Syncracy Operational Management LLC: investment adviser

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

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

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

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 Fees are withdrawn from Investor accounts without prior notice but are subject to post-deduction reporting and periodic statements.

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

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

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

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

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

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

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

Syncracy seeks to address these potential conflicts by managing the Funds in accordance with its fiduciary duty and consistent with each Fund’s stated investment objectives, guidelines, and restrictions, as set forth in their respective private placement memoranda and other governing documents. The Adviser also maintains internal controls and oversight procedures designed to ensure the fair and equitable treatment of all clients and adherence to applicable regulatory standards.

The Funds may accept investments from high net worth individuals, family offices, funds of funds, institutional investors, pension plans, endowments, foundations, and other sophisticated entities. Each Fund generally imposes a minimum investment amount, which is disclosed in the Fund’s private placement memorandum and limited partnership agreement. The General Partner may, in its sole discretion, waive or reduce such minimum investment requirements on a case-by-case basis.

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

pre-ICOs, simple agreements for future tokens (“SAFTs”), simple agreements for future equity (“SAFEs”), token warrants, and other current or future forms of cryptofinance and blockchain-native assets (collectively, “Digital Assets”). In addition, Syncracy may invest in companies related to the Digital Asset sector across both public and private markets, including venture capital and private equity-style investments (“Portfolio Companies”). The Funds’ investments in Digital Assets and Portfolio Companies are referred to collectively as “Portfolio Investments.”

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

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

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

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

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

potential capital loss due to the concentrated nature of the Funds’ portfolios. Digital Asset Trading is Volatile and Speculative. Digital Assets represent a speculative investment and involve a high degree of risk. As relatively new and evolving financial instruments, many Digital Assets have not yet achieved widespread adoption or integration into traditional economic and financial systems. While some Digital Assets may serve as mediums of exchange or stores of value, a significant portion of current demand is driven by speculative trading, market momentum, and investor sentiment rather than underlying economic fundamentals. As a result, digital asset prices may be subject to extreme volatility, including substantial intraday price swings and sudden declines in value. In addition, the use of Digital Assets in retail or commercial transactions remains limited, and their utility in everyday commerce is uncertain. To the extent that adoption fails to expand or declines, demand may weaken and prices may suffer. The reliance on speculative interest also increases the risk of sharp reversals due to adverse news, regulatory developments, security breaches, or technical flaws in the underlying protocols. These characteristics make digital asset trading inherently risky and may expose the Funds to sudden and material losses. Risk of Loss of Private Key. Digital Assets are typically held in digital wallets secured by private cryptographic keys, which are required to access, transfer, or control the assets. The security and accessibility of these private keys are critical to safeguarding the Funds’ holdings. If a private key is lost, destroyed, stolen, or otherwise compromised, the associated Digital Assets will generally be irretrievable and permanently lost. Unlike traditional financial institutions, there is no central authority or recourse to reverse or recover unauthorized transactions involving Digital Assets. Syncracy implements multiple layers of operational and technological safeguards to protect private keys, including geographically distributed backups and cold storage solutions. Nevertheless, no system is infallible, and there remains the risk that private keys could be lost due to technical malfunctions, human error, unauthorized access, or catastrophic events. If any such event were to occur, the affected Fund could suffer a complete loss of the associated Digital Assets, which may result in a substantial or total loss of an Investor’s capital. Dependence on Key Personnel. Syncracy is dependent on the services of its principals and key personnel, including Daniel Cheung and Ryan Watkins. The success of the Funds may depend to a great extent on the investment skills of the Syncracy’s principals and key personnel. There can be no assurance that Daniel Cheung, Ryan Watkins, or any other principals or key personnel will continue to be associated with Syncracy. The Funds may be adversely affected if, because of illness, resignation, or other factors, the services of the relevant people were not available for any significant period of time. In the event that a principal responsible for custody and access is incapacitated or otherwise unable to perform key duties, Syncracy may be unable to retrieve private keys or access specific wallet addresses. While Syncracy may seek to involve trusted third parties or implement further contingency planning over time, there is no guarantee that such measures will be effective. The loss of access due to personnel-related events could result in the permanent loss of Fund assets, and Investors could experience a substantial or total loss of capital as a result. Technology and Security. Syncracy depends on sophisticated technological infrastructure to manage, secure, and transact in Digital Assets. This includes proprietary and third-party software, hardware wallets, communication systems, and other technology solutions that support portfolio management and custody functions. Although Syncracy believes it has designed and implemented a security framework reasonably suited to protecting Fund assets, such assessments are based on current technologies and known vulnerabilities. As the digital asset landscape evolves, new security threats may emerge, and previously unknown vulnerabilities may be exploited by malicious actors. In addition, as the Funds’ assets grow in size, they may become a more attractive target for hackers or other adversaries seeking to disrupt operations or steal Digital Assets. Syncracy’s ability to maintain secure custody, execute trades, and protect sensitive data depends on the continued reliability and adaptability of its technology

stack. A failure in any part of this system, whether due to internal error, cyberattack, or third-party failure, could result in theft, asset loss, or operational disruption, any of which could negatively affect Fund performance or result in a partial or complete loss of assets. Security Breaches. Security breaches, whether caused by cyberattacks, hacking attempts, malware, or inadvertent system vulnerabilities, pose a significant risk to the Funds. These events may involve unauthorized access to internal systems, compromise of digital wallets, corruption or loss of data, or disruption to normal business operations. In particular, successful intrusions into systems used for key management, trading execution, or custody of assets could result in unauthorized transfers or theft of Digital Assets. Although Syncracy employs industry-standard security practices, including firewalls, encryption, and multi-factor authentication, these defenses may not be sufficient to prevent or mitigate all forms of attack. In addition, any vulnerabilities in third-party service providers may expose Syncracy to downstream risks beyond its direct control. If a security breach occurs, the affected Fund may be forced to suspend operations, delay redemptions, or absorb financial losses. Except in cases of gross negligence, fraud, or willful misconduct by Syncracy, such losses would be borne by the Funds and, ultimately, their Limited Partners. Trading on Digital Asset Networks. The Funds will convert Limited Partner contributions denominated in U.S. dollars into Digital Assets via transactions executed over various blockchain networks. These networks typically operate on a decentralized basis, utilizing peer-to-peer protocols and public transaction ledgers known as blockchains. Transactions across such networks require the recipient to provide a public key, effectively a digital wallet address, and the sender must authorize the transaction using a private key. The authorization process involves cryptographic functions, such as hashing algorithms and digital signatures, that validate ownership and control of the Digital Assets being transferred. While these systems are designed to ensure security and integrity, they are also vulnerable to a variety of risks. For example, malware or phishing attacks may compromise private keys, and improperly secured wallets may be susceptible to unauthorized access. Additionally, blockchain protocols may be subject to network congestion, fork events, bugs in the source code, or coordinated manipulation. Many digital asset exchanges have experienced fraud, cyberattacks, or operational failures, leading to the loss of customer assets. In numerous instances, customers have not been made whole following such events. A security breach, transaction failure, or loss of wallet access on a network or exchange used by the Funds could result in a permanent loss of assets and materially affect Fund performance. Intellectual Property Rights Claims May Adversely Affect the Operation of Digital Asset Networks. Digital asset networks rely on open-source software and decentralized consensus mechanisms. However, they are not immune from legal challenges, particularly in the area of intellectual property. Third parties may assert claims that the operation, structure, or source code underlying specific blockchain protocols or Digital Assets infringes on patented technology, copyrighted software, or other proprietary rights. Even if such claims lack merit, the cost of defending against them — or the market perception of increased legal uncertainty, could negatively impact the value and functionality of affected Digital Assets. In the event that a legitimate intellectual property claim is brought against a protocol in which a Fund is invested, the network may be forced to halt operations, alter its codebase, or cease supporting certain functionalities. This may render the associated digital asset illiquid or unusable. Moreover, if the Fund is unable to hold or transfer the affected asset due to legal injunction or protocol-level disruption, it may be compelled to write down or liquidate its position, potentially at a significant loss. Any such outcome could materially and adversely affect the Fund and result in losses for Investors. Initial Coin Offerings Risk. The Funds may invest in initial coin offerings (“ICOs”) or token presale rounds conducted by blockchain-based startups or projects. These offerings allow participants to purchase newly issued Digital Assets, often in exchange for U.S. dollars or existing Digital Assets. ICOs are frequently conducted with minimal regulatory oversight, limited disclosure requirements, and immature operational infrastructures. Tokens acquired through these offerings may

not confer equity, voting rights, or other traditional ownership claims and may lack established use cases or adoption. Investments in ICOs and presales are highly speculative and subject to a broad range of risks, including project failure, fraud, illiquidity, technological flaws, and regulatory intervention. A number of ICOs have resulted in total losses for investors due to scams, insider manipulation, or unrealized business models. In addition, the legal status of many Digital Assets issued via ICOs remains uncertain. The SEC and other regulators have stated that, depending on the specific characteristics of the token and the offering structure, such tokens may constitute securities under U.S. law. Accordingly, the Funds may be subject to enforcement actions, registration requirements, or limitations on resale. Any such regulatory developments could impair the Funds’ ability to hold or dispose of these assets and may result in significant losses or operational burdens. Stablecoin Depegging Risk. Stablecoins are Digital Assets designed to maintain a stable value relative to a reference asset, most commonly the U.S. dollar, through various mechanisms including reserve backing, algorithmic control, or market incentives. While stablecoins are intended to offer price stability, they remain subject to market forces, and their stability depends on the confidence of market participants in the underlying peg. In times of market stress, loss of trust, or insufficient reserves, a stablecoin may “depeg” from its target value. A stablecoin depegging event can cause a sudden and substantial decline in value, leading to liquidity disruptions, markto-market losses, and collateral shortfalls, particularly if the stablecoin was used for margining, settlement, or as a cash equivalent within the Fund. Certain algorithmic or undercollateralized stablecoins have failed entirely, resulting in neartotal losses for holders. Even fully backed stablecoins face risks related to reserve transparency, redemption mechanics, and custodial oversight. If a Fund holds or transacts in a stablecoin that becomes impaired or loses its peg, the Fund may suffer significant financial and operational consequences. Stolen or Incorrectly Transferred Digital Assets May Be Irretrievable. Blockchain transactions are typically irreversible. Once a transaction is confirmed and recorded on the blockchain, there is no built-in mechanism to reverse it or recover the transferred Digital Assets. Accordingly, if Digital Assets are sent to the wrong address, whether due to human error, software malfunction, or a fraudulent instruction, they are likely to be permanently lost. Similarly, if a Fund’s digital wallet is compromised and assets are stolen, there is generally no centralized recourse or regulatory protection available to recover those assets. These risks are exacerbated by the complex and pseudonymous nature of blockchain addresses and the lack of universally adopted account verification standards. To the extent that Syncracy or a Fund is unable to identify or engage with a recipient, seek legal remedy, or initiate a corrective transaction, any erroneously transferred or stolen assets may be irrecoverable. Such events could materially impair a Fund’s performance and expose Limited Partners to significant capital losses. Risk to Digital Asset Networks from Malicious Actors. Certain digital asset networks rely on distributed consensus mechanisms, such as proof-of-work or proof-of-stake, to verify transactions and maintain the integrity of the blockchain. These systems depend on a large and decentralized group of participants to validate and record transactions. However, if a malicious actor, or group of coordinated participants (such as a botnet), were to obtain majority control over the network’s mining or staking power (commonly referred to as a “51% attack”), they could disrupt the network’s operation. A successful 51% attack may allow the attacker to reverse transactions, prevent new transactions from being confirmed, or double-spend Digital Assets. While such attacks do not allow for the creation of counterfeit assets, they can significantly undermine confidence in the network, impair its functionality, and reduce the value of associated Digital Assets. If a Fund is invested in a digital asset that experiences a 51% attack, it could suffer a substantial loss of value or become unable to transact altogether. Moreover, the decentralized nature of digital asset communities means that recovering from such an attack may require hard forks, network reorganizations, or consensus changes, which themselves can further affect asset pricing and liquidity. These risks are particularly acute for newer or less widely

adopted protocols with lower aggregate network participation. Counterparty Risk. The Funds may enter into transactions in over-the-counter (“OTC”) or interdealer markets, particularly when trading Digital Assets that are not listed on centralized exchanges or require bespoke agreements. In these markets, counterparties are typically not subject to the same level of regulatory oversight or transparency as participants in traditional, exchange-based markets. Furthermore, protections commonly associated with exchangecleared trades, such as margining, netting, and the performance guarantees of clearing houses, may be unavailable. As a result, the Funds face the risk that a counterparty may default on its contractual obligations due to financial distress, fraud, operational failure, or legal disputes. In some cases, counterparties may dispute the terms of a trade or fail to settle transactions, potentially exposing the Funds to losses or delays. Syncracy is not subject to restrictions on the number or type of counterparties with which it may transact, and it may concentrate exposure with one or a few trading partners. The lack of standardized credit assessments, limited recourse mechanisms, and absence of a centralized enforcement body in many digital asset markets heighten the risk of counterparty failure. Any such failure could result in the loss of principal, missed investment opportunities, or operational disruptions for the Funds. Regulatory Risk Related to Digital Assets. The legal and regulatory landscape surrounding Digital Assets is rapidly evolving and remains uncertain. In the United States, agencies such as the Securities and Exchange Commission (“SEC”), Commodity Futures Trading Commission (“CFTC”), Financial Crimes Enforcement Network (“FinCEN”), and Internal Revenue Service (“IRS”) have issued varying and sometimes conflicting statements regarding the classification, taxation, and regulation of Digital Assets and related activities. In particular, whether specific Digital Assets should be classified as securities, commodities, or another category entirely remains a subject of ongoing legal interpretation and enforcement discretion. Future legislative or regulatory developments could impose new registration, compliance, disclosure, or custodial requirements on Syncracy or the Funds, which may be burdensome, costly, or operationally challenging. These developments could also restrict the Funds’ ability to invest in certain Digital Assets or to transact in certain jurisdictions. Regulatory changes may also create adverse tax consequences or reporting obligations that affect Investors. Outside the U.S., foreign regulatory frameworks are similarly unsettled, and some jurisdictions have banned or restricted the use of Digital Assets altogether. The global patchwork of inconsistent and evolving regulations creates compliance risk, legal uncertainty, and the potential for future enforcement actions that could adversely affect the Funds’ investments and performance. Pandemic and Global Disruption Risk. Widespread health emergencies, such as pandemics or epidemics, along with other forms of systemic disruption, including geopolitical conflict, climate events, terrorism, and global supply chain breakdowns, may materially and adversely affect global economic conditions, asset prices, and investor behavior. These events can disrupt financial markets, limit access to infrastructure and service providers, and cause significant volatility or liquidity dislocations in both traditional and digital asset markets. For example, a pandemic may limit the availability of personnel or resources at Syncracy, third-party custodians, trading venues, and other service providers, potentially impairing the Adviser’s ability to manage Fund assets effectively. Travel restrictions, lockdowns, or public health mandates may hinder due diligence, impair market access, or delay execution. Similarly, cyberattacks or disruptions to internet infrastructure could affect access to digital wallets, blockchain nodes, or order execution systems. These and other global disruptions are inherently unpredictable and may pose material risks to the operations, liquidity, and performance of the Funds. Remote Work and Distributed Operations Risk. Syncracy may permit its personnel to work remotely or maintain operations across distributed geographic locations. While the Adviser has implemented security protocols and operational procedures to facilitate secure and efficient remote work, such arrangements inherently carry increased operational risks. These include heightened exposure to data breaches, inadvertent disclosure of sensitive information,

unauthorized access to trading systems, and potential delays in executing or monitoring portfolio activities. In addition, a remote or decentralized workforce may create challenges in oversight, communication, and coordination, particularly during periods of market stress or operational incident. Technology infrastructure supporting remote operations, such as internet connectivity, access controls, or collaboration platforms, may be vulnerable to outages, cyber threats, or user error. Any failure of such systems could impair Syncracy’s ability to manage the Funds or respond promptly to market events, resulting in potential operational losses or adverse performance outcomes for Investors.

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

Supervised persons are also required to submit reports of personal securities holdings upon commencement of employment and annually thereafter, and to report personal securities transactions on a quarterly basis. Personal trading by supervised persons involved in managing client accounts must be conducted in a manner that places client interests ahead of personal interests with respect to client-eligible investments. The Code also addresses the handling of material non-public information and other confidential information, as well as policies governing political contributions, gifts and entertainment, and other potential sources of conflicts of interest. A copy of Syncracy’s Code of Ethics is available to Investors and prospective Investors upon request.

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

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

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

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

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

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

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

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