Clients are detailed in the governing agreements for those clients. B. Additional Fees and Expenses The expenses attributable to each specific client are detailed in each client’s organizational documents. We have set forth below the expenses that each client can generally be expected to bear, however in some instances certain expenses listed below may be borne by, or solely applicable to, certain clients and not others. Each client bears its own expenses, its pro rata share of its “master fund” expenses, and its pro rata share of any trading subsidiary’s expenses, including, without limitation, the following: (i) the Management Fee; (ii) expenses related to the analysis, research, due diligence and monitoring of actual and prospective investments (whether or not consummated) and the consummation of investments; costs incurred in attending seminars and conferences related to digital currencies; costs related to the lending and custody of Bitcoin, SOL, other cryptocurrencies, tokens issued in Early-

Stage Token Offerings, and Digital Assets and other assets (including, but not limited to, third party wallet providers and insurance); fees and expenses related to trading on Liquid Token exchanges and other decentralized exchanges; fees or performance-based compensation paid to third-party advisers; fees and expenses related to obtaining research and market data (including, without limitation, any information technology hardware, software or other technology incorporated into the cost of obtaining such research and market data); due diligence expenses, including, anti-money laundering and digital wallet due diligence costs, sanctions screening fees and consulting fees; costs incurred in attending seminars and conferences related to Digital Assets; costs associated with entering into SAFEs or simple agreements for future tokens (“SAFTs”) and participating in EarlyStage Token Offerings; and expenses relating to short sales of Digital Assets; (iii) organizational and reorganizational expenses; (iv) operational expenses, including, without limitation, the following: fees and expenses relating to information technology hardware, software or other technology (including, without limitation, costs of software licensing, implementation, data management and recovery services and custom development) used to research investments, evaluate and manage risk, facilitate valuations, facilitate accounting functions, facilitate compliance with the rules of any self-regulatory organization or applicable law (including, without limitation, reporting obligations), facilitate and manage the purchase and sale of Digital Assets and other assets or otherwise manage a client or any trading subsidiary, portfolio management systems, risk management systems and order management systems; fees and expenses of third-party risk management products, models and services; third-party administrative fees and expenses; fees and expenses of third- party professionals, including, without limitation, consultants, valuation service providers, attorneys and accountants; the costs of any litigation or investigation involving activities of a client or any trading subsidiary; third-party audit and tax preparation expenses; fees and expenses (including, without limitation, director registration fees) of any client’s or trading subsidiary’s directors; costs of preparing and distributing reports and notices; taxes; expenses incurred in connection with negotiating and complying with provisions of any side letter agreement; fees and expenses related to compliance with the rules of any self-regulatory organization or applicable law in connection with the activities of a client or any trading subsidiary, including, without limitation, any governmental, regulatory, licensing, filing or registration fees or taxes (including, without limitation, filing fees); expenses incurred in connection with the offering and sale of fund interests or shares and other similar expenses related to a client (excluding fees payable to any placement agent); expenses incurred in connection with any outsourcing of the administration of a Fund and expenses associated with annual meetings of a Fund and such Fund’s various committees; extraordinary expenses, including, without limitation, the following: indemnification expenses; fees and expenses incurred in connection with any tax audit by any U.S. federal, state or local authority, including, without limitation, any related administrative settlement and judicial review; and fees and expenses incurred in connection with the reorganization, dissolution, windingup or termination of a client or any trading subsidiary; (v) directors’ and officers’ liability insurance and (vi) “broken deal” expenses. Generally, all expenses borne by a client, other than the Management Fee and any expenses that the applicable Fund General Partner or board of directors determines should be allocated to a particular investor (e.g., investor-related taxes), will be debited or charged against all of the capital accounts or shares on a pro rata basis. To the extent that expenses to be borne by a client are paid by the Fund General Partner or the Investment Adviser, a client will reimburse such party for such expenses. The Investment Adviser may from time to time incur expenses jointly on behalf of the clients (e.g., research). The Investment Adviser will attempt to allocate such expenses on a basis that they consider fair and equitable. In the event that multiple clients participate in an investment, the Investment Adviser will allocate investment-related expenses, including research, among such

entities on a fair and equitable basis, which may be pro rata. The allocation of research costs and other investment-related expenses by the Investment Adviser may be made on an estimated basis (such as based on assumed participation rates in a given transaction) if and when the Investment Adviser believes that is the appropriate method of allocating such expenses. Except for certain clients which have pre-determined limits on organizing expenses, clients do not have a pre-determined limit on their ordinary or extraordinary operating expenses. Clients’ actual annual operating expenses are disclosed in their year-end audited financial statements, which are provided to each investor. C. Additional Compensation and Conflicts of Interest Neither the Investment Adviser nor any of its supervised persons accepts compensation (e.g., brokerage commissions) for the sale of securities or other investment products.

Certain of our Funds have higher fees or more favorable performance-based compensation arrangements than other Funds. Consequently, a conflict of interest exists because we have a greater incentive to favor Funds from which we receive higher fees or performance-based compensation arrangements. Please also see “Item 10: Other Financial Industry Activities and Affiliations” and “Item 12: Brokerage Practices” for more details on conflicts resulting from the management of multiple clients. We have adopted and implemented policies and procedures intended to address these conflicts of interest, including trade allocation and aggregation policies. Our allocation policy seeks to allocate investment opportunities among all clients fairly, to the extent practical and in accordance with each client’s applicable investment strategies, over a period of time. Investment opportunities will generally be allocated among those clients for which participation in the respective opportunity is considered appropriate, taking into account, among other considerations: (i) whether the risk-return profile of the proposed investment is consistent with a client’s objectives; (ii) the potential for the proposed investment to create an imbalance in a client’s portfolio; (iii) the liquidity requirements of a client; (iv) potentially adverse tax consequences; (v) regulatory restrictions that would or could limit a client’s ability to participate in a proposed investment; and (vi) the need to re-size risk in a client’s portfolio. Investments may be allocated among client portfolios, and such allocations will be determined based on the Investment Adviser’s allocation policy.

In this Item 8.A, we have included summaries of each of the investment objectives for the different clients we advise; however, more detailed descriptions of such methods of analysis and investment strategies are incorporated into such clients’ governing agreements. The Early-Stage Token Offshore Funds The investment objective of the Early-Stage Token Offshore Funds is to achieve capital appreciation and maximize absolute returns by participating in early-stage token opportunities within the blockchain space, with the ultimate goal of holding Liquid Tokens resulting from such opportunities. The Early- Stage Token Offshore Funds seek to secure Liquid Tokens and access to Liquid Tokens using a wide variety of means and arrangements. In prior years, early-stage token opportunities arose primarily from new tokens, blockchain protocols or related services, financed and launched through Early-Stage Token Offerings of Liquid Tokens. Today, as the landscape for early-stage token opportunities is evolving, the Investment Adviser is adapting to market practices and novel ways of obtaining Liquid Tokens and the rights to Liquid Tokens, including in connection with or through preferred equity stakes in portfolio companies, SAFEs, warrants for tokens and purchase agreements for existing Liquid Tokens. The Early-Stage Token Offshore Funds generally intend to hold each investment for long-term appreciation over a period of not less than 12 months. The Early-Stage Token Offshore Funds may invest in these and other Liquid Tokens that one or more jurisdictions, including the United States, or governmental authorities or courts within such jurisdictions, may now or in the future consider securities or other regulated products for purposes of their laws and regulations. The Early-Stage Token Funds The investment objective of the Early-Stage Token Funds is to achieve capital appreciation and maximize absolute returns by participating in early-stage token opportunities within the blockchain space, with the ultimate goal of holding Liquid Tokens (defined below) resulting from such opportunities. The Early-Stage Token Funds seek to secure Liquid Tokens and access to Liquid Tokens using a wide variety of means and arrangements. In prior years, early-stage token opportunities arose primarily from new tokens, blockchain protocols or related services, financed and launched through Early-Stage Token Offerings of Liquid Tokens. Today, as the landscape for early-stage token opportunities is evolving, the Investment Adviser is adapting to market practices and novel ways of obtaining Liquid Tokens and the rights to Liquid Tokens, including in connection with or through preferred equity stakes in portfolio companies, SAFEs, warrants for tokens and purchase agreements for existing Liquid Tokens. The Early-Stage Token Funds generally intend to hold each investment for long-term appreciation over a period of not less than 12 months. The Early-Stage Token Funds may invest in these and other Liquid Tokens that one or more

jurisdictions, including the United States, or governmental authorities or courts within such jurisdictions, may now or in the future consider securities or other regulated products for purposes of their laws and regulations. The Liquid Token Funds The investment objective of the Liquid Token Funds is to achieve capital appreciation and maximize absolute returns by investing in a diversified portfolio consisting primarily of Liquid Tokens. The Liquid Token Funds may also invest in related equity assets that exhibit strong market acceptance and liquidity. The Liquid and Early-Stage Token General Partner intends to manage the Liquid Token Funds so that investments in instruments that are securities for purposes of U.S. laws and regulations do not exceed forty percent (40%), measured at the time of investment, of the total value of the portfolio at any time. The Investment Adviser will employ a long-biased approach to capture the potential upside while retaining the flexibility to navigate market fluctuations using futures, options and other derivatives, including for short positions when warranted. The Investment Adviser employs in-depth research and due diligence on blockchain-enabled protocols that utilize Liquid Tokens created, issued, and transmitted using the underlying software. The Investment Adviser conducts fundamental research to ascertain the fair value of certain underlying Liquid Tokens and any associated assets in which the Liquid Token Funds invest. Tactical trading will be utilized to adjust exposure levels in response to perceived divergence from fair value. Moreover, the Investment Adviser may strategically deploy a moderate amount of leverage to enhance returns while maintaining appropriate risk management. The Liquid Token Funds do not (i) expect to participate in Early-Stage Token Offerings, (ii) intend to invest in assets that have limited liquidity or (iii) intend to invest extensively (and in no instance over 40%, measured at the time of investment, of the Liquid Token Master Fund’s investments) in assets that have been determined to be securities for purposes of U.S. laws and regulations. The Venture Funds The Venture Funds primarily invest in businesses that seek to use blockchain technology to disintermediate rent-seeking incumbents and enable peer-to-peer transactions using tokenized assets. The Investment Adviser believes that blockchain applications will disintermediate a myriad of industries. Certain Venture Funds may, from time to time, hold tokens (through Early-Stage Token Offerings) that potentially convert into equity where such Venture Funds invest in the underlying issuing company. Certain Venture Funds will also be open to ancillary spaces, such as fintech, artificial intelligence, and machine learning. Investment Criteria. The Venture Funds generally plan to lead “Seed” and “Series A” deals, taking board seats where appropriate. The Venture Funds will endeavor to leave ample capital for each investment to be in the position to allocate funding to the entire lifecycle of the company, if so determined. Investment Strategy. The Investment Adviser expects to have access to superior deal flow, by virtue of its active presence in the blockchain industry. The Venture Funds will seek to build a diversified portfolio (in terms of number of positions and industries of focus) of blockchain technology-related venture investments to balance risk. The goal will be for the portfolio companies to be complementary and be able to leverage mindshare and assets among one another. The Investment Adviser expects to provide industry-specific value-added resources to the portfolio companies

based on its industry knowledge. The Bitcoin Funds The investment strategy of the Bitcoin Funds is to invest substantially all of its assets in Bitcoin. The Bitcoin Funds will only take immediate delivery of Bitcoin. The Bitcoin Funds will not trade, buy, sell or hold Bitcoin derivatives for any purpose. Transactions in Bitcoin will not be made on a leveraged, margined, or offer-financed basis. Through the investment program, investors in the Bitcoin Funds may indirectly participate in the Bitcoin market without owning or controlling specific Bitcoin. The Bitcoin Funds may engage in Bitcoin lending transactions, in the sole discretion of the Filing Adviser. The Blockchain Funds The Blockchain Funds allocate their capital across Blockchain Venture Assets, Special Opportunity Investments, and Digital Assets. The concentration of Blockchain Venture Assets, Special Opportunity Investments, and Digital Assets in the portfolio will fluctuate over time, and the Blockchain Funds will allocate capital to Blockchain Venture Assets, Special Opportunity Investments, and Digital Assets in such amounts as the applicable general partner determines in its sole discretion. It is anticipated that the Blockchain Funds may initially be invested up to 100% in Digital Assets, which percentage is expected to decline over the Investment Period as capital is drawn down for investment in Blockchain Venture Assets. Blockchain Venture Assets The Blockchain Venture Assets portfolio consists of actively managed early-stage companies building products and services in the nascent blockchain ecosystem. The Investment Adviser expects to use technical capabilities, market leadership, and exclusive deal flow to invest in private companies building out core blockchain infrastructural products and services, and by actively guiding those companies to create successful exits. The Class A Portfolio generally will seek to invest in “Seed”, Series A, and Series B financings in initial investment sizes between $1-50 million, with a proportional amount reserved for follow- on rounds. However, the actual investment strategy used for the Class A portfolio may deviate from this description. Areas of focus for Blockchain Venture Asset investments are: infrastructure, payments, enterprise, media and financial services. Early-Stage Token Offerings The Blockchain Funds invest in new protocols and tokens issued by financing developer teams. New tokens, blockchain protocols and related services are often developed, financed, and launched through an Early-Stage Token Offering. For portfolio construction purposes, the Investment Adviser will consider an offering to be an Early-Stage Token Offering if such offering is not listed on any Digital Asset exchange with a weekly volume above either $21 million per week or $3 million per day. Early- Stage Token Offerings are potentially profitable, but very risky; it takes deep technical and market knowledge to invest successfully in such investments. Once the offering has taken place and after a vesting or lockup period, the Blockchain Funds will seek to sell sufficient tokens earned in the Early- Stage Token Offering to recover its invested cost. A core thesis driving the Investment Adviser’s early- stage token strategy is that DeFi will be a main driver of value. Early-Stage Token Offerings are generally subject to trading restrictions (such as vesting or lockup periods) at the beginning of their lifecycle and, therefore, are illiquid or only thinly traded. EarlyStage Token Offerings become more liquid over time as such trading restrictions expire. The Blockchain Funds generally expect to invest in Early-Stage Token Offerings early in their life cycle

when they are less-liquid and therefore will be considered Blockchain Venture Assets by the applicable general partner. Early-Stage Token Offerings will progress in their lifecycles and become more liquid. Once an Early-Stage Token Offering is listed on any Digital Asset exchange with a weekly volume above either $21 million per week or $3 million per day, the applicable general partner will re-characterize such Early-Stage Token Offering to be a Digital Asset rather than a Blockchain Venture Asset for purposes of determining construction of the Blockchain Funds, including for reinvestment purposes. Digital Assets The Blockchain Funds invest in widely traded Digital Assets such as cryptocurrency coins and “utility tokens” (e.g., Bitcoin, Ethereum) as well as Early-Stage Token Offerings that are listed on any Digital Asset exchange with a weekly volume above either $21 million per week or $3 million per day. The Investment Adviser expects to use technical, market and trading expertise to exploit market inefficiencies in early-stage token projects and in larger-cap publicly traded Digital Assets that span different use cases and functional utility (in the short and medium term). The most widely traded Digital Assets are highly volatile and dominated by retail investor trading. In the short and medium term, the Investment Adviser expects Decentralized Finance (DeFi) to be a central theme driving value in the Digital Asset markets. Blockchain Venture Fund The investment objective of the Blockchain Venture Fund is substantially similar to the investment objective of a certain class of interests of the Blockchain Fund. The governing documents for the Blockchain Venture Fund should be read in conjunction with the governing documents for the Blockchain Fund. The Solana Funds The Investment Adviser causes the Solana Funds to invest substantially all of their assets in Solana purchased from the bankruptcy estate of FTX. The Solana Funds hold Purchased SOL under the terms of the Purchase Agreement in accordance with the lock-up period and vesting schedule applicable to each SOL Block and may sell such Purchased SOL following the end of such period. Token-25 Funds The investment objective of the Token-25 Funds is to track the performance of the 25 largest Liquid Tokens. The components of the Token-25 Master Fund’s portfolio will be weighted based on their respective market capitalizations. Portfolio composition and rebalancing decisions driven by market capitalization determinations will be made in accordance with the Investment Adviser’s internal policies, as may be amended from time to time. The Investment Adviser may choose not to invest in a Liquid Token that otherwise satisfies the investment criteria if the Investment Adviser believes that such Liquid Token is fraudulent or is otherwise significantly flawed and, in that case, may substitute the Liquid Token with the next largest market capitalization the Investment Adviser believes does not possess these flaws or may reduce the number of Liquid Tokens held in the portfolio. Beta Bridge Funds The investment objective of the Beta Bridge Funds is substantially similar to the investment objective of the Token-25 Funds. To effectuate the investment objective of the Beta Bridge Funds, the Beta Bridge Funds invest all of its investable assets in the Token-25 Master Fund. An investor’s capital contribution to the Beta Bridge Funds constitutes an irrevocable capital commitment to the

Fund V Master Fund and Fund V Offshore Fund. The amount of such Fund V Master Fund and Fund V Offshore Fund capital commitment shall be equal to the net asset value of an investor’s interests in the Beta Bridge Funds as of the date of the initial closing of the Fund V Master Fund and Fund V Offshore Fund (or the Fund V Master Fund and Fund V Offshore Fund closing date after the initial closing of Fund V Master Fund and Fund V Offshore Fund); provided that in the event that the net asset value of an investor’s interests in the Beta Bridge Funds as of the date of the initial closing of the Fund V Master Fund and Fund V Offshore Fund (or the Fund V Master Fund and Fund V Offshore Fund closing date after the initial closing of the Fund V Master Fund and Fund V Offshore Fund) is greater than the amount of their aggregate capital contributions to the Beta Bridge Funds, such investor may elect to reduce their Fund V Master Fund and Fund V Offshore Fund capital commitment to an amount no lower than their aggregate capital contributions to the Beta Bridge Funds. TON Funds The Investment Adviser causes the TON Funds to invest substantially all of their assets in Purchased TON. The TON Funds hold Purchased TON under the terms of the TON Purchase Agreement in accordance with the lock-up period and the applicable vesting schedule and intends to stake its locked Purchased TON to generate yield. Once Purchased TON becomes Unlocked Purchased TON, the TON Funds may sell such Unlocked Purchased TON at such times as the Fund General Partner determines, including to satisfy withdrawals, or may otherwise continue to stake such Unlocked Purchased TON. WLD Funds The Investment Adviser causes the WLD Funds to invest substantially all of their assets in the Purchased WLD. The WLD Funds hold Purchased WLD under the terms of the WLD Purchase Agreement in accordance with the lock-up period and vesting schedule applicable to each WLD Block and intends to stake its locked Purchased WLD to generate yield. Once Purchased WLD becomes Unlocked Purchased WLD, the WLD Funds may sell such Unlocked Purchased WLD at such times as the Fund General Partner determines, including to satisfy withdrawals, or may otherwise continue to stake such Unlocked Purchased WLD. DAT Funds The Investment Adviser causes the DAT Funds to invest substantially all of their assets into DAT companies. Investments in DAT companies are expected to provide a range of economic exposure to Digital Assets through the acquisition of DAT company securities, including equity and fixed-income instruments. The term of the portfolio will be two years from inception, unless extended by the Opportunities General Partner, in its sole discretion, for up to two additional six-month periods to provide for the orderly liquidation of the portfolio. B. Material, Significant or Unusual Risks Relating to Investment Strategies The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in clients advised by us. These risk factors include only those risks we believe to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by us. In addition, not all risk factors set forth below apply to each client – some risk factors apply to certain clients and not to others. The risk factors applicable to a specific client are further detailed in that client’s governing documents. Cybersecurity Risk. As part of its business and investment strategy, the Investment Adviser

processes, stores and transmits large amounts of electronic information, including information relating to the transactions of certain clients and personally identifiable information of the investors. Similarly, service providers of the Investment Adviser or a client, especially the Funds’ administrator, may process, store and transmit such information. The Investment Adviser has procedures and systems in place that it believes are reasonably designed to protect such information and prevent data loss and security breaches. However, such measures cannot provide absolute security. The techniques used to obtain unauthorized access to data, disable or degrade service, or sabotage systems change frequently and may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design or manufacture or other problems that could unexpectedly compromise information security. Network connected services provided by third parties to the Investment Adviser may be susceptible to compromise, leading to a breach of the Investment Adviser’s network. The Investment Adviser’s systems or facilities may be susceptible to employee error or malfeasance, government surveillance, or other security threats. On-line services provided by the Investment Adviser to the investors may also be susceptible to compromise. Breach of the Investment Adviser’s information systems may cause information relating to the transactions of a client and personally identifiable information of the investors to be lost or improperly accessed, used or disclosed. The service providers of the Investment Adviser and its clients are subject to the same electronic information security threats as the Investment Adviser. If a service provider fails to adopt or adhere to adequate data security policies, or in the event of a breach of its networks, information relating to the transactions of a client and personally identifiable information of the investors may be lost or improperly accessed, used or disclosed. The loss or improper access, use or disclosure of the Investment Adviser’s or a client’s proprietary information may cause the Investment Adviser or the client 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 events could have a material adverse effect on a client and investments held by such client. Intellectual Property and Licensing Risks. Certain portfolio companies and blockchain protocols in which the Funds invest may depend on proprietary or open-source software, trademarks, or patents. These assets could be challenged by third parties, resulting in costly litigation, injunctions, or loss of rights to use key technology. Even unfounded intellectual property claims may require significant legal expenditures, divert management attention, or delay development of Digital Asset projects. Any adverse determination or settlement could materially reduce the value of the Funds’ investments or limit the use of related technologies. Data Privacy and Cyber-Disclosure Risk. Digital asset projects and service providers engaged by the Funds often operate across multiple jurisdictions and may collect or process personally identifiable information or on-chain data subject to global privacy regimes. Differing legal standards, enforcement practices, and security capabilities across jurisdictions may expose the Funds or their portfolio companies to data breaches, unauthorized disclosures, or regulatory sanctions. In certain regions, even the lawful sharing of user data with regulators or counterparties may create liability, fines, or reputational harm. Artificial Intelligence Risks. Developments in artificial intelligence such as OpenAI, ChatGPT and similar large language models, chatbots, and technologies (collectively, “Artificial Intelligence”) can pose risks to the Investment Adviser, the Funds, and the Funds’ portfolio companies. The Investment Adviser has used and expects to continue to use Artificial Intelligence in various processes, including, without limitation, to assist with certain investment research. The Investment Adviser is also exposed

to the risks of Artificial Intelligence through third parties (including, but not limited to, the Investment Adviser’s or the Funds’ service providers or counterparties) that use Artificial Intelligence, and the Investment Adviser may not always be aware of such use. The Investment Adviser cannot necessarily control the manner in which products created and/or utilized by third parties are developed or maintained. Artificial Intelligence is 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 Artificial Intelligence utilizes or fully to evaluate the source and the reliability of the data being analyzed. Further, the outputs of Artificial Intelligence may be inaccurate or unreliable and are also susceptible to errors in such outputs’ creation or subsequent analysis. Additionally, the use of Artificial Intelligence may involve (a) cybersecurity risks (including, but not limited to, the increased likelihood that the Investment Adviser, the Funds and the Funds’ portfolio companies become a victim of cybercrime), (b) threats to proprietary and confidential information, (c) intellectual property violations, and (d) other risks that are not currently foreseen. Such inaccuracies, errors, risks, threats, and/or violations could have adverse impacts on the Investment Adviser, the Funds, and the Funds’ portfolio companies. Artificial Intelligence continues to develop rapidly, making it difficult to predict the future risks that may arise from such developments. Due to the rapidly evolving nature of Artificial Intelligence and its widespread potential uses, the Investment Adviser expects that its policies and procedures will continue to evolve in response to challenges presented by Artificial Intelligence in a manner reasonably designed to match the Investment Adviser’s use of, and interaction with, such technologies. Fundamental Analysis. Certain trading decisions made by the Investment Adviser may be based on fundamental analysis. Data on which fundamental analysis relies may be inaccurate or may be generally available to other market participants. To the extent that any such data are inaccurate or that other market participants have developed, based on such data, trading strategies similar to certain clients’ trading strategies, the client may not be able to realize its investment goals. In addition, fundamental market information is subject to interpretation. To the extent that the Investment Adviser misinterprets the meaning of certain data, a client may incur losses. General Economic and Market Conditions. The success of certain clients’ investment activities will be affected by general economic and market conditions, such as interest rates, availability of credit, credit defaults, inflation rates, economic uncertainty, changes in laws (including laws relating to taxation of a client’s investments), trade barriers, currency exchange controls, and national and international political circumstances (including wars, terrorist acts or security operations). These factors may affect the level and volatility of the prices and the liquidity of clients’ investments. Volatility or illiquidity could impair clients’ profitability or result in losses. A client may maintain substantial trading positions that can be adversely affected by the level of volatility in the financial markets. Note that certain clients’ Early- Stage Token Offering-focused investment strategies may be uncorrelated to changes in general economic and market conditions. Governmental Interventions. Extreme volatility and illiquidity in markets has in the past led to, and may in the future lead to, extensive governmental interventions in equity, credit and currency markets, and it is possible that similar interventions may occur in the market(s) for Digital Assets. Generally, such interventions are intended to reduce volatility and precipitous drops in value. In certain cases, governments have intervened on an “emergency” basis, suddenly and substantially eliminating market participants’ ability to continue to implement certain strategies or manage the risk of their outstanding positions. In addition, these interventions have typically been unclear in scope and application, resulting in uncertainty. It is impossible to predict when these restrictions will be imposed, what the interim or permanent restrictions will be and/or the effect of such

restrictions on certain clients’ strategies. Long-Term; Short Selling. The success of certain clients’ investment strategies depends upon the Investment Adviser’s ability to identify Digital Assets that will be successful. This is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. If such Digital Assets were to fail or were to diverge further from values expected by the Investment Adviser, the client may incur a loss. In the event of market disruptions, significant losses can be incurred which may force the client to close out one or more positions. Furthermore, the valuation models used to determine whether a position presents an attractive opportunity consistent with the Investment Adviser’s strategy may become outdated and inaccurate as market conditions change. The Investment Adviser may cause certain clients to sell Digital Assets short; such activities may create inherent risks of loss, including the risk of theoretically unlimited loss. Short-Term Market Considerations. The Investment Adviser’s trading decisions may be made on the basis of short-term market considerations, and the portfolio turnover rate could result in significant trading related expenses. Long-Term Appreciation; Holding Period. Subject to certain limited circumstances, certain clients will hold each investment for longer periods of time due to the terms of those clients’ investment strategies (including, in the case of the Early-Stage Offshore Funds, a period of not less than 12 months). Accordingly, a client may be unable to take advantage of short-term market considerations (opportunistically sell investments) and may be forced to hold an investment at times where it would otherwise be advantageous to sell or after the value of such investment is perceived to have peaked. Diversification and Concentration. Certain clients’ investments may become significantly concentrated in a single (or limited number of) Digital Assets. Such limited diversification may result in the concentration of risk, which, in turn, could expose a client to losses disproportionate to market movements in general if there are disproportionately greater adverse price movements with respect to such Digital Assets. Because certain clients have the ability to concentrate their investments by investing up to 15% of their capital in a single portfolio company and an unlimited amount of their assets in a single industry, the overall adverse impact on a client of adverse movements in the value of the securities of a single issuer or industry will be considerably greater than if the client were not permitted to concentrate its investment to such an extent. Risk of Certain Investments. Certain clients may invest in companies that are financially leveraged or troubled or potentially troubled and may be or have recently been involved in restructurings, bankruptcy, reorganization or liquidation. Securities of such companies are likely to be particularly risky investments although they also may offer the potential for correspondingly high returns. As a result, certain clients may lose all or substantially all of its investment in any particular instance. In addition, there is no minimum credit standard which is a prerequisite to certain clients’ investment in any security. Securities in which a client may invest may rank junior to other outstanding securities and obligations of the issuer, all or a significant portion of whose debt securities may be secured by substantially all of the issuer’s assets. Moreover, a client may invest in securities that are not protected by financial covenants or limitations on additional indebtedness. While leverage presents opportunities for increasing a portfolio company’s total return, it has the effect of potentially increasing losses as well. If income and appreciation on investments made with borrowed funds are less than the required interest payments on the borrowings, the value of the portfolio company’s net assets will decrease. Accordingly, any event which adversely affects the value of an investment by a portfolio company would be magnified to the extent a portfolio

company is leveraged. Lack of Liquidity. There is no certainty that there will ever be a public market for the securities of portfolio companies held by certain clients. In addition, practical limitations may restrict the ability of a client to sell or distribute its securities in a portfolio company, such as limitations imposed by co- investors, financial institutions or management. The lack of liquidity of a client’s investments in portfolio companies may preclude or delay any disposition of such investments, or reduce the proceeds that might otherwise be realized from any such disposition. Competition for Investments. Certain clients will be subject to intense competition for investment opportunities with many sources of capital, including other financial buyers and strategic buyers. There can be no assurance that a client will be able to invest its capital on terms favorable to a client or in comparison to its competitors. Need for Follow–On Investments in Portfolio Companies. Certain portfolio companies that a client may invest in may need additional capital. A company’s inability to obtain such capital, whether from certain clients or another source, may have an adverse effect upon such company. Provision of Managerial Assistance; Control Positions. Certain clients, their general partners, the Investment Adviser and/or their respective affiliates may serve on, or designate members to serve on, the supervisory boards or boards of directors of portfolio companies. Serving on such bodies and/or designation of supervisory board members and of directors and other measures contemplated exposes the Fund General Partners, the Investment Advisers and/or their respective affiliates and, ultimately, certain clients to potential liability and exposes the assets of a client to claims by an investment, the portfolio company, its security holders and its creditors. Minority Investments. Certain clients may make minority investments in entities where the client may not be able to protect its investments or to control or influence effectively the business or affairs of such entities. Certain clients may be adversely affected by actions taken by the majority holder(s) of the investments in which it invests. Investments in Private Companies. A client may invest in private companies, including those at an early stage of development, which involves a high degree of business and financial risk. Early-stage companies with little or no operating history may require substantial additional capital to support expansion or to achieve or maintain a competitive position, may produce substantial variations in operating results from period to period or may operate at a loss. Such companies may face intense competition, including competition from companies with greater financial resources, more extensive development, better marketing and service capabilities and a larger number of qualified management and technical personnel. Such risks may adversely affect the performance of such investments and result in substantial losses. Companies whose securities are not publicly traded will generally not be subject to public disclosure and other investor protection requirements applicable to publicly traded securities. Illiquid positions also may be difficult to value and such valuation may require the exercise of substantial discretion by the Investment Adviser. Investments in private companies and other assets and liabilities for which no market prices are available will be carried on the books of a client at fair value (which may be at cost) as reasonably determined by the Investment Adviser in accordance with the Investment Adviser’s valuation policy (the “Valuation Policy”). There is no guarantee that fair value will represent the value that will be realized by a client on the eventual disposition of the investment or that would, in fact, be realized upon an immediate disposition of the investment. Small Companies. Clients will generally make investments in small companies. While smaller

companies generally have potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. Risks Relating to Digital Asset Derivatives Trading. The Funds may invest in Digital Asset derivatives, although the Investment Adviser expects that any such investment is likely to constitute only a limited portion of any given Fund’s portfolio. Digital Asset derivatives, such as futures or options on futures on a Digital Asset, are also a relatively new asset class, and trading in these instruments, like trading in the Digital Assets themselves, carries a high level of risk. Investments in Digital Asset derivatives, like direct investments in Digital Assets, should be considered substantially more speculative and significantly more likely to result in a total loss of capital than many other investments. Lending Digital Assets. The Funds will lend Digital Assets on a collateralized and an uncollateralized basis from their portfolio to creditworthy securities firms, financial institutions and other third-party borrowers (and affiliates of the Funds and/or the Investment Adviser). While such loan is outstanding, the Funds will receive interest on the investment of the collateral or a fee from the borrower. The risks in lending Digital Assets, as with other extensions of secured credit, if any, consist of possible delay in receiving additional collateral, if any, or in recovery of Digital Assets or possible loss of rights in the collateral, if any, should the borrower fail financially. Borrowers engaging in decentralized application (including decentralized exchange) (“DAPP”)-based yieldgenerating activities may be subject to less due diligence than borrowers in traditional borrowing arrangements and may therefore represent an increased risk of default on the borrowed Digital Assets. The Funds will not face such borrowers directly and will instead transact with the DAPP. The Funds are unlikely to be aware of the identity of the borrowers. As such, in the event of default, the Funds will be unable to pursue such borrowers on their own and may have limited or no recourse in the event of a default, particularly if the value of the collateral drops significantly. Furthermore, during the time any Digital Assets are in the possession of such borrower, such Digital Assets may be kept in custody that provides a different level of security than that of the Funds’ custodians. In addition, Digital Assets lending may be treated for U.S. federal income tax purposes as a sale of the lent Digital Assets, which would cause the Funds to recognize any built-in gain or loss in such Digital Assets. The prices of Digital Assets can be extremely volatile, and the value of collateral pledged by a borrower may decrease, resulting in the borrower’s loan being under-collateralized. If the value of the collateral decreases and the Funds were forced to liquidate the collateral upon a buyer’s default, there is no assurance that liquidation of any collateralized Digital Assets would satisfy a borrower’s obligations under the applicable loan. Although borrowers on most DAPPs are required to “overcollateralize” (i.e., post collateral valued greater than the value of the loan (typically greater than 150%)), the frequent and rapid volatility of Digital Assets may result in a situation where the value of the collateral that a borrower posted falls so rapidly that despite algorithmic liquidation triggers there is insufficient collateral value left over to repay the loan. Decentralized Finance and Decentralized Application Risks. Decentralized finance (“DeFi”) investments are generally offered through DAPPs and smart contracts without the oversight or control of a centralized party. DeFi projects are generally built upon existing decentralized blockchains, such as the Ethereum blockchain, and others. The DeFi industry is relatively new and rapidly growing. Consequently, the industry is currently subject to scrutiny by the government and other regulatory bodies. The legal status of DAPPs has not yet been determined, as multiple federal and state authorities have jurisdiction over aspects of DeFi, including the Department of Justice,

FinCEN, the Service, the CFTC and the SEC, and the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), depending upon the services offered by and provided through the DAPP. For example, to the extent the DAPP enables participants to engage in regulated money transmission services, the DAPP, or its owners or operators (which in the case of DeFi or DAPPs may be determined by those persons with significant ownership of Digital Assets on the DAPP, with the ability to control the protocol used by the DAPP, or that are profiting from the DAPP) would be required to register with FinCEN as a money services business. Similarly, to the extent that the DAPP enables purchase or sale of securities the DAPP may be required to register with the SEC. Given the evolving nature of the DeFi industry, there is no guarantee that legal, tax, or regulatory changes that materially affect the DeFi industry and Funds’ investment strategies will not occur. Further, failure by these DAPPs to comply with all applicable current and future laws may adversely affect their ability to operate and, consequently, the Funds and their investments. The decentralized nature of a DAPP also presents compliance risk to participants, including the Funds. DAPPs that allow anonymous peer-to-peer exchange of digital assets without the use of an intermediary are particularly vulnerable to financial crime and can be used by persons that have been designated as prohibited under applicable sanctions laws. Unlike centralized cryptocurrency exchanges and other financial institutions which are required to adopt and implement anti-money laundering (“AML”) controls, such as customer identity verification and suspicious activity reporting, and conduct sanctions screening to ensure compliance with sanctions laws, DAPPs, by design, lack a centralized governing body. This makes the implementation of any AML controls or sanctions compliance measures challenging because there is no governing body requiring the implementation of such controls and any party with an internet connection can participate in the DAPP. It is possible, if not likely, that few, if any, DAPPs currently conduct identity verification of participants, such as know-your-customer (“KYC”) due diligence, or sanctions screening to assess whether participants are listed on various sanctions lists or located in a country or territory subject to comprehensive sanctions (e.g., Cuba, Iran, North Korea and the Crimea, Donetsk and Luhansk regions of the Ukraine). Accordingly, persons that engage with DAPPs may be doing so at considerable risk, as such persons have either direct or indirect exposure to every other participant swapping or staking digital assets via the DAPP, including any bad actors that may be involved. Because participants in a DAPP cannot select their counterparty within the DAPP, participants run the risk of engaging in financial transactions with persons engaged in criminal conduct or that are persons prohibited under applicable sanctions laws. Accordingly, this lack of transparency increases the risk that the Funds may be deemed to have transacted with criminals and/or persons that are operationally based or domiciled in a country or territory subject to comprehensive sanctions that have been issued by the United States, United Nations, the European Union, the United Kingdom or the Cayman Islands or a person or wallet address listed on a sanctions list administered by the OFAC or any other similar economic and trade sanctions program (collectively, “Prohibited Persons”), potentially exposing the Funds and/or the Investment Adviser to violations of law, including anti-money laundering and/or sanctions laws. The Funds intend to take certain measures to mitigate the risk of dealing with Prohibited Persons. However, particularly given the challenges in conducting due diligence on DAPPs participants, there can be no assurance that such measures will prove effective. To the extent a DAPP, a DAPP owner, operator or participant, or a digital wallet associated with the DAPP, is a Prohibited Person, the Funds may be unable to have dealings with the DAPP, or required to cease any further dealings with the DAPP, until such sanctions are lifted or a license is sought under applicable law to continue dealings, and such that the Funds may not be able to fulfill their investment objectives. For these and other reasons specific to the decentralized finance industry, investments through DAPPs, particularly those that operate using blockchain technology, pose greater risks than investments

made in other sectors. Leverage. If utilized, leverage will subject certain clients or their investments to risks normally associated with debt financing, including the risk that cash flow will be insufficient to meet required payments of principal and interest, the risk that indebtedness on the investments will not be able to be refinanced or the risk that the terms of such refinancing will not be as favorable as the terms of the existing indebtedness. While leverage may enhance total returns to the investors, if investment results fail to cover borrowing costs, returns to the investors will be lower than if there had been no borrowings. Price volatility. A principal risk in trading or transacting in Digital Assets is the rapid fluctuation of market price. High price volatility undermines Digital Assets’ role as a medium of exchange as consumers or retailers are much less likely to accept them as a form of payment. The value of client portfolios relates directly to the value of the Digital Assets held in the client portfolio and fluctuations in the price of Digital Assets could adversely affect the net asset value of a client’s portfolio. There is no guarantee that a client will be able to achieve a better than average market price for Digital Assets or will purchase Digital Assets at the most favorable price available. The price of Digital Assets achieved by a client may be affected generally by a wide variety of complex and difficult to predict factors such as Digital Asset supply and demand; rewards and transaction fees for the recording of transactions on the blockchain; availability and access to Digital Asset service providers (such as payment processors), exchanges, miners or other Digital Asset users and market participants; perceived or actual Digital Asset network or Digital Asset security vulnerability; inflation levels; fiscal policy; interest rates; and political, natural and economic events. To the extent the public demand for Digital Assets were to decrease, or certain clients were unable to find a willing buyer, the price of Digital Assets could fluctuate rapidly and a client may be unable to sell the Digital Assets in its possession or custody. Fund investors will be subject to the risk of price fluctuations of Digital Assets until they fully withdraw/ redeem from a Fund. In 2022, the price of Digital Assets experienced significant volatility and declines–failure to recover to previous levels could materially impact the success of the clients’ investment strategies. Further, if the supply of Digital Assets available to the public were to increase or decrease suddenly due to, for example, a change in a Digital Asset’s source code, the dissolution of a Digital Asset or digital currency exchange, or seizure of Digital Assets by government authorities, the price of Digital Assets could fluctuate rapidly. Such changes in price, demand and supply of Digital Assets could adversely affect an investment in a client. In addition, governments may intervene, directly and by regulation, in the Digital Asset market, with the specific effect, or intention, of influencing Digital Asset prices and valuation (e.g., releasing previously seized Digital Assets). Similarly, any government action or regulation may indirectly affect the Digital Asset market or Digital Asset network, influencing Digital Asset use or prices. To the extent a Digital Asset is used in an in-protocol utility mechanism in such a way as to incur a “slashing condition” (i.e. to violate a rule of protocol inaction or misaction) some or all of that Digital Asset may be destroyed. Certain clients will compete with direct investments in Digital Assets and other potential financial vehicles backed or linked to Digital Assets. Any change in market and financial conditions, or other conditions beyond a client’s control, may make investment and speculation in Digital Assets more attractive, which could limit the supply of Digital Assets and increase or decrease liquidity. Performance of Digital Assets. In the event the types of Digital Assets held by certain clients perform less well than competing Digital Assets, such Digital Assets held by a client may be

devalued or fall into disuse, adversely affecting the client. Stablecoin Risks. The term “stablecoin” refers to a Digital Asset with a value that is pegged to a reference asset, such as the U.S. Dollar. In some cases, the value of the stablecoin is determined by reference to assets backing the stablecoin and, in other cases, the value is determined by a pricing methodology that is used to maintain the price of the stablecoin. Historically, the stablecoin market operated in a largely unregulated environment, relying on self-attestation and voluntary disclosure by issuers regarding reserve assets. The absence of a unified regulatory framework created significant uncertainty about issuers’ solvency, the quality of reserve backing, and redemption practices. This lack of oversight was highlighted by several high-profile events in which stablecoins temporarily or permanently lost their peg, raising concerns about market contagion and systemic risk. On July 18, 2025, the Guaranteeing Essential Non-Interest-bearing Instrument Utility and Stability Act of 2025 (the “GENIUS Act”) became law in the United States, which established a comprehensive federal framework for payment stablecoin issuers. Under the GENIUS Act, only “permitted payment stablecoin issuers” may issue stablecoins in or from the U.S. Such issuers must: (i) Maintain one-to-one reserves backing all issued stablecoins in permitted reserve assets, such as U.S. dollars, Treasury bills, government money market funds, or certain fully collateralized repurchase agreements; (ii) Segregate and custody reserves with qualified U.S. financial institutions; (iii) Publish periodic reserve reports and undergo independent audits at least annually; and (iv) Obtain federal or state licensing (for domestic issuers) or meet comparable regulatory standards (for foreign issuers operating in the U.S.). These requirements introduced new operational, legal, and compliance burdens. Issuers that fail to meet these standards may face enforcement actions or restrictions, which could impair the liquidity or redemption value of affected stablecoins. Fiat-pegged stablecoins therefore remain subject to both the volatility of the underlying fiat currency and the regulatory, operational, and counterparty risks associated with their issuers. The Funds may hold Digital Assets in the form of fiat-pegged stablecoins where the issuer may not retain sufficient reserves, face operational challenges, or become subject to heightened scrutiny or enforcement under the GENIUS Act. Such stablecoins remain dependent on banking infrastructure and government policy and may be affected by geopolitical or economic conditions that could adversely impact their value. Moreover, there is no guarantee that the value of a given stablecoin will not fluctuate and become unpegged to its reference asset. There is a risk that the Fund will suffer significant losses in the event that a stablecoin held by the Fund decreases in value relative to its reference asset. Stablecoins are distinct from other Digital Assets in that their value is backed by the value of an underlying asset, such as fiat currency like U.S. dollars, commodities, or other cryptocurrencies. Stablecoins are subject to the same risks as other Digital Assets as set forth herein but are also subject to unique risks. While stablecoins are intended to be less volatile than other Digital Assets, they are inherently subject to the volatility of the underlying assets they are pegged to. Algorithmically-managed stablecoins (“Algorithmic Stablecoins”) pose additional risks by comparison to fiat and Digital Asset -backed stablecoins. Notably, Algorithmic Stablecoins do not typically rely on reserve backing assets or overcollateralization, meaning that Algorithmic Stablecoins are inherently more volatile than stablecoins backed by fiat or traditional commodities, and potentially more volatile than Digital Asset -backed stablecoins given the lack of overcollateralization. Instead, Algorithmic Stablecoins generally rely on two separate Digital Assets —a stablecoin and another Digital Asset which backs the stablecoin—with a smart contract regulating the relationship between the stablecoin and backing Digital Asset. The smart contract that governs the relationship between the two assets is generally programmed to automatically generate more units of a stablecoin, or destroy already existing units of the backing Digital Asset, in response to swings in each Digital Asset’s relative supply and demand. For example,

TerraUSD—an Algorithmic Stablecoin backed by its sister token, LUNA— lost its peg in May 2022 due to market factors outpacing the algorithms ability to burn/mint tokens to maintain stability. As such, the use of Algorithmic Stablecoins may expose the Fund to relatively high- volatility risks by comparison to fiat-based stablecoins and Digital Asset -backed stablecoins. Stablecoin Banking Partners. Certain of the Funds will have exposure to stablecoins that are backed 1:1 by U.S. Dollars. The U.S. Dollars or U.S. Dollar equivalents that provide the backing for the stablecoins are held in trust by third-party banks and custodians. While many stablecoin issuers provide monthly or annual attestations by independent third-party auditors that detail their reserves and banking partners, the value of any given stablecoin is tied to the financial viability of the stablecoin issuers’ banking partners and the U.S. government (in the case of U.S. treasuries). Stablecoin Depegging Risks. Stablecoins may become depegged if the market no longer believes the stablecoin is fully backed. This may happen for a variety of reasons, for example if the assets held by the issuer of the stablecoin were devalued, illiquid or unavailable due to the insolvency or failure of a bank custodian, or due to non-compliance with the GENIUS Act’s reserve and redemption requirements, such stablecoins could “depeg” either temporarily or permanently. In addition, regulatory or legal issues related to the use or issuance of stablecoins could also pose a risk factor for potential depegging of USDC or other U.S. Dollar backed stablecoins. Regulatory or legal developments, including future amendments or stricter interpretations of the GENIUS Act, could also affect issuers’ ability to maintain stability or redemption mechanisms, potentially leading to further market volatility. Smart contract vulnerabilities may expose stablecoins to potential losses or breaches. Regulatory actions or changes, such as those introduced under or triggered by implementation of the GENIUS Act, can materially impact the operation, acceptance, or liquidity of stablecoins. A stablecoin’s stability ultimately depends on market trust, the efficacy of its underlying mechanisms, and continuing compliance with applicable regulatory requirements. Financing Constraints of Underlying Projects. Many issuers operate without minimum capitalization requirements and depend on ongoing fundraising or sales to sustain development. If these issuers fail to raise sufficient funds, lose banking relationships, or are subject to enforcement actions, they may be unable to complete network launches. The Funds may therefore experience delays or total losses on investments linked to such under-capitalized projects. Staking and Validator Operational Risks. The Funds may stake Digital Assets directly or through thirdparty validators to earn network rewards. Staking activities involve operational and protocol-specific risks, including downtime, misconfiguration, or validator misconduct that can result in penalties or “slashing” of staked assets. Traditional staking is locking native blockchain assets to support validation and earn rewards. Non-validation staking refers to depositing or locking assets for yield without directly securing the network, though it’s still colloquially called “staking.” Changes to protocol rules or governance structures may also alter reward rates or lock-up periods, reducing liquidity. Reliance on external staking service providers introduces counterparty and cybersecurity risk that could lead to partial or total loss of staked assets. Networks utilizing proof-of-stake mechanisms may depend on a small number of validators controlling substantial portions of staked assets. Concentration of validator power increases vulnerability to network manipulation, governance capture, or correlated downtime events, which may reduce network security and impair the value of staked holdings. Destruction of Digital Assets. Certain Digital Assets are intended to be controllable only by the possessor of both the unique public and private keys relating to the local or online digital wallet in which such Digital Assets are held. To the extent private keys relating to certain clients’ Digital Asset holdings are lost, destroyed or otherwise compromised, a client may be unable to access the

related Digital Assets and such private keys are not capable of being restored by a Digital Asset network. Any loss of private keys relating to digital wallets used to store the client’s Digital Assets could adversely affect an investment in a client. Further, Digital Assets are typically transferred digitally, through electronic media not controlled or regulated by any entity. To the extent a Digital Asset transfers erroneously to the wrong destination, a client may be unable to recover the Digital Asset or its value. Such loss could adversely affect a client’s investment in such Digital Asset. Irrevocable Digital Asset Transactions Just as the blockchain (or similar technologies) creates a permanent, public record of Digital Asset transactions, it also creates an irrevocable one. Transactions that have been verified, and thus recorded as a block on the blockchain (or similar technologies), generally cannot be undone. Even if the transaction turns out to have been in error, or due to theft of a user’s Digital Assets, the transaction is not reversible. Certain clients may be unable to replace missing Digital Assets or seek reimbursement for any erroneous transfer or theft of Digital Assets. To the extent that such clients are unable to seek redress for such action, error or theft, such loss could adversely affect an investment in such clients. Under the Investment Adviser’s trade errors policy, in the absence of bad faith, gross negligence, willful misconduct or actual fraud on the Investment Adviser’s part, the clients (and not the Investment Advisers) will benefit from any gains resulting from trade errors and will be responsible for any losses (including additional trading costs) resulting from trade errors and similar human errors. Solana Generally The investment characteristics of virtual Digital Assets generally, and of SOL specifically, differ from those of traditional currencies, commodities or securities. Importantly, SOL is not backed by a central bank or a national, supra-national or quasi-national organization, any hard assets, human capital, or other form of credit. Rather, it is market-based: SOL’s value is determined by (and fluctuates often, according to) supply and demand factors, the number of merchants that accept it, the adoption of smart contracts using the Solana platform, competition from other smart contract platforms and the value that various market participants place on it through their mutual agreement, barter or transactions. Development and Acceptance of Solana As a relatively new product and technology, SOL is not yet widely adopted as a means of payment for goods and services. Banks and other established financial institutions may refuse to process funds for SOL transactions, process wire transfers to or from Solana exchanges, Digital Asset– related companies or service providers, or maintain accounts for persons or entities transacting in Digital Asset. Market capitalization for Digital Asset as a medium of exchange and payment method may always be low. To date, speculators and investors seeking to profit from either short- or longterm holding of SOL drive much of the demand for it, and competitive products may develop which compete for market share. Clients could be adversely impacted if SOL fails to expand into retail and commercial markets and/or if smart contracts using the Solana platform fails to expand. Risks Relating to Solana Price Volatility A principal risk in trading SOL is the rapid fluctuation of its market price. High price volatility undermines Solana’s role as a medium of exchange as retailers are much less likely to accept it as a form of payment. Fluctuations in the price of SOL could adversely affect the net asset value of our clients. There is no guarantee that clients will be able to achieve a better than average market price for Solana or will purchase Solana at the most favorable price available. The price of SOL

achieved by a client may be affected generally by a wide variety of complex and difficult to predict factors such as Solana supply and demand; rewards and transaction fees for the recording of transactions on the blockchain; availability and access to Digital Asset service providers (such as payment processors), exchanges, miners or other Solana users and market participants; perceived or actual Solana network or Solana security vulnerability; inflation levels; fiscal policy; interest rates; and political, natural and economic events. To the extent the public demand for Solana were to decrease, or a client was unable to find a willing buyer, the price of SOL could fluctuate rapidly and a client may be unable to sell the Solana in its possession or custody. Investors with outstanding withdrawal requests will remain subject to the risk of price fluctuations of SOL until they are fully withdrawn from a client. Further, if the supply of SOL available to the public were to increase or decrease suddenly due to, for example, a change in the Solana source code, the dissolution of a Digital Asset exchange, or seizure of Solana by government authorities, the price of SOL could fluctuate rapidly. Such changes in demand and supply of SOL could adversely affect an investment in a client. In addition, governments may intervene, directly and by regulation, in the SOL market, with the specific effect, or intention, of influencing Solana prices and valuation (e.g., releasing previously seized Solana). Similarly, any government action or regulation may indirectly affect the SOL market or Solana network, influencing SOL use or prices. Clients will compete with direct investments in SOL and other potential financial vehicles backed or linked to SOL. Any change in market and financial conditions, or other conditions beyond a client’s control, may make investment and speculation in SOL more attractive, which could limit the supply of SOL and increase or decrease liquidity. Security of Crypto Asset Networks Techniques to secure the blockchains of Digital Asset networks are recent inventions and may fail. For example, the incentives that keep a blockchain decentralized may prove insufficient, thus impacting the value or security of Digital Assets held by certain clients. Exploits in various blockchains may occur which result in losses for certain client portfolios. Third-Party Wallet Providers The Investment Adviser intends to use third-party wallet providers to hold certain clients’ Digital Assets. Clients may have a high concentration of its Digital Assets in one location or with one thirdparty wallet provider, which may be prone to losses arising out of hacking, loss of passwords, compromised access credentials, malware, or cyber-attacks. Clients are not required to maintain a minimum number of wallet providers to hold such clients’ Digital Assets. Clients’ information technology diligence on third-party wallet providers, which includes an annual review of the providers’ System and Organization Controls (“SOC”) reports and an annual re-evaluation of such providers and their information technology systems, may not identify all security vulnerabilities and risks associated with such providers. Certain third-party wallet providers may not indemnify the clients against any losses of Digital Assets. Digital Assets held by third parties could be transferred into “cold storage” or “deep storage,” in which case there could be a delay in retrieving such Digital Assets. The clients may also incur costs related to third party storage. Any security breach, incurred cost or loss of Digital Assets associated with the use of a third-party wallet provider, may adversely affect an investment in the clients. Security. Certain clients may use third party wallet providers to secure client Digital Assets. A client may, however, employ other systems to safeguard Digital Asset holdings, such as “cold storage” or “deep storage”, which may increase the time required to access certain Digital Assets, and may, therefore, delay liquidation of a client’s Digital Assets or payment of withdrawal proceeds, which

could have a material adverse effect on the net asset value of the client. The systems in place to secure the Digital Assets may not prevent the improper access to, or damage or theft of a client’s Digital Assets. Further, a security breach could harm a client’s reputation or result in the loss of some or all of the client’s Digital Assets. Any such security breach or leak of non-public information relating to the security of Digital Assets may adversely affect an investment in the client. Hackers. Hackers or malicious actors may launch attacks to steal, compromise, or secure Digital Assets, such as by attacking Digital Asset network source code, exchange servers, third-party platforms, cold and hot storage locations or software, or Digital Asset transaction history, or by other means. For example, in February 2014, Mt. Gox suspended withdrawals because it discovered hackers were able to obtain control over the exchange’s Bitcoin by changing the unique identification number of a Bitcoin transaction before it was confirmed by the Bitcoin network. Further, Flexcoin, a so-called Bitcoin bank, was hacked in March 2014 when attackers exploited a flaw in the code governing transfers between users by flooding the system with requests before the account balances could update—resulting in the theft of 896 Bitcoin. On February 21, 2025, Bybit, one of the world’s largest cryptocurrency exchanges, suffered an unprecedented cyberattack, resulting in the theft of approximately USD 1.5 billion in Ethereum tokens. As certain clients increase in size, they may become a more appealing target of hackers, malware, cyber-attacks or other security threats. Certain clients will undertake efforts to secure and safeguard the Digital Assets in its custody from theft, loss, damage, destruction, malware, hackers or cyber-attacks, which may add significant expenses to the operation of the client. There can be no assurance that such securities measures will be effective. A client may be unable to replace missing Digital Assets or seek reimbursement for any theft of Digital Assets, adversely affecting an investment in the client. Lack of Transparency. Given the type and extent of the security measures necessary to adequately secure Digital Assets, the investors will not fully know how certain clients store or secure their Digital Assets or the client’s complete holding of Digital Assets at any time. Government or Exchange Sanctions and Resale Restrictions. Digital Assets may be subject to sudden regulatory prohibitions, sanctions, or restrictions on trading, particularly when held through offshore exchanges or intermediaries. The Funds’ ability to sell, transfer, or convert certain assets may be impaired if regulators or exchanges impose blacklisting, delisting, or suspension orders. Resale or secondary trading of tokens originally issued under private placements may remain restricted under U.S. and foreign securities laws, reducing liquidity and potentially causing valuation losses. Banking Relationships. The Investment Adviser and the Funds will hold cash and other assets in accounts with one or more banks, custodians or depository or credit institutions (collectively, “Banking Institutions”), which may include both U.S. and non-U.S. Banking Institutions from time to time. The Funds may also enter into credit facilities and have other relationships with Banking Institutions. The distress, impairment, or failure of, or a lack of investor or customer confidence in, any of such Banking Institutions may limit the ability of each of the Investment Adviser and Funds to access, transfer or otherwise deal with its assets, draw upon a credit facility, or rely upon any of such other relationships, in a timely manner or at all, and may result in other market volatility and disruption, including by affecting other Banking Institutions. All of the foregoing could have a negative impact on the Funds. For example, in such a scenario, the Funds could be forced to delay or forgo an investment or a distribution, including in connection with a withdrawal, or generate cash to fund such investment or distribution from other sources (including by disposing of other investments or making other borrowings) in a manner that it would not have otherwise considered desirable. Furthermore, in the event of the failure of a Banking Institution, access to a depository account with that institution could be restricted and U.S. Federal Deposit Insurance Corporation (“FDIC”) protection may not be available for balances in excess of amounts insured by the FDIC (and similar considerations may apply to Banking Institutions in other

jurisdictions not subject to FDIC protection). In such a case, the Investment Adviser or the Funds may not recover all or a portion of such excess uninsured amounts and could instead have an unsecured or other type of impaired claim against the Banking Institution (alongside other unsecured or impaired creditors). The Investment Adviser does not expect to be in a position to reliably identify in advance all potential solvency or stress concerns with respect to its or the Funds’ banking relationships, and there can be no assurance that the Investment Adviser or the Funds will be able to easily establish alternative relationships with and transfer assets to other Banking Institutions in the event a Banking Institution comes under stress or fails. Reliance on Digital Asset Service Providers. Due to audit and operational needs, there will be individuals who have information regarding certain clients’ security measures. Any of those individuals may purposely or inadvertently leak such information. Further, several companies and/or financial institutions (including banks) may provide support to the client related to the buying, selling, and storing of Digital Assets. To the extent service providers no longer support a client or cannot be replaced, an investment in the client may be adversely affected. In addition, to the extent that a Digital Asset service provider offering due diligence services provides faulty or incomplete information to a client, and the client relies on such faulty or incomplete information to its detriment, an investment in the client may be adversely affected. Network Integrity and Security (Bitcoin and other Digital Assets). The source code used to form the Bitcoin is attributed to “Satoshi Nakamoto”, which is believed to be a pseudonym for a presently unidentified individual or group of individuals, who may be acting alone or in concert with a government, government organization or group with corporate influence. Only the portions of the source code that have been made public have been analyzed with regards to operation, ability to generate Bitcoin, and to conduct transactions in the previously described manner. There may exist an unseen portion of the original code wherein a pre-existing sub-routine and/or virus has been placed which will activate at a future time (determined by the original code writer(s)) causing disruptions to the blockchain and/or resulting in substantial losses, theft of Bitcoin, unauthorized transactions and the issuance of duplicate Bitcoin. Further, since the identity of the original code writer(s) is not known, one cannot discount the possibility of the same unknown individual(s) inserting and/or activating a sub-routine or artifact allowing said person(s) to manipulate a portion of the Bitcoin programming and/or blockchain itself to the benefit of this individual(s) (i.e., by programming a portion of each Bitcoin to transfer to such individual’s Bitcoin wallet). Digital Assets in which certain clients invest may be subject to similar risks. In addition, while the Investment Adviser undertakes every effort to ensure the highest levels of data protection and information assurance internally (using industry-leading best practices for data storage and transmission, the strongest cryptography known and available to the private sector, and stringent internal controls on data and communications), at some points during the act of transferring Digital Assets into or out of a client’s platform (during Download or Upload) the client’s platform requires interfacing with outside entities whose methods, practices and standards may be outside of the client’s control or who may be under the influence of bad actors. Events may occur where corrupted Digital Assets, viruses and/or attachments are introduced into the client’s platform, which could compromise the client’s operation or result in loss of Digital Assets, adversely affecting an investment in the client. There exists the possibility that while acquiring or disposing of Digital Assets, a client will unknowingly engage in transactions with bad actors who are under the scrutiny of government investigative agencies. As such, the client’s systems or a portion thereof may be taken off-line pursuant to legal process such as the service of a search and/or seizure warrant. Such action could

result in the loss of Digital Assets previously under the client’s control. The development team and administrators of a Digital Asset network’s source code could propose amendments to the network’s protocols and software that, if accepted and authorized, or not accepted, by the Digital Asset network community, could adversely affect the supply, security, value, or market share of the Digital Assets, and thus an investment in a client. Further a client may be adversely affected by a manipulation of a Digital Asset source code. Malicious Actor or Botnet. Malware is software used or programmed by malicious actors to disrupt computer operation, gather sensitive information or gain access to private computer systems. “Botnet” refers generally to a group of computers that use malware to compromise computers whose security defenses have been breached. To the extent that a malicious actor, cyber-criminal, computer virus, hacker, or botnet (e.g., Zero Access) obtains a majority of the processing power on a Digital Asset network; alters the source code and blockchain on which all of a Digital Asset’s transactions rely; or prevents the use, transfer, ownership, or integrity of a Digital Asset, investments in certain clients could be adversely affected. Strategy Exceptions and Hardware Errors. The Investment Adviser may develop trading systems for the purpose of pursuing its investment strategy on behalf of certain clients. The development of trading systems is complex and involves financial, economic, econometric and statistical theories, research, and modelling, which are then translated into computer code. In the Investment Adviser’s automated trading environment, clients are at risk of errors of implementation (e.g., “bugs” and classic coding errors), errors of design, and errors resulting from the unexpected interaction of various code modules or systems. These kinds of problems are collectively termed “Strategy Exceptions”. As part of its fiduciary duty, the Investment Adviser tests and evaluates new trading models prior to final production and implementation. Notwithstanding testing, there is always the chance that production models may contain code bugs or incorrect design, which could result in losses for the client. Coding errors and systemic risks from quantitative and algorithmic trading are inherent to the Investment Adviser’s strategies. Similarly, with regard to trading, communication, development, programming, and other systems or equipment that the Investment Adviser operates, utilizes or relies upon, any or all of the following events may occur, even where the Investment Adviser, acting as a fiduciary, takes steps to select secure and satisfactory equipment and service providers: (i) failures of such systems or equipment, (ii) interruptions in access to or the operations of such systems or equipment; (iii) loss of functionality of such systems or equipment; (iv) degradation or corruption of such systems or equipment; (v) compromises in the security or integrity of such systems or equipment; (vi) loss of power to such systems or equipment; and (vii) other situations that adversely affect such systems or equipment, however caused or occurring. These sorts of problems can result in losses for clients and are collectively termed “Hardware Failures”. Legal Claims. To the extent that the creation, use or circulation of Digital Assets, or a Digital Asset network generally, violates any foreign or domestic statute or regulation (such as the Stamp Payments Act of 1862 or US. federal counterfeiting statutes), or government, quasi-government, or private- individuals assert intellectual property claims against Digital Asset network source code or related mathematical algorithms, certain clients could be adversely affected. To the extent that any individual, institution, government or other authority asserts a claim of ownership or wrongful possession over the Digital Assets in the custody of a client, an investment in the client could be adversely affected. Regardless of its merit, such legal action may adversely affect an investment in the client.

Risks of Uninsured Losses. Though certain clients may seek to insure their Digital Asset or Bitcoin holdings, it may not be possible, either because of a lack of available policies or because of prohibitive cost, for a client to obtain insurance of any type that would cover losses associated with Digital Assets or Bitcoin. If an uninsured loss occurs or a loss exceeds policy limits, the client could lose a portion or all of its assets. Clients’ Digital Assets are not covered by the Federal Deposit Insurance Corporation or the Securities Investor Protection Corporation. Qualified Custodian. Under the Investment Advisers Act of 1940 (the “Advisers Act”), SEC registered investment advisers, such as the Investment Adviser, are required to hold securities with “qualified custodians”. Certain Digital Assets (or tokens offered in an Early-Stage Token Offering) may be deemed to be securities. Currently, many of the companies providing Digital Assets custodial services fall outside of the SEC’s definition of “qualified custodian”, and many long-standing, prominent qualified custodians do not provide custodial services for Digital Assets or otherwise provide such services only with respect to a limited number of actively traded Digital Assets. Accordingly, clients may use nonqualified custodians to hold all or a portion of their Digital Assets. If the SEC is not satisfied with this approach, it is possible that the Investment Adviser will be required to custody clients’ assets in a manner that the Investment Adviser believes to be less secure or to divest such assets that are deemed to be securities. Divergent International Regulation and Its Impact. Digital Assets are currently regulated in the U.S., but not all countries take the same regulatory approach. Other countries may take regulatory actions that restrict the right to acquire, own, hold, sell or use Digital Assets or to exchange Digital Assets for fiat currency. Such actions may result in restrictions on the Funds’ abilities to hold or dispose of certain assets. Any future regulatory action may adversely impact the Funds by limiting the functionality of Digital Assets or by restricting their liquidity or reducing their value. Domestic or international regulatory or legislative changes could lower demand for Digital Assets, impede growth in the Digital Asset market generally, and contribute to higher volatility and lower liquidity. There can also be no assurance that regulatory authorities will not examine the operations of the Funds or pursue enforcement actions against them or their affiliates. Such actions could stem from laws of general applicability, as well as from specific actions directed at the Funds or their service providers. In response to such actions, the Funds may be subject to judgments, settlements, fines or penalties, or may be required to restructure their operations or cease offering certain products or services. Any enforcement action could harm the Funds’ reputation, increase operational costs, and adversely affect the value of an investment in the Funds. Legal and Regulatory Classification of Digital Assets. There can be no assurance that Digital Assets held by the Funds will not be deemed or considered to be securities, or a jurisdictional legal equivalent, by other jurisdictions. If Digital Assets are deemed to be securities in certain jurisdictions, the Funds and their investors could be subject to additional restrictions on the sale, transfer, or holding of such assets. The Funds may invest in Digital Assets that are traded or held in multiple jurisdictions, which may result in such assets being subject to the laws and regulations of a variety of regulatory regimes. While the Funds intend to comply with applicable U.S. securities laws and relevant exemptions thereunder, compliance with the laws of each jurisdiction in which Digital Assets are held or traded is required. Many jurisdictions may treat Digital Assets as securities or other such financial products with unique regulatory obligations. Further, jurisdictions that do not currently treat Digital Assets as securities may change their laws, regulations, or interpretations of existing rules regarding the definition of securities or adopt new laws or regulations. Any such changes could result in certain Digital Assets held by the Funds being deemed securities in those jurisdictions. If Digital Assets were determined to be securities in jurisdictions that do not currently treat blockchain-based assets as securities, additional compliance obligations in such jurisdictions may apply both to the Funds and their investors. Sales or

transfers of Digital Assets (including staking rewards or other token distributions) in those jurisdictions may become expensive and burdensome. The impact of such developments would likely be similar to that under U.S. law and could inhibit demand for, or the use and liquidity of, the affected Digital Assets. Lack of Government Backing and Protections. Digital Assets are not legal tender, are not backed by any government, and are not subject to the protections of the FDIC, the Securities Investor Protection Corporation, or any similar program in any jurisdiction. Holding Digital Assets involves a high degree of risk and is done at the risk of the Funds and, indirectly, their investors. Hedging Strategy and Regulatory Uncertainty Risk. The Funds may utilize corresponding hedging positions to mitigate exposure. These hedging activities are designed to manage volatility, liquidity, and market risk. These activities are subject to complex and evolving regulatory oversight. The Funds’ current approach relies on interpretive guidance and no-action positions issued under the present U.S. presidential administration, which has signaled a more measured and adaptive stance toward Digital Asset markets. This approach diverges from the prior administration’s more aggressive enforcement posture, creating a reliance on the continuity of existing policy direction. The Funds’ ability to execute and maintain effective hedging strategies depends on market depth, pricing transparency, and the evolving availability of derivative instruments tied to Digital Assets. These markets may be less developed or subject to periods of illiquidity, which can impair the Funds’ ability to enter or exit positions efficiently. Operational risks may also impact the performance or intended function of the hedge. Investors should recognize that while hedging may reduce certain market risks, it may also introduce distinct sources of volatility and potential loss. Risks Relating to Government Oversight: Federal Regulatory Authorities U.S. Commodity Futures Trading Commission. The Commodity Futures Trading Commission (the “CFTC”) regulates commodities under Section 1a(9) of the under the Commodity Exchange Act (“CEA”) which defines “commodity” broadly to include “all services, rights, and interests in which contracts for future delivery are presently or in the future dealt in.” The CFTC oversees all “commodity interests,” including swaps, futures, perps, options, and “nonEligible Contract Participant” (“non-ECP”) leveraged crypto trades. (Fed. Reg. 48,208, 48,246–47 (Aug. 13, 2012); see also CFTC v. HDR Global Trading Limited, et al., Case No. 1:20-cv-08132 (S.D.N.Y. Aug. 10, 2021).) Only “Eligible Contract Participants” (“ECPs”), typically corporations, partnerships, trusts, brokerage firms or investors who qualify as ECPs by having more than $10 million in total assets, can enter over-the-counter derivatives. Spot transactions, where commodity assets are “actually” delivered within 28 days, do not require CFTC registration unless the transaction includes leverage or margin for non-ECPs. (See In re BFXNA Inc. d/b/a Bitfinex, CFTC Docket No. 16-19 (June 2, 2016)). Transactions with non-ECPs that are leveraged, margined, or financed are treated as futures unless actual delivery occurs within 28 days. If someone is not an ECP, they cannot enter into derivatives contracts unless it’s done on a regulated exchange. There is a somewhat dated statement from a former CFTC commissioner that supports the notion that the creator of a blockchain cannot be held liable for alleged wrongdoing by those who develop apps on that blockchain. Former CFTC Commissioner Brian Quintenz stated in a 2018 speech that “core developers of the underlying blockchain code” have “no involvement in the development of the smart contract code [of applications].” (See Remarks of Commissioner Brian D. Quintenz at the 38th Annual GITEX Technology Week Conference, (October 2022).) He further stated that the core developers “invented a code upon which any number of applications can run and, in my view, it seems unreasonable to hold them accountable for subsequent application that uses their underlying technology, without further evidence of knowledge or intent.”

In the past, the CFTC has brought close to fifty enforcement actions involving the Digital Asset space. See Testimony of Chairman Rostin Behnam regarding “Examining Digital Assets: Risks, Regulation, and Innovation” (Feb. 09, 2022). For example, the CFTC fined the stablecoin issuer Tether Holdings Limited (“Tether”) for making misleading statements regarding its U.S. dollar tether token Stablecoin (“USDT”) in October 2021. Tether was fined $41 million for misrepresenting to customers and the market that Tether maintained sufficient U.S. dollar reserves to back each Tether token in circulation. See “CFTC Orders Tether and Bitfinex to Pay Fines Totaling $42.5 Million,” Release Number 845021 (Oct. 15, 2021). Similarly, in a case involving BitMEX cryptocurrency derivatives trading platform in August 2021, the CFTC found BitMEX in violation of the Commodity Exchange Act by operating a facility to trade or process swaps without proper approvals, fining BitMEX $100 million. In addition, the CFTC issued a $1.4 million civil monetary penalty order against a DeFi platform, Blockratize, Inc. d/b/a Polymarket, for offering off-exchange event-based binary options contracts and failing to register as a swap execution facility (“SEF”) or obtain designation as a designated contract market (“DCM”). See Blockratize, Inc. d/b/a Polymarket.com, CFTC Press Release: PR8478-22 (Jan. 3, 2022). According to the CFTC, Polymarket had been using blockchain-hosted smart contracts to operate an illegally unregistered or non-designated facility for event-based binary options trading contracts, and those event-based binary options contracts constituted swaps under the CFTC’s jurisdiction. See Blockratize, Inc. d/b/a Polymarket.com, CFTC Docket No. 22-09 (Jan. 3, 2022). In the settlement, Polymarket was ordered to wind down all markets that did not comply with the CEA and CFTC regulations, and cease all behavior deemed to be facilitating the trade of swaps. In September 2023, the CFTC issued orders simultaneously filing and settling charges against Opyn, Inc. (“Opyn”), ZeroEx, Inc. (“0x”) and Deridex, Inc. (“Deridex”). Deridex and Opyn were charged with failing to register as a SEF or DCM, failing to register as a futures commission merchant (“FCM”) and failing to adopt a customer identification program as part of a Bank Secrecy Act compliance program (as such compliance is required of FCMs). 0x, Opyn and Deridex were also charged with illegally offering leveraged and margined retail commodity transactions in Digital Assets. See Opyn, Inc., CFTC Docket No. 23-40 (Sep. 7, 2023), ZeroEx, Inc., CFTC Docket No. 23-41 (Sep. 7, 2023) and Deridex, Inc., CFTC Docket No. 23-42 (Sep. 7, 2023). In the event that the Funds’ activities are viewed as holding or offering Digital Asset derivatives (including futures, options and swaps), the Funds, the Investment Adviser or one or more companies in which they invest, may be required to register and comply with additional regulation under the Commodity Exchange Act, such as the Investment Adviser registering as a commodity pool operator (when holding Digital Asset derivatives) or a Fund, or one of the companies in which it invests, registering as a swap execution facility or swap dealer (when offering certain Digital Asset derivatives) or by being subject to the CFTC requirements with respect to such instruments, such as reporting, recordkeeping, mandatory clearing or minimum margin requirements. Such registration and associated compliance costs could adversely affect an investment in the Funds. To the extent the Investment Adviser’s activities are viewed as holding or offering Digital Asset derivatives (including futures, options and swaps), the Investment Adviser or one or more companies in which it invests, may be required to register and comply with additional regulation under the CEA, such as the Investment Adviser registering as a CPO (when holding Digital Asset derivatives) or the Investment Adviser, or one of the companies in which it invests, registering as an SEF or swap dealer (when offering certain Digital Asset derivatives) or by being subject to the CFTC requirements with respect to such instruments, such as reporting, recordkeeping, mandatory clearing or minimum margin requirements. Such registration and associated compliance costs could adversely affect an investment in the Funds.

Further, the CFTC has recently been active in policing activities in liquidity pools. For instance, in 2024, the CFTC engaged in an enforcement action against Universal Navigation Inc. d/b/a Uniswap Labs (the “Uniswap Order”). In the Uniswap Order, the CFTC found that, by allowing users to exchange and otherwise interact in certain “leveraged” tokens through an automated market maker protocol developed and deployed by Uniswap Labs, Uniswap Labs violated Section 4(a) of the CEA, which, generally, requires that transactions in leveraged commodities with non-eligible contract participant customers be made on or subject to the rules of a board of trade that has been designated or registered by the CFTC as a contract market for the specific commodity. This enforcement action will likely result in automated market maker protocols limiting the tokens available to trade on their protocols. While the Uniswap Order noted that leveraged tokens accounted for less than 0.25% of relevant transaction volumes, this could nevertheless limit the Investment Adviser’s investment opportunities, including opportunities to earn fees for providing liquidity to liquidity pools. Further, this and other enforcement actions could create regulatory uncertainty and reduce investment opportunities available to market participants, including the Investment Adviser. SEC. The SEC has asserted jurisdiction with respect to transactions in certain Digital Assets. Whether a particular Digital Asset is deemed a security depends on the specific facts and circumstances of the transaction. Regardless of classification, the SEC and other U.S. regulatory authorities have taken the position that they may investigate, examine, or pursue enforcement actions related to the offer, sale, or trading of Digital Assets. Other agencies with overlapping or distinct enforcement authority, such as the CFTC, the Department of Justice (“DOJ”), or state securities regulators, may also take action in connection with Digital Asset activities that are not classified as securities transactions. In Howey, the U.S. Supreme Court established the standard for determining whether a transaction qualifies as an “investment contract.” The Howey test is a highly fact-specific inquiry pursuant to which courts must examine “the entirety of the parties’ understandings and expectations.” See SEC v. Telegram Grp. Inc., 448 F. Supp. 3d 352, 379 (S.D.N.Y. 2020) (citing SEC v. W.J. Howey Co., 328 U.S. 293, 297-98 (1946)). Courts apply this fact-specific inquiry to determine whether a cryptocurrency is an: (1) an investment of money; (2) in a common enterprise; (3) with the expectation of profit; and (4) derived solely by the efforts of others. All four prongs must be met for a transaction to qualify as an investment contract and, thus, a security. The SEC’s April 2019 “Framework for ‘Investment Contract’ Analysis of Digital Assets” (the “Framework”) outlines how the agency applies the Howey test to digital assets and provides a set of non-exhaustive factors to determine whether a cryptocurrency is being offered as a security. (See U.S. Securities and Exchange Commission, Framework for “Investment Contract” Analysis of Digital Assets (Apr. 3, 2019).) While promulgated in 2019, the Framework marked the SEC’s first meaningful attempt to define the treatment of cryptocurrencies under federal securities laws and has since been followed by applicable court decisions. The Framework emphasizes economic reality over form and focuses on whether there is an investment of money in a common enterprise with a reasonable expectation of profits derived from the efforts of others. Since issuing the Framework, the SEC’s Division of Enforcement, under former SEC Chairman Gary Gensler, brought several enforcement actions against high-profile cryptocurrency companies in the U.S. Under Chairman Paul Atkins, appointed by President Trump, the SEC has shifted away from its prior regulation-by-enforcement approach, voluntarily dismissing several significant enforcement actions and signaling a move toward clearer, rules-based regulation. (See Securities and Exchange Commission v. Coinbase, Inc., No. 23 Civ. 4738 (S.D.N.Y. Feb. 27, 2025); see also SEC v. Binance Holdings Limited, et al., No. 23-cv-1599, Dkt. 301 (D.D.C. 2023) (May 29, 2025). (On February 27, 2025, the SEC announced that it had filed a joint stipulation with Coinbase Inc. and Coinbase Global Inc., to dismiss the ongoing civil enforcement action against both entities.) Atkins has criticized the prior approach in Senate testimony and created a Crypto Task Force led by Commissioner Hester Peirce to promote regulatory clarity. (See Opening Statement of Paul Atkins Nomination Hearing Before the Senate Banking Committee (Mar. 27, 2025).)

For example, on February 27, 2025, the SEC announced that it had filed a joint stipulation with Coinbase Inc. and Coinbase Global Inc., to dismiss the ongoing civil enforcement action against both entities, stating that the dismissal would “facilitate the Commission’s ongoing efforts to reform and renew its regulatory approach to the crypto industry.” (See Securities and Exchange Commission v. Coinbase, Inc., No. 23 Civ. 4738 (S.D.N.Y. Feb. 27, 2025); Press Release, SEC Announces Dismissal of Civil Enforcement Action Against Coinbase, U.S. Securities and Exchange Commission (Feb. 27, 2025).) On May 29, 2025, the SEC filed a similar joint stipulation with the Binance defendants, dismissing its civil enforcement action against them. See SEC v. Binance Holdings Limited, et al., No. 23-cv-1599, Dkt. 301 (D.D.C. 2023) (May 29, 2025). Following the SEC’s enforcement actions, ten state regulators pursued similar actions alleging that Coinbase’s Staking program involved the unregistered offer and sale of securities. See e.g., Kentucky Department of Financial Institutions v. Coinbase Global, Inc., Coinbase, Inc., No. 2023-AH-00011, (Kentucky Department of Financial Institutions, March 31, 2025); In the Matter of Coinbase Global, Inc., Coinbase, Inc., No. 20225292, (Securities Commissioner of South Carolina March 27, 2025); In Re Coinbase Global, Inc., Coinbase Inc., No. 23-003-S (Vermont Department of Financial Regulation March 13, 2025); In the Matter of: Coinbase Global, Inc., Coinbase, Inc., No. CO-2023-0009 (Alabama Securities Commission, April 23, 2025) California Desist and Refrain Order (June 6, 2023); New Jersey Summary Order (June 6, 2023); Maryland Show Cause Order (June 6, 2023); and In the Matter of Coinbase Global, Inc., Coinbase, Inc., No. C2023-0127 (Ill. Sec. Dep’t Mar. 28, 2025). Five states (i.e., California, Washington, Wisconsin, New Jersey, and Maryland) issued cease-and-desist orders or initiated litigation, emphasizing that investor returns were tied to Coinbase’s managerial efforts and success. See, e.g., Maryland Show Cause Order *8 (June 6, 2023) (“Coinbase advertises that investors can profit by depositing crypto assets with Coinbase and letting Coinbase stake the deposits. Coinbase advertises on its website as follows: a. ‘Earn up to 6.00% APY on your crypto. Put your crypto to work and earn rewards.’ c.[‘]Collect rewards automatically just for holding popular assets.’”). Five other states (i.e., Alabama, Illinois, Kentucky, South Carolina, and Vermont) initially brought actions but later dismissed them, with Alabama noting that “it would be most efficient, appropriate, and in the best interests of justice to RESCIND the pending Show Cause Order” in light of ongoing federal policy development. See, e.g., In the Matter of: Coinbase Global, Inc., Coinbase, Inc., No. CO-2023-0009, paragraphs 4-6 (Alabama Securities Commission, April 23, 2025). Furthermore, while not regulation or law, recent SEC statements such as the Statement on Certain Protocol Staking Activities (See U.S. Sec. & Exch. Comm’n, Statement on Certain Protocol Staking Activities (May 29, 2025).) and Chairman Paul Atkins’ speech on American Leadership in the Digital Finance Revolution (See Paul S. Atkins, Chairman, U.S. Sec. & Exch. Comm’n, American Leadership in the Digital Finance Revolution (July 31, 2025).) indicate the SEC’s view that many cryptocurrencies and cryptocurrency activities fall outside the ambit of its regulatory authority. Importantly, Chairman Atkin’s speech includes the assertion that “[d]espite what the SEC has said in the past, most crypto assets are not securities.” In addition, comments made in August 2025 by Assistant Attorney General Matthew Galeotti of the Department of Justice’s suggests the agency is unlikely to target software developers for merely writing code without criminal intent going forward. (See Office of Public Affairs | Acting Assistant Attorney General Matthew R. Galeotti Delivers Remarks at the American Innovation Project Summit in Jackson, Wyoming | United States Department of Justice (“Our view is that merely writing code, without ill-intent, is not a crime. Innovating new ways for the economy to store and transmit value and create wealth, without ill-intent, is not a crime.”); see also US DOJ to back off money transmitter cases in shift backed by crypto | Reuters.) In general, the regulatory risk for cryptocurrency has been significantly reduced with this new administration. There can be no assurance that the Investment Adviser or the General Partners will avoid regulatory examination and possibly enforcement actions. Many of the SEC’s prior enforcement actions against U.S.-based private fund advisers engaged in Digital Asset strategies occurred under the previous administration and reflected a more aggressive enforcement posture. Those proceedings commonly involved issues such as compliance with Rule 206(4)-2 under the Advisers Act (custody rule), adherence to Rule 144 (resale restrictions), and the potential need to register as broker-dealers when engaging in secondary market transactions.

Under the current administration, however, the SEC has indicated a move away from “regulation-byenforcement” toward a rules-based, guidance-driven framework. As such, while the potential for regulatory examination remains, the likelihood of adversarial enforcement against compliant fund advisers has diminished. Although the Investment Adviser believes its practices are consistent with prevailing industry standards and current regulatory expectations, there can be no assurance that future interpretations will not differ. If the SEC or any other authority questions or challenges such practices, the General Partners or Investment Adviser could face examinations, investigations, or sanctions. Even absent monetary penalties, any such scrutiny could result in reputational impact or require procedural adjustments to the Funds’ compliance framework. If certain Digital Assets held by the Funds are later deemed to be securities, the Funds may be required to comply with additional registration, reporting, custody, or trading obligations. While recent statements by the SEC suggest a narrower scope of what constitutes a “security” in the Digital Asset context, the possibility of reclassification cannot be excluded. Any such change in classification could result in increased compliance costs, temporary trading restrictions, or a decline in the value or liquidity of affected Digital Assets. The Investment Adviser continuously monitors regulatory developments and may, where appropriate, treat certain Digital Assets as securities for purposes such as custody, trading, or material nonpublicinformation controls to ensure compliance with applicable U.S. laws. If Digital Assets held by the Funds were unexpectedly deemed to be securities under a future regulatory framework, the Funds could incur additional compliance burdens or temporary restrictions on transferability until procedures are adapted. SEC Enforcement Activities. In the past the SEC has brought enforcement actions relating to Digital Assets that assert the SEC’s jurisdiction due to the SEC’s classification of such instruments as securities, including in relation to certain Digital Assets.. These risk factors do not contain a comprehensive description of all such actions, but provide certain examples and key cases: In July 2022, the SEC filed securities fraud charges against a former employee of Coinbase, Inc. (“Coinbase”) related to misuse of confidential information and two other individuals, alleging that this employee engaged in illegal insider trading in violation of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, with respect to transactions in several Digital Assets, which the SEC asserted are securities, by trading in those Digital Assets prior to such assets being made available for trading on the Coinbase platform. The former Coinbase employee and two other persons were also indicted on two counts of wire fraud and conspiracy to commit wire fraud in connection with this alleged insider trading. In February 2023, the former Coinbase employee pleaded guilty to two counts of conspiracy to commit wire fraud, and in May 2023 the former Coinbase employee was sentenced to two years in prison. In May 2023, the SEC and the former Coinbase employee settled the securities fraud claims referenced above, pursuant to which the former Coinbase employee and his co-defendant agreed to be permanently enjoined from violating Section 10(b) of the Securities Exchange Act and Rule 10b-5 and to pay disgorgement of ill-gotten gains, plus prejudgment interest. These orders were deemed satisfied by the forfeiture orders issued pursuant to the criminal action. In February 2023, the SEC brought a lawsuit against Terraform Labs PTE Ltd and its Chief Executive Officer in the U.S. District Court for the Southern District of New York, alleging, among other charges, violations of federal securities fraud in connection with the sale of crypto assets, including MIR and LUNA tokens. On July 31, 2023, U.S. District Judge Jed Rakoff denied a motion to dismiss the SEC’s claim, rejecting the distinction relied up on in the Ripple decision between issuances to institutional investors and secondary transactions involving retail investors, and ruling

that the case could proceed because the SEC has a “plausible claim” that Terraform Labs’ Terra USD token was a security when sold on public exchanges. In December 2023, Judge Rakoff ruled that TerraForm Labs violated U.S. law by failing to register Terra USD and Luna as securities. In August 2025, Terraform’s former Chief Executive Officer pled guilty to one count of conspiring to commit commodities fraud, securities fraud, and wire fraud, as well as one count of committing wire fraud in connection to his admitted deceitful actions at Terraform. In February 2023, the SEC entered into a settlement agreement with Payward Ventures, Inc. and Payward Trading Ltd. (collectively, “Kraken”), a cryptocurrency exchange, after alleging that Kraken’s “staking-as-a-service” program constituted an offering and sale of securities. The settlement agreement provides that Kraken will cease offering or selling securities through crypto asset staking services or staking programs and pay $30 million in disgorgement, prejudgment interest, and civil penalties. On September 3, 2024, the SEC settled an enforcement action against Galois Capital Management LLC (“Galois”), a former registered investment adviser, for: (1) failure to hold the crypto asset securities of the Galois Capital Alpha Fund LP (the “Galois Fund”) with a qualified custodian in violation of SEC Rule 206(4)-2 (the “Custody Rule”), and (2) misleading investors about the requisite notice periods for redemptions from the Galois Fund. The SEC’s settlement stated that Galois continuously held the Galois Fund’s crypto asset securities in online trading accounts on crypto asset trading platforms, specifically FTX. As a result, Galois lost half of the Galois Fund’s assets under management in connection with the FTX collapse in November 2022. This action represents the first instance in which the SEC charged a registered investment adviser with violating the Custody Rule for failing to hold crypto asset securities with a qualified custodian. FinCEN. To the extent that a client, or an entity in which a client invests, engages in money services business activity, including money transmission, as defined by FinCEN, the client or such entity may be deemed to fall within the Bank Secrecy Act’s definition of a financial institution, and subject to the Bank Secrecy Act, 31 U.S.C. §§ 5311-5314; 5316-5336, and its implementing regulations, and as such required to register with FinCEN as a Money Services Business. Certain clients and such entity would also be required to develop an AML program and adhere to federal reporting and recordkeeping requirements. Owners, operators, participants and others who assist in the operation of an unregistered money services business, may be subject to civil money penalties under 31 U.S.C. § 5321, and/or criminal liability under 31 U.S.C. § 5322 and 18 U.S.C. § 1960. Such additional legal and regulatory obligations may cause the client to incur extraordinary expenses and ongoing expenses, possibly affecting an investment in the client in a material and adverse manner. To the extent certain clients limit or reduce the scope of certain activities, investors’ rights or investment initiatives, in order to limit the applicability of government regulation and supervision, investments in certain clients may be adversely affected. In addition, on October 19, 2023, FinCEN issued a proposed rule (“Proposed Rule”) to apply the authorities of Section 311 of the USA PATRIOT Act to require covered financial institutions to implement recordkeeping and reporting requirements for transactions involving mixing of convertible virtual currency (“CVC”) within or involving a jurisdiction outside the United States and to designate mixing of CVC as a class of transactions of “primary money laundering concern.” The definition of CVC mixing in the Proposed Rule is drafted broadly such that if the Proposed Rule is finalized without modification, U.S. covered financial institutions may cease offering services to or engaging in transactions involving DeFi or DAPPs, which could cause Digital Assets to decline in value and adversely affect the ability of the clients to achieve its investment objective or operate in compliance with laws and regulations. Moreover, covered financial institutions and

the clients could face substantial costs to comply with any regulations requiring recordkeeping and reporting for transactions related to CVC mixing, which could adversely affect the ability of the clients to achieve their investment objectives. Further, FinCEN and the DOJ (and other government authorities) continue to take an active and focused role in prosecuting violations of anti-money laundering and sanctions laws involving virtual currency activities. For example, on November 21, 2023, FinCEN assessed a civil money penalty of $3.4 billion and OFAC assessed a penalty of $968 million against Binance Holdings Ltd. and its affiliates (collectively, “Binance”), a virtual currency exchange platform, for violations of the Bank Secrecy Act and multiple sanctions programs, including failure to implement programs to prevent and report suspicious transactions. The founder of Binance was also later sentenced to prison for four months. Such increased scrutiny by government authorities could affect the ability for a DAPP or DeFi protocol to operate, as government authorities investigate or examine circumstances associated with transacting in Digital Assets, mandate additional compliance controls, and impose transaction restrictions, which could adversely affect the ability of the clients to achieve their investment objectives. State Regulatory Authorities. Whether certain Digital Assets are deemed securities, or not, state securities regulators may investigate or examine circumstances associated with transacting in those Digital Assets. State securities regulators may also pursue investigations or actions involving transactions in Digital Assets that are not deemed securities. In addition, state money services business regulators may investigate or examine circumstances associated with transacting in Digital Assets. To the extent such regulators deem the activities of certain clients to be deemed a “money transmitter” (and/or any other type of regulated financial services provider, for example, a “virtual currency business” in New York) under state statutes or regulations, the Investment Adviser may incur significant fees in becoming licensed in each state in which it does business, and may also be required to adhere to state statutes, regulations and guidance. For example, the New York Department of Financial Services requires that custodians of virtual currency that are either BitLicensees or entities chartered by New York as limited purpose trust companies take measures to adequately protect, segregate and separate customer virtual currency from their own, engage in adequate due diligence of sub-custodians, and have clear customer- facing disclosures regarding the general terms and conditions associated with their products and services. Similarly, California, in October 2023, passed the California Digital Financial Assets Law, which prohibits a person from engaging in digital financial asset business activity or holding out as being able to engage in such activity without meeting certain criteria and being licensed by the California Department of Financial Protection and Innovation. States may impose fines or penalties with respect to any unlicensed activity or activity that violates applicable regulations and guidance. Further, owners, operators, participants and others who assist in the operation of an unlicensed money transmission or virtual currency business may also be subject to fines or penalties, and/or criminal liability under state laws or 18 U.S.C. § 1960, if applicable. Several additional states, specifically Maine, Minnesota, North Dakota, and Vermont, have amended their money transmission statutes to bring Digital Asset activities within their licensing regimes. Drawing from the Conference of State Bank Supervisors’ “Money Transmission Modernization Act,” these amendments now define “control of virtual currency” as the power to execute unilaterally or prevent indefinitely a virtual currency transaction, thereby potentially extending licensing requirements to a wide array of Digital Asset custodial and transfer activities. Although these provisions primarily target exchange and wallet service providers, the trend underscores growing state-level alignment toward regulated treatment of Digital Asset custody and control functions.

In the event that the Investment Adviser is required to adhere to state statutes, regulations and guidance applicable to money transmitters or virtual currency businesses, such additional legal and regulatory obligations may cause a client or the Investment Adviser to incur extraordinary expenses and ongoing expenses, possibly affecting an investment in a client in a material and adverse manner. To the extent that a client or the Investment Adviser limits or reduces the scope of certain investment activities of the clients’, investors’ rights, or the clients’ investment initiatives in order to limit the applicability of government regulation and supervision over the clients’ and not obtain licensing in each state in which it does business, the value of investments held in the clients may be adversely affected. Foreign Jurisdiction. Various foreign jurisdictions may adopt policies, laws, regulations or directives that affect Digital Assets or a Digital Asset network, generally. Such additional foreign regulatory obligations may cause the client, or the portfolio companies in which the clients invest, to incur extraordinary expenses and ongoing expenses, possibly affecting an investment in the client in a material and adverse manner. To the extent a Digital Asset is determined to be a security, commodity interest or other regulated asset, or a U.S. or foreign government or quasi-governmental agency exerts regulatory authority over Digital Asset use, exchange, trading and ownership generally in particular, the net asset value of a client may be adversely affected. Any additional regulatory obligations may cause a client, or a company that develops Digital Assets that are held by a client, to incur extraordinary, non-recurring expenses, and/or ongoing compliance expense, possibly affecting an investment in a client in an adverse manner. If a client, or a company that develops Digital Assets that are held by a client, determines not to comply with such regulatory requirements, a client, or such company, may be liquidated at a time that is disadvantageous to an investor. To the extent a client, or a company that develops Digital Assets that are held by the client, limits or reduces the scope of certain activities, investors’ rights or investment initiatives, in order to limit the applicability of government regulation and supervision, investment in the client may be adversely affected. Low Liquidity and Concentration of Ownership. By some comparisons, the market for Digital Assets, by trade volume, is very shallow. Many Digital Assets may also be hoarded by a few owners. Ownership concentration can be high, which creates greater market liquidity risk as large blocks of Digital Assets are difficult to sell in a timely and market efficient manner and well-connected customers can gain preferential treatment in order execution. In addition, a concentration of ownership can cause increased price volatility as trades by large holders of Digital Assets can impact the market price of Digital Assets. The daily trading volume of Digital Assets is a fraction of total Digital Assets mined. The lack of a robust and regulated derivatives market for most Digital Assets means that market participants do not have a broad basket of tools at their disposal, making hedging difficult. Legacy Wallets. Since the initial launch of the Bitcoin blockchain, a number of early Bitcoin wallets have accumulated and retained large amounts of Bitcoin. While thought to be dormant or inaccessible, these wallets may be accessed by their owners at any time. For example, in September 2021, a Bitcoin wallet dating back to around the time that Bitcoin’s pseudonymous creator Satoshi Nakamoto was last active online suddenly activated. If such wallets are detected as being active, the expected dilution of the Bitcoin supply could negatively impact the price of Bitcoin and other Digital Assets. Further, the Bitcoin contained in these wallets may be sold, which would have a negative impact on the price of Bitcoin and other Digital Assets. Digital Asset Key Person Risk. Although blockchain technology emphasizes decentralization and transparency, certain cryptocurrency protocols, including certain Digital Assets, are headed by one or more creators who remain active in the ongoing development and leadership of such protocol or Digital Assets. If a creator or leader of a Digital Asset is unwilling or unable to continue supporting

and developing the Digital Asset, the price of the Digital Asset, as well as other Digital Assets, could be negatively affected. Blockchain Analytics. Given that Digital Assets can be transferred peer-to-peer directly from one individual or entity to another pseudonymously, absent the use of a regulated third party, such as through non-custodial wallets or self-hosted wallets, and that digital wallets can be created almost instantaneously, it is almost impossible to accurately and effectively conduct transaction counterparty due diligence, transaction monitoring, and sanctions screening related to Digital Asset transactions without the use of blockchain analytics tools, the use of which are being increasingly encouraged or expected by regulators and government authorities. For example, the New York Department of Financial Services issued guidance in April 2022 to all virtual currency business entities that are either licensed under 23 NYCRR Part 200 or charted as a limited purpose trust company under the New York Banking Law on the importance of blockchain analytics to effective policies, processes, and procedures. To the extent such tools identify and/or classify a Digital Asset, a digital wallet, transaction or counterparty as higher risk, or as having direct or indirect exposure to criminal activity or sanctions, either correctly or incorrectly (based on erroneous information or an absence of information), the Funds, and/or the Digital Assets invested in by the Funds, may be negatively impacted, the investors may be adversely affected and the Funds may be unable to pursue their investment objectives. Bitcoin Lending. The Bitcoin Funds may lend Bitcoin on a collateralized and an uncollateralized basis from its portfolio to creditworthy securities firms, financial institutions and other third-party borrowers (and affiliates of the Bitcoin Funds and/or the Investment Adviser). While such loan is outstanding, the Bitcoin Funds will receive interest on the investment of the collateral or a fee from the borrower. The risks in lending Bitcoin, as with other extensions of secured credit, if any, consist of possible delay in receiving additional collateral, if any, or in recovery of Bitcoin or possible loss of rights in the collateral, if any, should the borrower fail financially. Furthermore, during the time any Bitcoin is in the possession of such borrower, such Bitcoin may be kept in custody that provides a different level of security than that of the Bitcoin Funds’s custodian. In addition, Bitcoin lending may be treated for U.S. federal income tax purposes as a sale of the lent Bitcoin, which would cause the Bitcoin Funds to recognize any built-in gain or loss in such Bitcoin. Past Developments in the Digital Asset Industry. In 2022, several prominent Digital Asset-related firms, including trading venues, exchanges and lending platforms, experienced financial distress and/or declared bankruptcy (the “Past Developments”). These failures included firms such as Celsius Networks, Three Arrows Capital, FTX and Voyager Digital. The impact of the Past Developments on the Digital Asset markets, including on other institutions or critical infrastructure for such markets, is not yet fully known and may evolve. Such impacts may include, but are not limited to: loss of confidence in the Digital Asset markets, reduced participation in the Digital Asset markets, closer scrutiny by governmental authorities of firms transacting in Digital Assets, or servicing Digital Asset market participants, new legislation and/or regulation of the Digital Asset markets. The Investment Adviser was not directly involved in the Past Developments, however such changes resulted in price changes and volatility in the Digital Asset markets, as well as increased negative scrutiny of the Digital Asset markets by governmental authorities and the press—these events indirectly impacted the clients. Selling of Digital Assets by companies experiencing bankruptcy and/or financial distress could depress the prices of such assets. It is possible that such effects could cause systemic risks to the Digital Asset markets. If the Past Developments cause sustained adverse impacts on the Digital Asset markets, the effectiveness and outlook for the clients’ investment strategies may be impacted in a materially adverse manner.

Forced selling by distressed companies may also depress the prices of assets used as collateral by other firms. If this market condition becomes widespread in the cryptoeconomy, including as a result of the Past Developments, we may suffer from increased counterparty risk, including defaults or bankruptcies of major customers or counterparties, which could lead to significantly reduced activity on our platform and fewer available crypto market opportunities in general. Further, forced selling of crypto assets by distressed companies could lead to lower crypto asset prices and a consequent reduction in our revenue. To the extent that conditions in the general economic and crypto assets markets materially deteriorate, our ability to attract and retain customers may suffer. Potential Interest Rate Increases. Uncertainty of the U.S. and global economy, and sensitivity of interest rates to changes in U.S. government and other nations’ monetary and fiscal policies, including changes in the federal funds rate, create a risk that interest rates will be volatile in the future. Interest rate volatility is difficult to predict, and may cause the value of any assets sensitive to interest rates, including fixed-income instruments, held by the clients to decrease, which may result in substantial withdrawals from the clients that, in turn, force the clients to liquidate such instruments at disadvantageous prices negatively impacting the performance of the client portfolios. Sanctions. The Investment Adviser’s operations are or may become subject to economic sanctions laws and regulations of various jurisdictions. At any given time, whether under applicable law, by contractual commitment or as a voluntary risk management measure, the Investment Adviser may be required, or elect, to comply with various sanctions programs, including the Specially Designated Nationals and Blocked Persons List and Sectoral Sanctions programs administered by OFAC, the sanctions regimes administered by subsidiary organs of the United Nations Security Council, the Sanctions Orders of the Cayman Islands (including as extended to the Cayman Islands by Order of the government of the United Kingdom from time to time), and the Restrictive Measures adopted by the European Union. Some sanctions that may apply to the Investment Adviser prohibit or restrict dealings with particular identified persons or digital wallets. Other potentially applicable sanctions programs broadly prohibit or restrict dealings in certain countries or territories or with individuals and entities located in such countries or territories. In addition to such current sanctions, additional sanctions may be imposed in the future. Such sanctions may be imposed with little or no advance warning or “safe harbour” for compliance and may be ambiguous, including as to the scope of financial activities that regulators may ultimately deem to be covered by the sanctions. Depending on the scope and duration of a particular sanctions program, compliance by the clients may result in a material adverse effect on the client portfolios. The Investment Adviser and its clients may be subject to heightened or targeted regulatory scrutiny and information requests as a result of such sanctions. In addition, if the Investment Adviser or its clients were to violate or be deemed in violation of any such sanction, they could face significant legal and monetary penalties. Sanctions may negatively impact the Investment Adviser’s ability to effectively implement its clients’ investment strategies and have a material adverse impact on the clients’ investments in various ways, including by preventing or inhibiting the clients from making certain investments, forcing the clients to divest from investments previously made, and leading to substantial reductions in the revenues, profits and value of the clients’ investments. Finally, sanctions may have broader economic implications, such as influencing the price of certain commodities, which may have adverse effects on inflation and the value of the U.S. dollar, which may adversely affect investment objectives and strategies of the clients. The U.S. government has also imposed, and authorized the imposition of, sanctions targeting Russia’s financial sector and access to capital markets. Such sanctions may adversely affect the investment objectives and strategies of certain clients. Climate Change-Related Risks. The environmental effects of climate change, including rising

temperatures, extreme weather, fires, flooding, erratic weather fluctuations, agricultural failures and displacement and destabilization of human populations, could have materially adverse effects on the investments held by the clients. The Investment Adviser believes that such risks may increase over time, although the time period over which these consequences might unfold is difficult to predict. In addition to the physical, economic and geo-political risks associated with climate change, there are transition risks. The willingness of certain governments, industries and businesses, especially those that profit from, or have a reliance on, fossil fuels, to adapt to climate change or transition to sustainable practices may also adversely affect the investments held by the client portfolios. Regulatory changes and divestment movements tied to concerns about climate change could adversely affect the value of certain industries whose activities or products are seen as accelerating climate change, or ill-positioned in light of the economic and social demands imposed by climate change. In recent years, certain investors have incorporated the business risks of climate change and the adequacy of companies’ responses to climate change as part of their investment theses. These shifts in investing priorities may result in adverse effects on the trading price of investments held by the clients if investors determine that the company has not made sufficient progress on climate change and environmental sustainability matters whether or not climate change proves to be as severe as predicted or preventable. The values of investments held by the clients whose performance is linked to assets and revenue streams that are exposed to climate change risk, may readily be affected by both long-term, systemic effects of climate change, as well as severe environmental events whose occurrence is inherently unpredictable. Assumption of Catastrophe Risks. The client portfolios may be subject to the risk of loss arising from direct or indirect exposure to various catastrophic events, including the following: hurricanes, earthquakes and other natural disasters (which may be caused, or enhanced in frequency and severity, by climate change factors); war, terrorism and other armed conflicts; cyberterrorism; major or prolonged power outages or network interruptions; and public health crises, including infectious disease outbreaks, epidemics and pandemics. To the extent that any such event occurs and has a material effect on global financial markets or specific markets or issuers in which the Investment Adviser causes the clients to invest (or has a material negative impact on the operations of the Investment Adviser or the clients’ service providers), the risks of loss can be substantial and could have a material adverse effect on the clients’ investments therein. Furthermore, any such event may also adversely impact one or more individual client investor’s financial condition, which could result in substantial withdrawal requests by such investor as a result of their individual liquidity situations and irrespective of client performance. TON and the Open Network Generally. The investment characteristics of virtual Digital Assets generally, and of TON specifically, differ from those of traditional currencies, commodities or securities. Importantly, TON is not backed by a central bank or a national, supra-national or quasinational organization, any hard assets, human capital, or other form of credit. Rather, it is marketbased: TON’s value is determined by (and fluctuates often, according to) supply and demand factors, the number of merchants that accept it, the adoption of smart contracts using the TON platform, competition from other smart contract platforms and the value that various market participants place on it through their mutual agreement, barter or transactions. Clients will conduct yield-generating DeFi activities in TON, which is an evolving, relatively new product and technology. The methods whereby TON is created, secured, accessed and used may differ from other Digital Assets.

Development and Acceptance of TON. As a relatively new product and technology, TON is not yet widely adopted. Banks and other established financial institutions may refuse to process funds for TON transactions, process wire transfers to or from TON exchanges, Digital Asset–related companies or service providers, or maintain accounts for persons or entities transacting in Digital Assets. Market capitalization for Digital Assets as a medium of exchange and payment method may always be low. To date, speculators and investors seeking to profit from either short- or long-term holding of TON drive much of the demand for it, and competitive products may develop which compete for market share. Clients could be adversely impacted if TON fails to expand into retail and commercial markets and/or if smart contracts using the TON platform fail to expand. Staking Generally and Staking of Purchased TON. During the initial distribution phase from June 2020 to June 28, 2022, over 98% of available TON was available for mining using the proof-ofstake consensus rather than proof-of-work. Because no more TON can be mined, TON now relies on a proof-of-stake algorithm for certain functionalities. TON incentivizes validators operating special nodes to keep the network functioning by depositing stakes to guarantee their dependability and reach consensus, and then reward validators after a predetermined period of time with the reward and the return of their deposit (“Proof of Stake”). The TON received as a reward is up to 0.6% of the total TON per year. TON is also earned through “Play to Earn” games on Telegram. Certain clients’ investment activities will be conducted in TON, including staking activities, which will expose it to risks generally associated with staking and proof-of-stake networks. Digital Assets (including TON) that are staked are maintained outside of cold storage during the staking process, locked into a smart contract and will generally not be maintained with a qualified custodian while it is being staked. The owner of the staked Digital Assets is provided with withdrawal keys that allow retrieval of the staked Digital Assets once withdrawals have been activated by the relevant protocol, and on a defined timeline with daily limits on the number of Digital Assets that can be withdrawn. Withdrawal keys will be held by a qualified custodian, but the additional complexities of staking Digital Assets can increase the risk of loss. Staked Digital Assets are also subject to higher risk of loss or theft due to malicious actions, network interruptions, or a failure by third-party validators to validate transactions. Staking will expose client assets to smart contracts. Smart contracts are subject to certain risks and may result in losses stemming from errors, bugs or other failures. Staking provides no guarantee of return nor are there currently efficient ways to insure against such risks. To the extent that smart contract insurance is available, it may not cover all risks related to staking of the Purchased TON (or other staked Digital Assets), engaging with smart contracts, or other opportunities utilized by clients, and neither clients nor the Investment Adviser is obligated to obtain such insurance. While the Investment Adviser expects to cause clients to engage in staking, neither the clients nor the Investment Adviser makes any guarantee or assurance that staking the Purchased TON (or other Digital Assets) will mitigate relevant risks. TON’s Ties to Telegram. While the team behind the messaging app Telegram initially developed TON, Telegram no longer has direct involvement due to the regulatory challenges surrounding the initial launch of TON, which was abandoned in May 2020 after the SEC filed a lawsuit in October 2019 claiming the ICO constituted an unregistered securities sale. The project was then taken up by the community rather than Telegram, and rebranded in 2021 as The Open Network Foundation, and spent 2021 and 2022 refining the network’s architecture. Telegram Messenger is no longer officially involved in the development of TON, but has integrated TON into the app and offers self-custodial wallet integration. TON jumped 40% in March 2024 following the announcement that 50% of ad revenue generated by Telegram channel owners would be paid in TON. This indirect tie to a social media platform could lead to increased volatility in client portfolios beyond the inherent risks

relating to Digital Assets. WLD Generally. The investment characteristics of Digital Assets generally, and of WLD specifically, differ from those of traditional currencies, commodities or securities. Importantly, WLD is not backed by a central bank or a national, supra-national or quasi-national organization, any hard assets, human capital, or other form of credit. Rather, it is market-based: WLD ‘s value is determined by (and fluctuates often, according to) supply and demand factors, the number of merchants that accept it, the adoption of smart contracts using the WLD platform, competition from other smart contract platforms and the value that various market participants place on it through their mutual agreement, barter or transactions. The Investment Adviser will cause clients to invest in WLD, which is an evolving, relatively new product and technology. The methods whereby WLD is created, secured, accessed and used may differ from other Digital Assets. Staking of Purchased WLD. The ability to “stake” WLD does not currently exist, nor is there the expectation that such ability to “stake” will be implemented in the future. However, if the ability to “stake” WLD becomes possible, the Investment Adviser may cause clients to “stake” Purchased WLD. The Purchased WLD that are “staked” will earn rewards in the form of additional WLD, which will accrue to the validator address, but neither the rewards nor the principal allocation of WLD can be withdrawn for a predetermined period of time, and as a result, the liquidity of such WLD will be limited. Such limitations on liquidity could prevent clients from disposing of such WLD during certain periods. C. Risks Associated With Particular Types of Securities We do not recommend a particular type of investment instrument to the Funds, but rather, we recommend and invest in multiple investment instruments. Given the broad discretion we have in managing the Funds, any one or more of the risks listed in the previous section may be incurred by our clients. However, because it may be useful in understanding our investment program, set forth below is a non- exclusive list of certain risks related to securities and other instruments that may be utilized within the client portfolios: Digital Assets and Bitcoin Generally. The investment characteristics of Digital Assets (which term includes, but is not limited to, virtual currencies, cryptocurrencies, digital coins/tokens, native tokens, stablecoins, non-fungible tokens, security tokens, trade tokens, synthetic assets, and any stored value within distributed ledger technologies), generally differ from those of traditional currencies, commodities or securities. Importantly, Digital Assets are not backed by a central bank or a national, supra-national or quasi-national organization, any hard assets, human capital, or other form of credit. Rather, Digital Assets are market-based: a Digital Asset’s value is determined by (and fluctuates often, according to) supply and demand factors, the number of merchants that accept it, and/or the value that various market participants place on it through their mutual agreement, barter or transactions. Certain activities that we undertake in connection with holding Digital Assets, such as staking, can lead to significant risks, such as limitations on liquidity or a risk of loss or theft due to malicious actions, network interruptions or a failure by third-party validators to validate transactions. The portfolio companies of certain clients generally will be related in various ways to the digital currency marketplace. Certain of the risks relating to Bitcoin (and other digital or virtual currencies)

are detailed below. Dependent on New Technology. TON and WLD are based in the rapidly changing fields of blockchain technology and the Digital Asset markets and thus faces special risks. The Investment Adviser has no control over and limited visibility into future technological developments. The rapid pace of technological development creates the risk that TON and WLD become obsolete, fails to gain meaningful market share, or falls out of favor as more appealing and advanced technologies and products emerge. TON and WLD have a very limited operating history. Such a technology may be unable to engage and retain sufficient skilled engineering, marketing and management personnel to allow it to maintain its technological edge and develop the corporate infrastructure required to sustain and grow its business. For these and other reasons specific to the lending industry, investments in TON and WLD pose greater risks than those in certain other sectors and other, more established Digital Assets. Development and Adoption of Blockchain Networks. The further development and acceptance of blockchain networks are part of a new and rapidly changing industry and are subject to a variety of factors that are difficult to evaluate. The Funds operate in a new industry and may be subject to heightened oversight, scrutiny, regulations, investigations, and enforcement. The regulatory status of consumptive use Digital Assets, and blockchain technology is unclear or unsettled in many jurisdictions, and it is difficult to predict how or whether governmental authorities may regulate such technologies. Numerous regulatory authorities across jurisdictions have been outspoken about considering the implementation of regulatory regimes that govern these technologies and the exchanges or markets associated therewith. It is difficult to predict how or whether any governmental authority may make changes to existing laws, regulations, or rules that may affect consumptive Digital Assets, blockchain technology, and its applications. Such regulations, including any governmental oversight, scrutiny, investigations, and enforcement, whether directed at the industry or the Funds, and changes to existing laws, regulations, or rules could have a material adverse effect on investments in the Funds. The factors affecting the further development of the cryptocurrency industry, as well as blockchain networks, include, without limitation: (i) worldwide growth in the adoption and use of blockchain technologies; (ii) government and quasi-government regulation of blockchain assets and their use, or restrictions on, or regulation of, access to and the operation of blockchain networks or similar systems; (iii) the maintenance and development of open-source software protocols; (iv) changes in consumer demographics and public tastes and preferences; (v) the availability and popularity of other forms or methods of buying and selling goods and services, or trading assets, including new means of using fiat currencies or existing networks; and (vi) general economic conditions and the regulatory environment relating to cryptocurrencies. Technology and Operational Failures. Business processes built on blockchain technology may be vulnerable to technology and operational failures. Accordingly, firms relying on such processes may need a robust business continuity plan and governance framework to mitigate risks. Bitcoin as a Model for Other Digital Assets. Certain clients will generally invest in Digital Assets which are an evolving, relatively new product and technology. The methods whereby each Digital Asset is created, secured, accessed and used may differ from one another. The risks and background related to Bitcoin, an early and prominent Digital Asset, are set forth below. Other Digital Assets may contain similar (or different) risks and vulnerabilities. In addition, creators of other Digital Assets may be able to leverage their understanding of Bitcoin’s history when generating new Digital Assets. Overview of Bitcoin, the Bitcoin Network and the Bitcoin Market. Presently, Bitcoin is a type of decentralized, virtual “cryptocurrency”, that functions without the intermediation of any central authority. Each individual Bitcoin unit exists as a digital file, based upon a mathematical proof, and is comprised of two numbers, or “keys”: the public key that encrypts a transaction value and the

private key that decrypts it. Bitcoin allows users to send payments within a decentralized, peer-topeer network, and does not require a central clearing house or financial institution clearing transactions. The smallest unit into which a Bitcoin can be divided is called the Satoshi: 1 Bitcoin contains 8 million Satoshi. Bitcoin-Qt, the original mathematical Bitcoin network source code and protocol, is believed to have been designed and created in 2009 by Satoshi Nakamoto (which is believed to be a pseudonym for a person or group of people, who have written the Bitcoin-Qt whitepaper and software application). Currently, Bitcoin is not represented by any official organization, government, or public or private authority, and the Bitcoin network does not rely on any government authority or financial institution to create, transmit or determine the value of Bitcoin. It is generally believed that Bitcoin originated independent of any foreign or domestic government authority or corporate influence. A number of known people have been thought to be Satoshi Nakamoto, although there is still much doubt about the true designer and creator of Bitcoin-Qt. The resulting ease of peer-to-peer transfers is expected to facilitate minimal, if any, transaction costs. Yet there are also entities, such as virtual currency service providers and exchanges, that provide third- party, intermediary services for the transfer, conversion or exchange of Bitcoin to other currencies or virtual currencies. Because Bitcoin is a virtual currency—a medium of exchange that functions like currency in accepted environments, but is not considered legal tender by any governmental authority— a person generally must have Internet access to connect to the Bitcoin network and obtain, transfer, access or use Bitcoin. Bitcoin Network. The “Bitcoin network” refers to the online platform through which Bitcoin is mined, validated and transmitted. Understanding the Bitcoin network requires an understanding of the terms “cryptography”, “blockchain” and “mining”. Cryptography. In the Bitcoin context, cryptography refers to the mathematical proofs on which any given Bitcoin is based. Because “mining” a Bitcoin requires the user to solve a complicated proof, the cryptography basis is intended to provide the Bitcoin network a high level of security. Such security, in turn, is designed to permit network users to control transactions and prevent doublespending (i.e., when a unit of virtual currency would be concurrently sent to and accepted by two different recipients). The Bitcoin network hosts (provides a forum for) the blockchain and Bitcoin mining. As explained below, these latter two concepts are necessary to create a consensus on the network about which transactions will be confirmed and considered valid. Blockchain. The blockchain is a chronologically ordered, public record of all validated Bitcoin transactions across the Bitcoin network. It is shared among all Bitcoin users. Each “block” in the “chain” (or entry in the record) contains and confirms many waiting transactions. The blockchain works as follows: Engaging in Bitcoin transactions requires a user to install or access on its computer or mobile device a Bitcoin software program that will allow the user to generate a digital Bitcoin account—commonly known as a “digital wallet” or “wallet”—in which to store Bitcoin, connect to the Bitcoin network, and purchase or sell, own, transfer, or receive Bitcoin. Users that have installed available Bitcoin-Qt must also make periodic software upgrades. Each Bitcoin wallet includes a unique address and verification system consisting of a “public key” and a “private key” which are linked mathematically to each other. A public key serves as an address for the digital wallet—similar to a bank account number. A user must provide its public key to the party initiating the transfer. The private key is a secret piece of data that proves the user is authorized to spend Bitcoin from a specific wallet—similar to a personal pin to confirm a transaction. It authorizes access to, and transfer of, the funds in the digital wallet to other users. Private key(s)

may be stored on a user’s computer or on remote servers. If a user fails to secure or make a backup of the public and private key relating to a digital wallet, or loses its private key, or the digital wallet containing the keys is deleted or hacked into, the user permanently loses access to the Bitcoin contained in the associated digital wallet, without any recourse to a centralized group or agency to assist in its recovery. Each Bitcoin user must “sign” transactions with a data code derived from entering the applicable private key into a “hashtag algorithm”. The hashtag algorithm produces a hash (or timestamp) which serves as a signature validation that the transaction has been authorized by the Bitcoin owner. Each timestamp includes the previous timestamp hash as input for its own hash. This dependency of one hash on another is what forms a chain, with each additional timestamp providing evidence that each of the previous timestamp hashes existed. Presently, each block on the blockchain contains a record of hundreds of validated transactions. Each validated transaction contains a unique identifier (i.e., a Bitcoin address/public key) that can be searched and located on the blockchain through Web sites like www.blockchain.com. It takes approximately ten minutes for each Bitcoin transaction to be confirmed by the network through the efforts of miners and a new block in the blockchain to be created. Each block that is added to the blockchain reduces the risk that a previous transaction will be reversed or that double spending has occurred. Mining. Bitcoin mining is the process of validating and adding transaction records to Bitcoin’s public ledger of past transactions (i.e., the blockchain). Each block is an independent mathematical proof which depends on the previous block. As an incentive to update the blockchain, Bitcoin miners may collect transaction fees for the transactions they confirm, along with newly created Bitcoin (i.e., rewards). Only the first miner to compute the proof is rewarded with Bitcoin, while the rest of the miners have to start over on a new block. Bitcoin supply is increased with every new block of transactions that is added to the blockchain. Currently, the reward is twenty-five (25) Bitcoin for each block that is added to the blockchain. The reward for solving a block is automatically adjusted–reduced by half for every 210,000 blocks mined–so that roughly every four years of operation of the Bitcoin network, half the amount of Bitcoin created in the prior four years are created. It is understood (but not guaranteed) that the total number of Bitcoin in existence will never exceed 21 million. Mining is currently very expensive and time-consuming, and miners must dedicate substantial resources to continuously power and cool devices. The mining reward system is designed to ensure that miners are compensated for their efforts and new Bitcoin enters into public circulation. The Bitcoin network’s mining protocol is intended to make it more difficult to solve for new blocks in the blockchain as the processing power dedicated to mining increases. Therefore, the Bitcoin mining process is designed to incentivize people to be efficient and use as little power as possible to create blocks and validate the transactions. Given the time and resources that must be dedicated to mining, miners may “pool” their efforts and act cohesively to combine their processing power to solve blocks. These efforts are called mining “pools”—and pool members generally split any resulting rewards based on the processing power they each contributed to solve for such blocks. Forking. If Bitcoin miners solve a block at approximately the same time, it causes a “fork” in the blockchain. The Bitcoin network software and protocol try to resolve forks by automatically giving priority to the longest blockchain in the fork. If forks are unresolved there are effectively two Bitcoin networks operating at the same time, each with its own version of the transaction history. This creates an increased risk of receiving a double-spend transaction, and a general systemic risk to the integrity and security of the Bitcoin network. To the extent that a significant majority of users and miners on the Bitcoin network install software that changes the Bitcoin network or properties of Bitcoin, including the irreversibility of transactions and limitations on the mining of new Bitcoin, the Bitcoin network would be subject to new protocols and software that may result in a “fork” of

the Bitcoin network, potentially adversely affecting Bitcoin’s value, the Bitcoin network and/or an investment in Bitcoin. Similarly, if less than a significant majority of users and miners on the Bitcoin network install such software, the Bitcoin network could “fork”, which may adversely affect Bitcoin’s value, the Bitcoin network and/or an investment in Bitcoin. To the extent that any temporary or permanent forks exist in the blockchain, Bitcoin’s value, the Bitcoin network and/or an investment in Bitcoin, may be adversely affected. On August 1, 2017 the Bitcoin blockchain experienced a hard “fork”, resulting in the creation of Bitcoin Cash (BCH), a version of Bitcoin with its own set of rules, updated technology and faster transaction speed. As Bitcoin Cash emerged from the same ledger as Bitcoin, Bitcoin holders received the same amount of Bitcoin Cash tokens after the split and, as a result, now hold both Bitcoin, which will continue to be recorded on the original Bitcoin blockchain, and Bitcoin Cash, which will be recorded on the new “forked” blockchain. The hard “fork” was the result of a disagreement regarding the optimal size of the blocks that make up the Bitcoin network (some users, merchants, businesses, investors and miners desired to increase the block size, so as to allow for greater transaction confirmation speed, while Bitcoin’s core developers desired to maintain the existing block size, so as to protect Bitcoin from potential hacks and more strongly preserve Bitcoin’s decentralized nature (as some miners would not install the new, updated, software)). The Bitcoin blockchain may experience additional hard “forks”, which may or may not have upgraded consensus rules that allow it to grow and scale. There is no guarantee that merchants, wallets or exchanges will support, or that a market will develop for, Bitcoin Cash and/or future Bitcoin tokens, which may also compete with Bitcoin (negatively affecting its value). In addition, hard “forks” may carry further risks, including, without limitation, (i) that Bitcoin networks heavily decline in value or that the combined value of the competing versions of Bitcoin is less than the value of a single Bitcoin network (particularly, if the “fork” is interpreted as a general failure to reach a consensus regarding the Bitcoin network), (ii) that developers, service providers and users choose one version of Bitcoin over another and (iii) that the division of mining power makes each Bitcoin blockchain slower and/or less secure. Mining Incentives. If rewards and transaction fees are not properly matched to the efforts of miners, miners may not have an adequate incentive to continue mining. Miners ceasing operations could reduce the collective processing power on the Bitcoin network, adversely affect the validation process for transactions, and, generally, make the network more vulnerable. Further, if a single miner or a mining pool gains a majority share in the Bitcoin network’s computing power, the integrity of the blockchain may be affected. A miner or mining pool could reverse Bitcoin transactions, make double-spend transactions, prevent confirmations or prevent other miners from mining valid blocks. Each of these scenarios could reduce confidence in the validation process or processing power of the network, and adversely affect Bitcoin’s value, the Bitcoin network and/or an investment in Bitcoin. As the number of Bitcoin awarded for solving a block in the blockchain decreases, the incentive for miners to continue to contribute processing power to the Bitcoin network may transition from a set reward to transaction fees. Either the requirement from miners of higher transaction fees in exchange for recording transactions in the blockchain or a software upgrade that automatically charges fees for all transactions may decrease demand for Bitcoin and prevent the expansion of the Bitcoin network to retail merchants and commercial businesses, resulting in a reduction in the net asset value. To the extent that any miners cease to record transactions in solved blocks, transactions that do not include the payment of a transaction fee will not be recorded on the blockchain until a block is solved by a miner who does not require the payment of transaction fees. Any such delays in the recording of transactions could result in a loss of confidence in the Bitcoin network, which could adversely impact Bitcoin’s value, the Bitcoin network and/or an investment in Bitcoin.

Changes to Underlying Protocol. In general, the underlying software protocols which govern the operation of Digital Asset networks are open source and anyone can use, copy, modify, and distribute them. The Investment Adviser makes no guarantee of the functionality, security, or availability of underlying protocols; (ii) that some underlying protocols are subject to consensusbased proof of stake validation methods which may allow, by virtue of their governance systems, changes to the associated blockchain or digital ledger (“Governance Modifiable Blockchains”), and that any transaction made by the Investment Adviser validated on such Governance Modifiable Blockchains may be affected accordingly; and (iii) that the underlying protocols are subject to sudden changes in operating rules (a/k/a “forks”), and that such forks may materially affect the value, function, and/or even the name of Digital Assets stored in client investors’ accounts. In the event of a fork, the Investment Adviser may temporarily suspend certain clients’ operations (with or without notice to client investors) and the Investment Adviser may, in its sole discretion, decide whether or not to support (or cease supporting) either branch of the forked protocol entirely. Clients assume absolutely no liability, obligation or responsibility whatsoever in respect to the operation of underlying software protocols, transactions affected by Governance Modifiable Blockchains, or an unsupported branch of a forked protocol and, accordingly, client investors acknowledges and assumes the risk of the same. Changes to underlying DAPP protocols may carry additional, specific risks. DAPPs are typically based on protocols that govern peer-to-peer interactions between computers connected to a Digital Asset’s network. Generally, the code that sets forth a Digital Asset protocol is informally managed by a development team known as the core developers. A Digital Asset’s core developers, miners, and/or users (each such core group in respect of a particular Digital Asset) (the “Community”) can propose amendments to a network’s source code through one or more software upgrades that alter such Digital Asset’s protocols, the software that govern its network and the properties of the Digital Asset itself, including, but not limited to, the irreversibility of transactions and limitations on the mining/creation of new Digital Asset units. To the extent that a majority of a Community installs such software upgrade(s), such Digital Asset’s network could be subject to new protocols and software that may adversely affect the Fund’s investment and trading activities. If less than a majority of a Community installs such software upgrade(s), such Digital Asset’s network could “fork”. Many digital currencies and Digital Assets are open source projects and, although there may be an influential group of leaders in a specific Community, there may be no official developers or group of developers that formally control the applicable network. For many digital currencies and Digital Assets, any individual can download the applicable network software and make any desired modifications, which are proposed to the relevant Digital Asset’s Community through software downloads and upgrades. However, the Community must usually consent to those software modifications by downloading the altered software or upgrade that implements the changes; otherwise, the changes do not become a part of that network. A developer or group of developers could potentially propose a modification to a network that is not accepted by the applicable Community, but that is nonetheless accepted by a substantial portion of such Community. In such a case, a “fork” in the blockchain could develop and two separate networks could result, one running the pre-modification software program and the other running the modified version (i.e., a second such network in respect of the same Digital Asset). Such a fork in the blockchain typically would be addressed by Community-led efforts to merge the forked blockchains. This kind of split in a network could materially and adversely affect the value of client investments and, in the worst-case scenario, harm the sustainability of the applicable Digital Asset’s economy. Oracle Risks and Flash Loan Attacks. The clients are subject to various risks associated with the oracles upon which DAPPs in which a client may directly or indirectly invest rely. DAPPs utilize smart contracts to take information in as an input, process that information through the rules defined in the computer code, and then execute certain actions, such as Digital Assets transactions, which

are programmed into smart contracts. Oracles send external data to smart contracts (e.g., the price of a given Digital Asset at a point in time), and they are generally used by DAPPs that rely on outside data to function. If one can manipulate the price of a Digital Asset for the oracle upon which a lending DAPP depends, one can exploit that flaw and generate a profit at the direct expense of other users. This phenomenon is often seen in combination with “flash loan attacks”—where a user abuses the ability to open an uncollateralized loan on the condition that the loan be repaid within the same transaction—and can negatively affect the clients’ returns. Virtual Currency Exchanges. Virtual currency exchanges are third-party service providers that convert Bitcoin to fiat currencies (i.e., currency a government considers to be legal tender) or other virtual currencies. Bitcoin are bought, sold, and traded with publicly disclosed (but often-changing) valuations on virtual currency exchanges, where the majority of Bitcoin buying and selling activity occurs. Virtual currency exchanges provide the most data with respect to prevailing valuations of Bitcoin. Market participants can choose which exchange on which to buy or sell Bitcoin, although these exchanges may charge significant fees for processing transactions. A virtual currency exchange that conducts business in the United States is subject to federal and state regulatory requirements. Bitcoin Service Providers. Several companies and financial institutions provide services related to the buying, selling, payment processing and storing of virtual currency (i.e., banks, accountants, exchanges, digital wallet providers, and payment processors). Certain clients expect the number of service providers to increase as the Bitcoin network (or other virtual currency networks) continue(s) to grow. However, there is no assurance that the virtual currency market, or the service providers necessary to accommodate it, will continue to support Bitcoin or other types of virtual currency, continue in existence or grow. Further, there is no assurance that the availability of and access to virtual currency service providers will not be negatively affected by government regulation or supply and demand of virtual currency or Bitcoin. Accordingly, companies or financial institutions that currently support virtual currency may not do so in the future. Bitcoin Investment Market. Private and professional investors and speculators invest and trade in Bitcoin. These market participants may range from exchange-traded-funds, private investment funds, brokers and day-traders. Certain activity involving Bitcoin may require approvals, licenses or registration, which may serve as a barrier to entry of investors, thereby limiting the market for Bitcoin. There is no assurance that the investment market for Bitcoin will continue to grow. Anonymity and Illicit Use. Although Bitcoin transaction details are logged on the blockchain, a buyer or seller of Bitcoin may never know to whom the public key belongs or the true identity of the party with whom it is transacting. Public key addresses are randomized sequences of 27-34 alphanumeric characters that, standing alone, do not provide sufficient information to identify users. Transacting with a counterparty making illicit use of Bitcoin could have a material adverse effect on the clients. On October 2, 2013, the FBI seized the domain name for the infamous “Silk Road” website—an online black marketplace for illicit goods and services—and arrested its alleged founder, Ross William Ulbricht. The website operated through multiple systems of strict anonymity and secrecy, using Bitcoin as the exclusive means of payment for illicit goods and services. As part of the raid, the FBI also seized over 50,000 Bitcoin from accounts on Silk Road, which were worth approximately $3.6 million at the time. In November 2022, the U.S. Department of Justice seized more than $3.36 billion in Bitcoin from an account linked to the Silk Road website. On January 21, 2025, President Donald Trump pardoned Ross Ulbricht.

Over the years, FinCEN has conducted several enforcement actions against digital currency exchanges, assessing significant civil money penalties for, among other things, failing to register as money service business and failure to adopt and implement a risk-based anti-money laundering program and file SARs. In certain cases, the founders/operators of such exchanges have faced criminal liability, as well. For example, on January 27, 2014, the CEO of BitInstant (the New York-based Bitcoin exchange service) was arrested on charges of money laundering and operating an unlicensed money transmitting business. On July 24, 2017, FinCEN assessed a $110 million civil money penalty against BTC-e, a/k/a Canton Business Corporation (“BTC-e”), an internet-based and foreign-located digital currency exchange founded in 2011, for failing to register as a Money Services Business and facilitating crimes like drug sales and ransomware attacks. FinCEN also assessed a separate $12 million fine against BTC-e’s owner, Alexander Vinnik. Further, on October 19, 2020, FinCEN assessed a civil money penalty against Larry Dean Harmon, as the primary operator of Helix, for anti-money laundering program failures, including its facilitation of transactions with darknet marketplaces, ransomware, child exploitation websites, and unregistered money services businesses. See In the Matter of Larry Dean Harmon, Assessment of Civil Money Penalty Number 2020-2 (Oct. 19, 2020). In 2023, FinCEN assessed a $3.4 billion civil money penalty against Binance Holdings Ltd. and several of its affiliates. Binance’s founder and chief executive officer also pleaded guilty to failing to maintain an effective anti-money laundering program and was sentenced to 4 months in prison. Further, identifying users can be made even more difficult where a user utilizes a tumbling or mixing services (e.g., Tornado Cash) to further obfuscate transaction details. In addition, FinCEN has previously notified financial institutions on the importance of practicing increased vigilance in preventing illicit actors from using Digital Assets to evade sanctions. See U.S. Dep’t of Treasury, FinCEN FIN-2022-Alert001, FinCEN Advises Increased Vigilance for Potential Russian Sanctions Evasion Attempts (Mar. 7, 2022). In April 2023, FinCEN issued a risk assessment about the role decentralized finance and digital assets play in facilitating unlawful transactions. See Illicit Finance Risk Assessment of Decentralized Finance, Dep’t of Treasury (April 2023). On December 6, 2023, the Founder of Bitzlato, Anatoly Legkodymov, pled guilty to operating a money transmitting business that transported and transmitted illicit funds. See E.D.N.Y. Docket No. 23-CR-496 (ENV). Development and Acceptance of Digital Assets and Bitcoin. As a relatively new product and technology, Digital Assets and Bitcoin are not yet widely adopted as a means of payment for goods and services. Banks and other established financial institutions may refuse to process funds for Digital Asset and Bitcoin transactions, process wire transfers to or from Digital Asset and Bitcoin exchanges, Digital Asset-related and Bitcoin-related companies or service providers, or maintain accounts for persons or entities transacting in Digital Assets and Bitcoin. Market capitalization for Digital Assets and Bitcoin as a medium of exchange and payment method may always be low. Further, Digital Asset and Bitcoin use as an international currency may be hindered by the fact that it may not be considered as a legitimate means of payment or legal tender in some jurisdictions. To date, speculators and investors seeking to profit from either short- or long-term holding of Digital Assets and Bitcoin drive much of the demand for it, and competitive products may develop which compete for market share. Although Bitcoin, as the first decentralized, digital currency, currently enjoys the majority of the market share, several other digital and cryptocurrencies have since emerged, including Ripple, Litecoin, Avalanche and Polkadot. Further, certain Digital Assets or payment systems may be the subject of a U.S. or foreign patent application (i.e., JP Morgan Chase Bank’s patent application for “Alt-Coin” with the United States Patent & Trademark Office), successfully patented, or, alternatively, mathematical Digital Asset network source codes and protocols may be patented or

owned or controlled by a public or private entity. Certain clients could be adversely impacted if Digital Assets or Bitcoin fail to retain their market share or to expand into retail and commercial markets. Any of these scenarios may increase Bitcoin’s volatility or decrease its value (price). Development and Acceptance of the Digital Asset and Bitcoin Networks. The growth and use of Digital Assets generally is subject to a high degree of uncertainty. Indeed, the future of the industry likely depends on several factors, including, but not limited to: (a) economic and regulatory conditions relating to both fiat currencies and Digital Assets, including digital currencies; (b) government regulation of the use of and access to Digital Assets, including digital currencies; (c) government regulation of Digital Asset and digital currency service providers, administrators or exchanges; (d) the domestic and global market demand for—and availability of—other forms of Digital Asset/digital currency or payment methods; and (e) uniquely regarding Bitcoin, the security, integrity and adoption of the Bitcoin network source code protocol. Any slowing or stopping of the development or acceptance of Digital Assets or a Digital Asset network or Bitcoin or the Bitcoin network, may adversely affect an investment in a client. Transaction Cost and Gas Fee Risk. Transactions executed by the Funds on networks require payment of variable “gas” or transaction fees. These costs can fluctuate widely depending on network congestion, demand, and technical updates. Elevated gas fees may significantly increase transaction costs, reduce returns on investment, or delay timely execution of trades and rebalancing activities. In extreme conditions, transaction fees may exceed the value of the underlying asset being transferred. Centralized Exchange and Custodial Dependence Risk. The Funds rely on Digital Asset exchanges, custodians, and wallet providers to trade and safeguard their holdings. Many such entities operate in lightly regulated or foreign jurisdictions and may be exposed to cybersecurity incidents, fraud, insolvency, or government enforcement actions. The failure or closure of a major third-party service provider could prevent the Funds from accessing their assets or executing trades, resulting in substantial losses. Market Volatility. Volatile market conditions at various times have had a dramatic effect on private investments. In addition, terrorist attacks and other acts of violence or war may affect the operations and profitability of certain clients’ portfolio companies. Such events could cause consumer confidence and spending to decrease or result in increased volatility in the U.S. and worldwide financial markets and economy. They also could result in a continuation of the current economic uncertainty in the U.S. or abroad. Any of these occurrences could have a significant impact on the operating results and revenues of a client’s portfolio companies and, in turn, on the return of a client’s investments. Early-Stage Token Offerings: New Digital Assets; SAFTs. Early-Stage Token Offerings occur in respect of Digital Assets that have not been tested or used in the marketplace. As a result, the risk that Digital Assets obtained by a client through Early-Stage Token Offerings will have imperfections and/or be susceptible to hackers is greater than that of Digital Assets that have already been established. In addition, the success or failure of the particular Digital Asset offered through an Early-Stage Token Offering is highly uncertain, as there is a risk that such Digital Assets will not develop a following. As described above, certain clients may participate in Early-Stage Token Offerings (or pre-EarlyStage Token Offerings) through SAFTs. As SAFTs are entered into in respect of Early-Stage Token Offerings which have yet to occur, there is a risk that the Early-Stage Token Offering will not occur or that the SAFT counterparty will otherwise default in its delivery of the Early-Stage Token Offering token.

Early-Stage Token Offerings: Liquidity. Liquidity in the Early-Stage Token Offering market is limited. Accordingly, in the event that substantial withdrawal requests are made by investors, a client may have difficulty liquidating its positions in order to satisfy such withdrawals. It is unclear how long the current situation (i.e., limited liquidity in the Early-Stage Token Offering market) will continue, and how such illiquidity will affect the particular assets in a client’s portfolio. Early-Stage Token Offerings: Rule 144. Rule 144 is an SEC rule that provides a securities law safe harbor for the public resale of restricted or control securities, but only if certain conditions are met (such as holding period requirements, which are typically six months to one year). In the event that an Early-Stage Token Offering held by a client is a security, the client will be restricted from trading except through a private placement or after satisfying the Rule 144 holding period. Accordingly, the number of trading counterparties will be less than would be the case for a Digital Asset that is not a security (and thus not subject to the same restrictions on resale). Any sale of securities that violate securities laws may be subject to rescission of the transaction by the purchaser. Early-Stage Token Offerings: Participation. Participating in Early-Stage Token Offerings may require certain clients to pledge Digital Assets. The trading platforms used by Early-Stage Token Offerings are relatively new and largely unregulated and may therefore be more exposed to theft, fraud and failure. For example, in June 2017, CoinDash, an Israeli startup, planned to raise capital by selling its own digital tokens in exchange for cryptocurrency Ethereum. Thirteen minutes into the token sale, an “unknown perpetrator” hacked CoinDash’s website and changed the address for sending Ethereum- based investments to a fake one, diverting millions of dollars in Ethereum-based investments to the attacker. In general, Early-Stage Token Offering trading platforms are currently start-up businesses, with limited operating history and no publicly available financial information. Consequently, if an Early-Stage Token Offering trading platform experiences theft, fraud or failure, the Early-Stage Token Offering operators may be unable to replace missing Digital Assets or seek reimbursement for any theft of Digital Assets, adversely affecting investors and a client. Early-Stage Token Offerings: Concentration. As Early-Stage Token Offerings may arise at unpredictable intervals, there is a risk that certain clients’ investments may become concentrated in a single (or limited number of) Digital Asset(s). Such limited diversification may result in the concentration of risk, which, in turn, could expose a client to losses disproportionate to market movements in general if there are disproportionately greater adverse price movements with respect to such Digital Asset(s). In addition, a client may be forced to hold fiat currency for significant periods of time (until the occurrence of an Early-Stage Token Offering opportunity). Early-Stage Token Offerings: Promise to Hold or Sell; Transferability. Digital Assets acquired by certain clients in connection with Early-Stage Token Offerings may also entail promises to sell within, or hold for, a specified time period. As a result, a client may be forced to sell an investment at an inopportune time, or hold an investment at times where it would otherwise be advantageous to sell. In addition, to the extent that clients invest in a SAFT, the SAFT may not be transferable. Early-Stage Token Offerings: Valuation. The Investment Adviser generally expects that the initial purchase of an Early-Stage Token Offering will occur at a substantial discount to the price expected in the event the Digital Asset (offered through the Early-Stage Token Offering) is successful. Digital Assets purchased by a client will generally be valued at cost until active trading in such Digital Assets develops. Accordingly, while investors who invest in a client prior to the emergence of such active trading will receive the potential benefit of purchasing such Digital Assets at expected discounted prices, any withdrawal proceeds paid to investors who withdraw from a client prior to the emergence of such active trading will generally reflect the cost of the Early-Stage Token

Offering and not the expected trading price of such Digital Assets on any active exchange or other market. The value of an Early-Stage Token Offering held by a client (prior to active trading) may also be adjusted based on various factors. Early-Stage Token Offerings: Fraudulent Early-Stage Token Offerings. Early-Stage Token Offering campaigns in which certain clients participate are unregulated and may turn out to be fraudulent. There is no guarantee that funds lost due to such fraudulent actions will be recovered by a client. Early-Stage Token Offerings: Potential SEC Involvement. As further discussed below, the SEC has advised that, depending on the facts and circumstances of each individual Early-Stage Token Offering, the Digital Assets that are offered or sold in an Early-Stage Token Offering may be deemed securities. See http://www.sec.gov/litigation/investreport/34-81207.pdf; see also http://www.investor.gov/additional-resources/news-alerts/alerts-bulletins/investor-bulletin-initialcoin-offerings. Accordingly, Early-Stage Tokens may be considered securities for purposes of U.S. laws and regulations. While it remains uncertain whether the SEC will take any action concerning a particular Early-Stage Token Offering, even if the SEC does not take action with respect to EarlyStage Token Offerings held by a client, any actions taken by the SEC with respect to Early-Stage Token Offerings generally may potentially impact the value and liquidity of Early-Stage Token Offerings in the client’s portfolio. As a SAFT is generally considered an “investment contract”, and thus a security, dealing in SAFTs requires compliance with the securities laws, and SAFTs may be subject to the risks described herein with respect to securities law compliance. There is no assurance that the offer, sale or purchase of any SAFT will be deemed “compliant” by any regulatory authority. Early-Stage Token Offerings: Ineligibility. Certain clients may be ineligible to participate in certain Early-Stage Token Offerings (particularly, Early-Stage Token Offerings issued by non-U.S. sponsors that limit participation to non-U.S. persons or entities). While a client may seek to participate in Early- Stage Token Offerings through a non-U.S. subsidiary, there is no guarantee that a non-U.S. subsidiary of a client will be permitted to take part in an Early-Stage Token Offering that generally limits participation to non-U.S. persons or entities. Digital Asset/ Digital Currency Exchanges: General. The exchanges on which Digital Assets trade are relatively new and largely unregulated and may therefore be more exposed to theft, fraud and failure than established, regulated exchanges for other products. Digital Asset exchanges may be start-up businesses with no institutional backing, limited operating history and no publicly available financial information. Exchanges generally require fiat currency funds to be deposited in advance in order to purchase Digital Assets, and no assurance can be given that those deposit funds can be recovered. Additionally, upon sale of Digital Assets, fiat currency proceeds may not be received from the exchange for several business days. The participation in exchanges requires users to take on credit risk by transferring Digital Assets from a personal account to a third-party’s account. Certain clients will take the credit risk of an exchange with every transaction. Digital Asset exchanges may impose daily, weekly, monthly or customer-specific transaction or distribution limits or suspend withdrawals entirely, rendering the exchange of Digital Assets for fiat currency difficult or impossible. Additionally, Digital Asset prices and valuations on Digital Asset exchanges have been volatile and subject to influence by many factors including the levels of liquidity on exchanges and operational interruptions and disruptions. The prices and valuation of Digital Assets remain subject to any volatility experienced by Digital Asset exchanges, and any such volatility can adversely affect an investment in certain clients.

Digital Asset exchanges are appealing targets for cybercrime, hackers and malware. It is possible that while engaging in transactions with various Digital Asset exchanges located throughout the world, any such exchange may cease operations due to theft, fraud, security breach, liquidity issues, or government investigation. In addition, banks may refuse to process wire transfers to or from exchanges. Over the past several years, many exchanges have, indeed, closed due to fraud, theft (e.g., Mt. Gox voluntarily shut down because it was unable to account for over 850,000 Bitcoin), government or regulatory involvement, failure or security breaches (e.g., the voluntary temporary suspensions by Mt. Gox of cash withdrawals due to distributed denial of service attacks by malware and/or hackers), or banking issues (e.g., the loss of Tradehill’s banking privileges at Internet Archive Federal Credit Union). In 2018 alone, Digital Asset exchanges based in Japan (Coincheck), Italy (Bitgrail), India (Coinsecure) and South Korea (Coinrail) were reported to have experienced major hacks, resulting in losses of approximately $650,000,000. In addition, significant hacks have occurred in 2019 and 2020, including a hack on a Singapore based cryptocurrency exchange KuCoin resulting in a loss of more than $150,000,000. In 2021, cryptocurrency platform Poly Network suffered a hack of tokens worth more than $600,000,000. Overall, more than 150 blockchain hacking incidents took place in 2021, with nearly $7 billion in funds lost. In February 2022, Wormhole, one of the most popular bridges linking the Ethereum and Solana blockchains, lost about $320,000,000 in a hack. On February 21, 2025, Bybit, one of the world’s largest cryptocurrency exchanges, suffered an unprecedented cyberattack, resulting in the theft of approximately USD 1.5 billion in Ethereum tokens. Exchanges may even shut down or go offline voluntarily, without any recourse to investors. As a result, the price of Bitcoin has decreased drastically following such incidents, adversely affecting all Bitcoin holders. In many of these instances, the customers of such exchanges have not been compensated or made whole for the partial or complete loss of their account balances. An exchange may be unable to replace missing Digital Assets or seek reimbursement for any theft of Digital Assets, adversely affecting investors and an investment in a client. Moreover, Digital Asset exchanges are subject to the risk of their own insolvency as well as of insolvency of exchanges, service providers and other companies with which they work in the Digital Asset space. In the first half of 2022, Luna (and related stablecoin TerraUSD) collapsed leading to widespread flow-on-distress for some of the biggest participants in the Digital Asset markets. Shortly after Luna’s collapse, each of Celsius Networks, Voyager Digital and Three Arrows Capital declared bankruptcy, resulting in a loss of confidence in participants of the cryptoeconomy and negative publicity surrounding crypto more broadly. By late 2022, FTX, the third largest Digital Asset exchange by volume at the time, halted customer withdrawals amid rumors of the company’s liquidity issues and likely insolvency. Shortly thereafter, FTX’s CEO resigned and FTX and several affiliates of FTX filed for bankruptcy. Several other entities in the Digital Asset industry filed for bankruptcy following FTX’s bankruptcy filing, such as BlockFi Lending LLC (“BlockFi”) and Genesis Global Holdco, LLC, both of which are Digital Asset lenders. In response to these events, the Digital Asset markets have experienced extreme price volatility and several other entities in the Digital Asset industry have been, and may continue to be, negatively affected, further undermining confidence in Digital Asset markets. Any financial, security or operational difficulties experienced by such exchanges may result in an inability of the clients to recover fiat currency or Digital Assets being held by the exchange, or to pay investors upon withdrawal, or a decrease in the value of the Digital Assets held by the Funds. The 2022 bankruptcy of FTX mentioned above, for example, caused investors in FTX to lose millions of dollars. Further, the clients may be unable to recover Digital Assets awaiting

transmission into or out of the client portfolios, all of which could adversely affect an investment in the client portfolios. These disruptions in the Digital Asset markets have also negatively impacted the liquidity of Digital Assets because certain entities affiliated with defunct exchanges historically engaged in significant trading activity but have now curtailed operations. A lack of stability in the Digital Asset exchange market and the closure or temporary shutdown of Digital Asset exchanges due to insolvency, business failure, hackers or malware, government-mandated regulation, or fraud, undermines confidence in Digital Asset networks and may result in continued significant volatility in Digital Asset prices. In any insolvency proceeding involving Digital Assets, courts and/or administrators as applicable, will face numerous questions of first impression regarding how to treat various portfolio investments in the Digital Asset exchanges. There are numerous Digital Asset exchanges and each is formed and set up under different legal regimes and with different contractual custodial commitments and obligations to their customers. Depending on the precise nature of such customer relationships, Digital Assets held in a Digital Asset exchange may or may not be considered to be the property of a bankruptcy estate. Even if Digital Asset exchanges are required by applicable law or contractual obligations to keep customer assets isolated and segregated, due to limited oversight, even with diligence, it is often hard to confirm a specific Digital Asset exchange’s level of compliance and there is significant risk those exchanges will not comply with these contractual or legal custodial commitments. Accordingly, customers who have Digital Assets purportedly held in custody by a Digital Asset exchange, including the clients, could be treated as general unsecured creditors and ultimately recover little or nothing after more senior creditors are satisfied in a subsequent insolvency proceeding. Even if Digital Assets held in custody by Digital Asset exchanges are deemed to be customer property and not property of the bankruptcy estate, there may be a significant delay in a Digital Asset exchange returning investors’ property whereby the passage of time and decline in value of the Digital Asset prevents the clients from properly exiting an investment position. Such Digital Assets, even if deemed customer property, could have also been improperly commingled with other assets and diminished during such commingling, which could lead to a reduced recovery for customers. There are no clear laws on how Digital Assets should be treated in bankruptcy. In addition to the threshold question of whether an exchange’s holdings of Digital Assets could be deemed property of the estate, novel issues of whether to classify Digital Assets as securities, commodities, currencies or something else could have a material effect on the applicability of safe harbor defenses to protect against potential avoidance actions by debtors. Relatedly, Digital Asset transactions involving smart contracts create complications for determining the applicable transfer date for clawback actions because they are self-executing. The applicable transfer date can change how Digital Assets are valued for purposes of avoidance actions, which is of critical importance given how rapidly such Digital Assets can fluctuate in value. Additionally, to the extent that the Digital Asset exchanges representing a substantial portion of the volume in Digital Asset trading are involved in fraud or experience security failures or other operational issues, such Digital Asset exchanges’ failures may result in losses or less favorable prices of Digital Assets or may adversely affect the clients, their operations and investments, or the Fund investors. Further, certain SEC officials have made statements that the platforms on which Digital Assets trade may be required to register and be regulated like traditional regulated exchanges. These statements suggest an additional regulatory focus on Digital Asset trading and lending platforms by the SEC may impact the platforms on which the clients trade or the availability of trading platforms

generally. See https://www.sec.gov/news/speech/gensler-remarks-crypto-markets-040422. In February 2022, the SEC engaged in enforcement in a first-of-its-kind action against BlockFi for failing to register the offers and sales of its retail crypto lending product and violating registration provisions of the Investment Company Act of 1940 (the “Company Act”). The order imposed a $50 million civil money penalty and $50 million in fines to be paid to 32 states for similar charges. The SEC’s BlockFi order suggests that certain Digital Asset platforms and products may be subject to the federal securities laws. If additional crypto lending platforms and products are deemed subject to the federal securities laws and regulations, the clients or the Digital Assets exchanges or platforms on which they trade may be required to comply with certain relevant federal securities laws and regulations and associated compliance costs could adversely affect an investment in the client portfolios. To the extent the Investment Adviser’s trading and lending platform is required to register and be regulated like a traditional regulated exchange, such registration and compliance costs could adversely affect its operations and indirectly, the clients. Digital Asset/Exchanges: Limited Exchanges on Which to Trade. Certain clients may trade Digital Assets on a limited number of Digital Asset exchanges (and potentially only a single exchange) either because of actual or perceived counterparty or other risks related to a particular exchange. Trading on a single exchange may result in less favorable prices and decreased liquidity for a client and therefore could have an adverse effect on a client and the investors. Digital Asset and Digital Currency Exchanges: Non-U.S. Operations. Digital Asset and Bitcoin exchanges may operate outside of the United States. Certain clients may have difficulty in successfully pursuing claims in the courts of such countries or enforcing in the courts of such countries a judgment obtained by the client in another country. In general, certain less developed countries lack fully developed legal systems and bodies of commercial law and practices normally found in countries with more developed market economies. These legal and regulatory risks may adversely affect certain clients and their operations and investments. Digital Asset/Exchanges: Risks of Buying or Selling Digital Assets. Certain clients may transact with private buyers or sellers or Digital Asset exchanges. Such clients will take on credit risk every time that they purchase or sell Digital Assets, and such clients’ contractual rights with respect to such transactions may be limited. Although a client’s transfers of Digital Assets or fiat currency will be made to or from a counterparty which the Investment Adviser believes is trustworthy, it is possible that, through computer or human error, or through theft or criminal action, certain clients’ Digital Assets or fiat currency could be transferred in incorrect amounts or to unauthorized third parties. To the extent that a client is unable to seek a corrective transaction with such third party or is incapable of identifying the third party which has received a client’s Digital Assets or fiat currency (through error or theft), a client will be unable to recover incorrectly transferred Digital Assets or fiat currency, and such losses will negatively impact certain clients. Certain Digital Asset exchanges may place limits on certain clients’ transactions, or certain clients may be unable to find a willing buyer or seller of Digital Assets. To the extent a client experiences difficulty in buying or selling Digital Assets, investors may experience delays in subscriptions or payment of withdrawal proceeds, or there may be delays in liquidation of a client’s Digital Assets— adversely affecting the net asset value of a client. Financial Technology Risk. Companies that are developing financial technologies that seek to disrupt or displace established financial institutions generally face competition from much larger

and more established firms. Fintech companies may not be able to capitalize on their disruptive technologies if they face political and/or legal attacks from competitors, industry groups or local and national governments. Laws generally vary by country, creating some challenges to achieving scale. A fintech company may not currently derive any revenue, and there is no assurance that a fintech company will derive any revenue from innovative technologies in the future. With regard to any DAPPs’ products and internal systems, such DAPPs generally rely on software that is highly technical and complex, and a DAPPs’ internal systems depend on the ability of such software to store, retrieve, process, and manage immense amounts of data. Such software may now or in the future contain undetected errors, bugs, or vulnerabilities. Some errors may only be discovered after the code has been released for external or internal use. Errors or other design defects within such software may result in a negative experience for users and marketers who use the DAPPs’ products, delay product introductions or enhancements, or result in measurement or billing errors. Any errors, bugs, or defects discovered in the DAPPs’ software could result in damage to such DAPPs’ reputations, loss of users, loss of revenue, or liability for damages, any of which could adversely affect such DAPPs’ business and financial results, and could result in losses for the Fund. Digital Assets Treasury Companies Generally. The Funds may seek to invest in DAT companies; however, DAT companies may have operating objectives that go beyond DAT holdings, and there can be no assurance that those traditional operations will be successful. A significant decrease in the value of Digital Assets could adversely affect the ability of DAT companies to satisfy their financial obligations. If the core business of a DAT company does not generate cash flow in the future sufficient to satisfy its financial obligations, the DAT company will be required to fund its obligations using equity or debt financings. The DAT company’s ability to obtain equity or debt financing may in turn depend on, among other factors, the value of its Digital Asset holdings, investor sentiment and the general public perception of Digital Assets. A significant decline in the market value of a DAT company’s Digital Asset holdings or negative shift of public perception of Digital Assets may create liquidity and credit risks and, as a result, adversely impact the DAT company’s ability to secure sufficient equity or debt financing to satisfy its financial obligations, including its debt and cash dividend obligations. DAT companies are exposed to various risks as a result of holding Digital Assets. Historical financial statements do not reflect the potential variability in earnings that a DAT company may experience in the future as a result of its Digital Asset holdings. A DAT company’s holding of Digital Assets could significantly impact its financial results. DAT companies are a relatively new concept and the strategy of holding Digital Assets in corporate treasury strategies has not been tested over an extended period of time or under different market conditions. If Digital Asset prices were to decrease or the strategy otherwise proves unsuccessful, a DAT company’s financial condition, results of operations, and the market price of its listed securities would be materially adversely impacted. DAT companies are subject to risks in the Digital Asset investment market. Market volatility may impact a Fund’s liquidity timing related to DAT company investments affected by market conditions. Private and professional investors and speculators invest and trade in Digital Assets. These market participants may range from exchange-traded-funds, private investment funds, brokers and day-traders. Certain activity involving Digital Assets may require approvals, licenses or registration, which may serve as a barrier to entry for investors, thereby limiting the market for Digital Assets. There is no assurance that the investment market for Digital Assets will continue to grow. A DAT Company may transact with private buyers or sellers or virtual currency exchanges. A DAT company will take on credit risk every time it purchases or sells Digital Assets, and its contractual rights with respect to such transactions may be limited. Although a DAT company’s transfers of Digital Assets or cash will be made to or from a counterparty which the DAT company believes is trustworthy, it is possible that,

through computer or human error, or through theft or criminal action, such DAT company’s Digital Assets or cash could be transferred in incorrect amounts or to unauthorized third parties. To the extent that a DAT company is unable to seek a corrective transaction with such third party or is incapable of identifying the third party which has received such DAT company’s Digital Assets or cash (through error or theft), such DAT company will be unable to recover incorrectly transferred Digital Assets or cash, and such losses will negatively impact the DAT company. If a DAT company invests in a Digital Asset that is not classified as a security for U.S. federal securities law purposes and such Digital Asset is subsequently reclassified as a security, such reclassification could lead to such DAT company being classified as an “investment company” under the Company Act, which would subject such DAT company to significant additional regulatory controls. If such Digital Asset is determined to be a security, the additional regulatory restrictions imposed by such determination could adversely affect the market price of the Digital Asset and in turn adversely affect the market price of such DAT company’s listed securities. Digital Asset ETFs. Digital Asset ETFs track the performance of an underlying Digital Asset. As of August 2025, only Bitcoin and Ethereum ETFs are permitted by the SEC. The SEC is currently reviewing applications for a Solana ETF and may do so for other Digital Assets in the future. Investors may view Digital Asset ETFs as an alternative to investing in Digital Assets directly. If the general sentiment pushes investors towards Digital Asset ETFs instead of investing in Digital Assets directly, this could have an adverse effect on the Fund. PIPE Transactions. Private investments in public companies whose stocks are quoted on stock exchanges or which trade in the over-the-counter securities market, a type of investment commonly referred to as a “PIPE” transaction, may be entered into with smaller capitalization public companies, which will entail business and financial risks comparable to those of investments in the publicly-issued securities of smaller capitalization companies, which may be less likely to be able to weather business or cyclical downturns than larger companies and are more likely to be substantially hurt by the loss of a few key personnel. In addition, PIPE transactions will generally result in clients acquiring either restricted stock or an instrument convertible into restricted stock. As with investments in other types of restricted securities, such an investment may be illiquid. The clients’ ability to dispose of securities acquired in PIPE transactions may depend on the registration of such securities for resale. Any number of factors may prevent or delay a proposed registration. Alternatively, it may be possible for securities acquired in a PIPE transaction to be resold in transactions exempt from registration in accordance with Rule 144 under the Securities Act, or otherwise under the U.S. federal securities laws. There can be no guarantee that there will be an active or liquid market for the stock of any small capitalization company due to the possible small number of stockholders. As a result, even if the clients are able to have securities acquired in a PIPE transaction registered or sell such securities through an exempt transaction, the clients may not be able to sell all the securities on short notice, and the sale of the securities could lower the market price of the securities. There is no guarantee that an active trading market for the securities will exist at the time of disposition of the securities, and the lack of such a market could hurt the market value of the clients’ investments. Initial Public Offerings. Investments in initial public offerings (or shortly thereafter) often involve higher risks than investments issued in secondary public offerings or purchases on a secondary market due to a variety of factors, including the limited number of shares available for trading, unseasoned trading, lack of investor knowledge of the issuer and limited operating history of the issuer. In addition, some companies in initial public offerings are involved in relatively new industries or lines of business, which may not be widely understood by investors. Some of these companies may be undercapitalized or regarded as developmental stage companies, without revenues or operating income, or the near-term prospects of achieving them. These factors may contribute to substantial price volatility for such securities and, thus, for the value of the clients’ DAT interests. Additionally, in connection with certain initial public offerings, clients may be issued restricted securities that cannot be disposed of during the applicable restricted period. As a result, clients may be required to hold such investments despite adverse price movements.

Investments in New Technologies (Machine Learning Technology and Artificial Intelligence). Companies in the machine learning technology and artificial intelligence industries may be subject to significant competitive pressures, such as aggressive pricing, new market entrants, competition for market share, short product cycles due to an accelerated rate of technological developments and the potential for limited earnings and/or falling profit margins. These companies also face the risks that new services, equipment or technologies will not be accepted by consumers and businesses or will become rapidly obsolete. These factors can affect the profitability of these companies and, as a result, the value of their securities. Also, patent protection is integral to the success of many companies in these industries, and profitability can be affected materially by, among other things, the cost of obtaining (or failing to obtain) patent approvals, the cost of litigating patent infringement and the loss of patent protection for products (which significantly increases pricing pressures and can materially reduce profitability with respect to such products). In addition, these companies may have limited operating histories, and prices of these companies’ securities may be more volatile than other securities, especially over the short term. Portfolio Funds. The clients may invest a portion of its assets in other private funds, such as venture capital or private equity funds (each such fund in which an investment is made, a “Portfolio Fund”), which investments are likely to involve one or more of the following risks. Compensation not Correlated to the Fund’s Performance The clients may bear both asset-based fees and performance-based fees or allocations paid or allocated to the sponsor or manager of a Portfolio Fund. To the extent that the clients invest in a Portfolio Fund, the clients should be expected to bear their pro rata share of any asset-based fees and performance-based fees and the organizational and offering costs and expenses and operating and administrative expenses of such Portfolio Fund. Withdrawals from Portfolio Funds; In-Kind Distributions The clients may have limited rights pursuant to which it may withdraw, transfer or otherwise liquidate its investments in Portfolio Funds. Investments in Portfolio Funds are not themselves marketable; therefore, the clients will not be able to readily dispose of their interests in Portfolio Funds. Under the terms of the governing documents of the Portfolio Funds, the ability of the clients to withdraw any amount invested therein may be subject to certain restrictions and conditions, including restrictions on the withdrawal of interests for an initial period, restrictions on the amount of withdrawals, the frequency with which withdrawals can be made and investment minimums that must be maintained. Additionally, Portfolio Funds typically reserve the right to reduce or suspend withdrawals and to satisfy withdrawals by making distributions in kind, under certain circumstances. Thus, upon the client’s withdrawal of all or a portion of its interest in a Portfolio Fund, the client may receive financial instruments that are illiquid or difficult to value. Risks Relating to Private Investment Funds Generally Systemic Risk. Systemic risk is the risk of broad financial system stress or collapse triggered by the default of one or more financial institutions, which results in a series of defaults by other interdependent financial institutions. Financial intermediaries, such as banks and Digital Asset exchanges with which the clients interacts, as well as the clients, are all subject to systemic risk. A systemic failure could have material adverse consequences on the clients and on the markets for the Digital Assets in which the clients seeks to invest. For example, the March 2023 failures of Silicon

Valley Bank and Signature Bank created a significant amount of market uncertainty for those entities, banks and nonbanks alike, who interacted with those institutions. The clients’ investment program, may involve new types of financial intermediaries, the systemic risk of which may be less correlated to broader markets. Increased Regulatory Oversight. Increased regulation (whether promulgated under securities laws or any other applicable law) and regulatory oversight of, and changes in law applicable to, private investment funds and their managers, especially with respect to private investment funds investing in blockchain or Digital Assets (such as the clients) and their managers (such as the Investment Adviser), may impose administrative burdens on the Investment Adviser, including, without limitation, responding to examinations and other regulatory inquiries and implementing policies and procedures. Such administrative burdens may divert the Investment Adviser’s time, attention and resources from portfolio management activities to responding to inquiries, examinations and enforcement actions (or threats thereof) and could potentially impact the investment objectives of the clients. Regulatory inquiries often are confidential in nature, may involve a review of an individual’s or a firm’s activities or may involve studies of the industry or industry practices, business arrangements that occur frequently in the industry, as well as the practices of a particular institution. Digital Assets and companies transacting in Digital Assets are currently the subject of significant legislative and regulatory scrutiny, and the regulatory requirements applicable to firms operating in the Digital Asset markets are evolving. In the U.S. and other jurisdictions, the evolving status of Digital Assets under applicable securities and banking laws may require certain counterparties and service providers to obtain additional licenses or become subject to greater regulatory oversight or interventions. If this occurs, certain counterparties and/or service providers may need to limit their product offerings and/or ability to enter into certain transactions, and in some cases may withdraw from certain business lines upon which the clients depend. The clients could be adversely impacted by such developments. Given that the clients may invest in digital currency (or Digital Asset) companies and that the regulatory environment regarding digital currencies (and Digital Assets) is continuing to evolve, the clients may be affected if any of its portfolio companies is or becomes subject to state or federal regulation. Any additional regulatory obligations may cause the clients to incur extraordinary, nonrecurring expenses, possibly affecting an investment in the clients in an adverse manner. For example, with respect to any investment of 10% or more of the equity or voting shares of a portfolio company that is required to obtain state money transmitter licenses, the clients and/or its principals may be required to: (1) furnish financial statements of the clients and/or financial and biographical information of Fund principals to state regulatory authorities; and/or (2) obtain approval from state regulatory authorities. Additionally, the clients may choose to limit, reduce or divest investments in a portfolio company in response to these or other perceived or actual regulatory requirements at a time that is otherwise disadvantageous to an investor in the clients. To the extent the clients limit or reduce the scope of certain investments or activities, investors’ rights or investment initiatives, in order to limit the applicability or potential applicability of regulatory requirements, investment in the clients may be adversely affected.

Material Relationships or Arrangements with Industry Participants Certain clients hold investments in Digital Asset-related companies, while certain other funds hold those Digital Assets. Conflicts of interest may arise in that the Investment Adviser may be incentivized to purchase (and not divest) Digital Assets developed by blockchain technology companies in which certain clients invest. In the event the Investment Adviser determines that participation in an Early- Stage Token Offering is appropriate for certain clients, those clients will generally participate pro rata in such opportunity based on available capital. In addition, the Venture Funds may, from time to time, hold Digital Assets through Early-Stage Token Offerings where the Venture Funds invest in the underlying issuing company. In such case(s), investment opportunities in such Early-Stage Token Offerings of Digital Assets will be allocated among the applicable clients in a manner that is fair and equitable. It is anticipated that the Investment Adviser’s investment teams will develop numerous quantitative models and software for use by one or more investment teams for the benefit of one or more clients. Similarly, trading and other systems (e.g., order management) developed by employees of the Investment Adviser are expected to be used by the Investment Adviser’s investment teams, including investment teams that do not manage the same client’s assets. The determination of how models and systems will be allocated among the applicable clients and other pooled investment vehicles will be made on a fair and equitable basis, to the extent practical and in accordance with, among other factors, the applicable client’s investment strategies, over a period of time. From time to time, the Investment Adviser may license the software developed by the Investment Adviser or its personnel to third parties or use such software for proprietary trading purposes, which may increase competition by limiting the investment opportunities available to certain clients. Additionally, investment teams that do not manage a specific client’s assets and/or third parties with license to utilize an investment team’s proprietary models and software, may develop implementation methods for such models and software that provide a competitive advantage over one or more clients, thereby reducing and/or eliminating the effectiveness of such model or software with respect to one or more clients. The Investment Adviser may be subject to conflicts relating to its selection of Digital Asset intermediaries, exchanges and counterparties on behalf of clients. Client portfolio transactions will be allocated to intermediaries, exchanges and counterparties on the basis of numerous factors and not necessarily lowest pricing. Intermediaries, exchanges and counterparties have at times provided

other services that are beneficial to the Investment Adviser, other clients, or other vehicles managed by the Investment Adviser, but not necessarily beneficial to the Funds. The Investment Adviser, its affiliates, and certain clients have invested in or established Digital Asset exchanges or other Digital Asset service providers, including businesses that focus on storage, security and custody of Digital Assets. The Investment Adviser has caused and expects in the future to cause one or more clients to transact with such affiliated service providers. Such affiliated service providers receive compensation when effecting Digital Asset transactions on behalf of certain clients. Investors will have no right to request which Digital Asset service providers, intermediaries, exchanges and counterparties the clients transact with or invest in, and should not expect the clients to accommodate any such requests. Conflicts of interest may arise from the fact that any service provider to a client (“Service Provider”) or any affiliate of a Service Provider may provide services to, or have business, financial, personal or other relations with (i) other private funds with investment programs similar to that our clients or (ii) the Investment Adviser or any of its affiliates. Certain Service Providers or affiliates of Service Providers are investors in certain clients, a source of investment opportunities or a co-investor or commercial counterparty or entity in which the Investment Adviser has an investment. It is customary for a Service Provider to charge different rates or have different terms for different types of services. Based on the types of services used by the Investment Adviser and its affiliates as compared to the types of services used by clients and the terms of such services, a Service Provider has entered into an arrangement with the Investment Adviser or its affiliates that provides for more favorable rates or terms than an arrangement with a client. Similar arrangements may also be entered into in the future. Conflicts of interest may arise from the fact that the Investment Adviser and its affiliates provide, or may in the future provide, investment management services to Other Clients. The Investment Adviser currently manages the treasury of a DAT company focused on Solana, and may in the future manage the treasuries of additional DAT companies focused on other Digital Assets (each, a “PanteraManaged DAT”). The Investment Adviser’s purchase and sale of applicable Digital Assets (including Solana) on behalf of a Pantera-Managed DAT and one or more Other Clients will generally be allocated among such Pantera-Managed DAT and such Other Clients in a manner that the Investment Adviser determines is fair and equitable. The personnel of the Investment Adviser or their affiliates may invest in DAT companies and/or other investments, which may conflict or compete with the Funds, including by investing or selling investments in DAT companies when a Fund is doing the opposite. D. Material Conflicts of Interest Relating to Other Investment Advisers We do not recommend or select other investment advisers for our clients.

independence in the investment decision-making process must be maintained at all times.

Clients and prospective clients may request a copy of the Code by contacting us at the address or telephone number listed on the first page of this document. B. Securities that the Investment Adviser or a Related Person Has a Material Financial Interest

1. Cross Trades The Investment Adviser may determine that it would be in the best interests of certain clients to transfer a security from one client to another (each such transfer, a “Cross Trade”) for a variety of reasons, including, without limitation, tax purposes, liquidity purposes, to rebalance the portfolios of clients, or to reduce transaction costs that may arise in an open market transaction. If the Investment Adviser decides to engage in a Cross Trade, the Investment Adviser will determine that the trade is in the best interests of each client involved in it and take steps to ensure that the transaction is consistent with the duty to obtain best execution for each of those clients. A cross transaction between two clients may occur as an “internal cross”, where the Investment Adviser instructs the custodian for the applicable client accounts to book the transaction at the price determined in accordance with the Valuation Policy. If the Investment Adviser effects an internal cross, the Investment Adviser will not receive any fee in connection with the completion of the transaction.

2. Principal Transactions To the extent that Cross Trades may be viewed as principal transactions (as such term is used under the Advisers Act) due to the ownership interest in a client by the Investment Adviser, its affiliates, or its personnel, the Investment Adviser will comply with the requirements of Section 206(3) of the

Advisers Act. For the avoidance of doubt, the Fund General Partners and the Investment Adviser will comply with the requirements of Section 206(3) of the Advisers Act for any principal transactions. In connection with principal transactions, Cross Trades, related-party transactions and other transactions and relationships involving potential conflicts of interest, the directors and/or the Fund General Partners are each authorized to select one or more persons who are not affiliated with the Investment Adviser (such as an independent director) to serve on a committee, which may be authorized, to approve or disapprove, to the extent required by applicable law or deemed advisable by the directors and/or the Fund General Partner, such transactions and conflicts of interest. Such committee may approve of such transactions prior to or contemporaneous with, or ratify such transactions subsequent to, their consummation. In no event will any such transaction be entered into unless it complies with applicable law. The person(s) so selected may be exculpated and indemnified by the Funds. Any decision of such committee will be binding on all Fund investors. Cross Trades between clients may occur, and will not be presumptively treated as principal transactions absent a determination by the Investment Adviser otherwise. C. Investing in Securities that the Investment Adviser or a Related Person Recommends to Clients The Code places restrictions on personal investments by employees, including that they disclose their personal holdings and transactions in securities and other instruments, including Bitcoin or other Digital Assets, to the Investment Adviser on a periodic basis. The Investment Adviser, its affiliates and its employees may invest on behalf of themselves in securities and Digital Assets that would be appropriate for, held by, or may fall within the investment guidelines of clients. The Investment Adviser, its affiliates and its employees also engage, and in the future may engage, in a broad spectrum of activities, including direct investment activities (including trading in Digital Assets and alternative currencies outside of client portfolios) and investment advisory activities, and have extensive investment activities (including investments for their own account), on behalf of both persons or entities to which they provide investment advice on a principal basis, that are independent from, and may from time to time conflict with or be adverse to advice given or action taken for clients, including by buying or selling Digital Assets at different times than clients, or when a client is doing the opposite. These activities have the potential to adversely affect the prices and availability of other securities or instruments held by or potentially considered for one or more clients. Additionally, the Investment Adviser and its affiliates may invest in or establish Digital Asset exchanges, indexes, and/or other Digital Asset service providers, including service providers utilized by clients. Potential conflicts also may arise due to the fact that the Investment Adviser and its personnel may have investments in some Funds but not in others or may have different levels of investments in the various Funds. In addition, certain employees of the Investment Adviser may have a material financial interest in instruments held by client portfolios, and such employees may receive a financial benefit from clients’ investment in such instruments. Certain employees of the Investment Adviser have provided, and may in the future continue to provide, advisory services to Early-Stage Token Offering issuers in connection with their offerings and development of their protocols. Clients and investors in the Funds should be aware that any compensation received in connection with such activities benefits the Investment Adviser (or its employees) and not clients. Compensation may take the form of Early-Stage Token Offering tokens. Such activities pose a potential conflict of interest because the Investment Adviser may be incentivized to cause clients to engage in investment activities with respect to such Early-Stage

Token Offering issuers, including but not limited to: (i) investing in such Early-Stage Token Offering issuers, (ii) participating in the Early-Stage Token Offerings of such issuers, or (iii) purchasing Digital Assets that were previously offered through Early-Stage Token Offerings of such issuers. The Investment Adviser has established policies and procedures to monitor and resolve conflicts with respect to investment opportunities in a manner it deems fair and equitable, including the restrictions placed on personal trading in the Code, as described above, and regular monitoring of employee transactions and trading patterns for actual or perceived conflicts of interest, including those conflicts that may arise as a result of personal trades in the same or similar securities made at or about the same time as client trades. D. Conflicts of Interest Created by Contemporaneous Trading The Investment Adviser provides investment advisory services on behalf of a number of clients and other pooled investment vehicles. Certain clients have investment programs that are similar to or overlap and may, therefore, participate with each other in investments. It is the policy of the Investment Adviser to allocate investment opportunities among all clients fairly, to the extent practical and in accordance with each client’s applicable investment strategies, over a period of time. Investment opportunities will generally be allocated among those clients for which participation in the respective opportunity is considered appropriate, taking into account, among other considerations: (i) whether the risk-return profile of the proposed investment is consistent with a client’s objectives; (ii) the potential for the proposed investment to create an imbalance in a client’s portfolio; (iii) the liquidity requirements of a client; (iv) potentially adverse tax consequences; (v) regulatory restrictions that would or could limit a client’s ability to participate in a proposed investment; and (vi) the need to re-size risk in a client’s portfolio. Investments may be allocated among client portfolios, and such allocations will be determined based on the Investment Adviser’s allocation policy. The Investment Adviser and its affiliates may, from time to time, offer one or more Fund investors, clients, employees, other vehicles managed by the Investment Adviser, or third parties (any such party, a “Co-Investor”) the opportunity to invest in special purpose vehicles (“SPVs”) that participate in select Early-Stage Token Offerings (“Special Purpose Opportunities”), including through SAFTs. Generally, SPVs will co-invest with clients in such opportunities. The Investment Adviser and its affiliates are not obligated to arrange, and Co-Investors will not be obligated to participate in, Special Purpose Opportunities. The Investment Adviser and its affiliates have sole discretion as to the amount (if any) of a Special Purpose Opportunity that will be allocated to a particular Co-Investor and may allocate Special Purpose Opportunities instead to other CoInvestors. The Investment Adviser or its affiliates receive fees and/or allocations from Co-Investors, which may differ from the fees and/or allocations borne by clients. To the extent that clients and Co-Investors participate in a particular investment, the Investment Adviser will generally seek to dispose of such investment in a manner that is fair and equitable (i.e., simultaneously), subject to legal, tax, regulatory or other concerns, other considerations such as the relative amounts of capital available for new investments, as applicable. The Investment Adviser will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to any client solely because the Investment Adviser purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to any client if, in its reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practical or desirable for the client.

1. Research and Other Soft Dollar Benefits We do not currently intend to receive research and other soft dollar benefits from broker-dealers.

2. Brokerage for Client Referrals Neither the Investment Adviser nor any related person receives client referrals from any brokerdealer or third party. However, as discussed above, subject to best execution, the Investment Adviser may consider, among other things, capital introduction and marketing assistance with respect to investors in the Funds in selecting or recommending broker-dealers for the Funds.

3. Directed Brokerage The Investment Adviser does not recommend, request or require that a client direct the Investment Adviser to execute transactions through a specified broker-dealer. B. Order Aggregation If the Investment Adviser determines that the purchase or sale of Digital Assets is appropriate with regard to multiple clients, the Investment Adviser may, but is not obligated to, purchase or sell Digital Assets on behalf of such clients with an aggregated order, for the purpose of reducing transaction costs, to the extent permitted by applicable law. When an aggregated order is filled through multiple trades at different prices on the same day, each participating client will receive the average price, with transaction costs generally allocated pro rata based on the size of each client’s participation in the order (or allocation in the event of a partial fill) as determined by the Investment Adviser. In the event of a partial fill, allocations may be modified on a basis that the Investment Adviser deems to be appropriate, including, for example, in order to avoid odd lots or de minimis allocations. When orders are not aggregated, trades generally will be processed in the order that they are placed with the Digital Asset counterparty selected by the Investment Adviser. As a result, certain Digital Asset trades for one client (including a client in which the Investment Adviser and its personnel may have a direct or indirect interest) may receive more or less favorable prices or terms than another client, and orders placed later may not be filled entirely or at all, based upon the prevailing market prices at the time of the order or trade. In addition, some opportunities for reduced transaction costs and economies of scale may not be achieved. When in the best interests of clients and other pooled investment vehicles, the Investment Adviser causes a client or other pooled investment vehicle to purchase assets in an aggregated single order for such client and subsequently allocate positions in that purchase to other clients through the use of Cross Trades.

These reports are made available electronically via e-mail or through the Investment Adviser’s password-protected website. Investors in the Funds receive letters on a periodic basis from the Investment Adviser documenting the performance of their Fund, along with a commentary by the Investment Adviser, although the Investment Adviser may provide certain investors with information on a more frequent and detailed basis if agreed to by the Investment Adviser. Information also may be available through the Investment Adviser’s password-protected website. In addition, the Investment Adviser issues investors tax reports and audited financial statements concerning their respective Funds within 120 days of the end of the Fund’s fiscal year (or as soon as reasonably practical). While all investors generally receive similar information, to the extent an investor receives additional information (that other investors have not received), which is in addition to information provided in a Fund’s regular reports to investors, such information may provide such investor with greater insight into the Fund’s activities. This may enhance such investor’s ability to make investment decisions with respect to the Fund and possibly affect such investor’s decision to request a redemption from the Fund.

However, it is not required to comply (or is deemed to have complied) with certain requirements of the Custody Rule with respect to each Fund because it complies with the provisions of the so-called “Pooled Vehicle Annual Audit Exception”, which, among other things, requires that each Fund be subject to audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and requires that each Fund distribute its audited financial statements to all investors within 120 days of the end of its fiscal year. Depending on whether a Digital Asset is a security, the Investment Adviser maintains Digital Assets with a qualified custodian, a non-qualified custodian, or internally. The Investment Adviser maintains clients’ Digital Assets that are securities with qualified custodians where the custodian supports the maintenance of such assets. The Investment Adviser maintains clients’ Digital Assets that are not securities with third-party custodians that, although they are not classified as qualified custodians, have implemented systems to safeguard such assets that the Investment Adviser has reviewed and diligenced. At times, Digital Assets are moved to trading platforms in order to effectuate transactions and other portfolio management activities. The Investment Adviser stores certain Digital Assets internally, and the Investment Adviser has developed an internal custody platform that incorporates dedicated hardware, encryption and redundancy into its architecture.

In limited circumstances, the Investment Adviser may refrain from voting Proxies where we believe that voting would be inappropriate, taking into consideration the cost of voting the Proxies and the anticipated benefit to its clients. Generally, clients may not direct our vote in a particular solicitation. Conflicts of interest may arise between the interests of clients on the one hand and us or our affiliates on the other hand. If we determine that we may have, or be perceived to have, a conflict of interest when voting Proxies, we will vote in accordance with our Proxy voting policies and procedures. Clients may obtain a copy of our Proxy voting policies and our Proxy voting record upon request.