Item 4.A Describe your advisory firm, including how long you have been in business. Identify your principal owner(s). Tower Arch Capital, L.P. (“Tower Arch”) is a private equity firm focused on acquiring interests in privately held, lower-middle market companies. Tower Arch was formed in 2013. Tower Arch was organized as a Delaware limited partnership and maintains its principal office in Draper, Utah. The principal owners of Tower Arch are Rhett Neuenschwander, David Parkin, Ryan Stratton, and David Topham (collectively, the “Principals”). There are no greater than 25% owners of Tower Arch. Tower Arch provides discretionary investment advisory services to privately offered pooled investment funds (the “Funds”). Tower Arch advises three sets of parallel funds. The first set includes Tower Arch Partners I, LP (“TAP I”) and Tower Arch Partners I (Q), LP (“TAP I (Q)” and together, the “TAP I Funds”), the second set includes Tower Arch Partners II, LP (“TAP II”) and Tower Arch Partners II (Q), LP (“TAP II (Q)” and together, the “TAP II Funds”) and the third set includes Tower Arch Partners III, LP (“TAP III”) and Tower Arch Partners III (Q), LP (“TAP III (Q)” and together, the “TAP III Funds”). In certain cases, Tower Arch has offered, and may in the future, offer to allow certain investors (including related persons of Tower Arch) the ability to co-invest along with the Funds in certain Portfolio Companies. In certain cases Tower Arch may form a co-investment vehicle to facilitate such investments (“Co-Investment Vehicle”). Such co-investments may or may not be subject to the fees described below in Item 5, or may be subject to different fee amounts and/or terms. Tower Arch or the applicable general partner may offer co-investment opportunities to some investors and not others, at the discretion of the General Partner. In the future, Tower Arch may provide investment advisory services to other Funds or other clients. Advisory Structure The activities of each Fund are governed by a limited partnership agreement (each a “Fund Agreement”), that specifies the investment guidelines and investment restrictions applicable to each Fund. Typically, an affiliate of Tower Arch serves as general partner of each of the Funds (each a “General Partner”). Each General Partner is a related person of Tower Arch. Tower Arch, together with the General Partners, provides investment management and/or investment supervisory services. The General Partners and Funds retain Tower Arch to provide investment management and advisory services. The General Partners retain management authority over the business and affairs of the Funds. specializing in a particular type of advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that service in greater detail. If you

provide investment advice only with respect to limited types of investments, explain the type of investment advice you offer, and disclose that your advice is limited to those types of investments. Tower Arch offers investment advice solely with respect to the investments made by the Funds. Such services consist of investigating, identifying, and evaluating investment opportunities; structuring, negotiating, and making investments on behalf of the Funds; managing and monitoring the performance of such investments; and disposing of such investments. The Funds generally invest in equity securities issued by private companies (“Portfolio Companies”). Tower Arch generally has broad and flexible investment authority with respect to the Funds. Each Fund’s investment objective and strategy is set forth in the respective Fund’s governing documents. All investors in the Funds (“Investors”) are provided with a Fund Agreement and, in the case of certain Funds, a confidential private placement memorandum prior to making an investment. Investors are urged to carefully review those documents prior to making an investment in the Fund. needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. Tower Arch tailors its investment advice to each Fund in accordance with the Fund’s investment objectives and strategy as set forth in the relevant Fund Agreement and, if applicable, confidential private placement memorandum. Certain investment limitations may be included in the Fund Agreements. Tower Arch and/or the General Partners have and may in the future enter into side letter agreements with certain Investors. Side letters are negotiated prior to investment and may establish rights that supplement, or alter the terms of, the applicable Fund Agreement. Pursuant to such side letters, certain Investors have rights which are not available to other Investors (including, without limitation, most favored nations rights, advisory board representation, transparency rights, reporting rights, and co-investment rights). (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. Not applicable. Tower Arch does not participate in wrap fee programs. discretionary basis and the amount of client assets you manage on a non-discretionary basis. Disclose the date “as of” which you calculated the amounts. As of December, 31 2023, Tower Arch and the General Partners’ regulatory assets under management were approximately $1,896,142,535, all managed on a discretionary basis. Tower Arch does not have any clients whose assets are managed on a non-discretionary basis.