AlphaCat Capital is an investment management firm incorporated in Delaware in August 2015 and operating from offices shared with a financial affiliate, American International Group, Inc , in New Jersey. AlphaCat Capital acts as a non-discretionary sub-adviser to clients and funds managed by its affiliate, AlphaCat Managers, which is separately registered with the U.S. Securities and Exchange Commission and based in Pembroke, Bermuda. AlphaCat Capital and AlphaCat Managers together conduct a single advisory business. Potential investors and clients should carefully read the Brochure for each of the Advisors. The Advisors: (i) are subject to a unified compliance program; (ii) advise only private funds and certain separate accounts maintained on behalf of qualified clients; (iii) use the same or similar names; and/or (iv) hold themselves out to current and prospective private fund investors and advisory clients as conducting a single advisory business because they share personnel and resources. AlphaCat Capital would be a “relying adviser” of AlphaCat Managers under the terms of the 2012 ABA No Action letter, but for AlphaCat Managers having its principal office and place of business outside of the United States. In addition, AlphaCat Capital would be considered to be a related adviser under rule 203A-2(b), if it had its primary office and principle place of business in Bermuda. All books and records in relation to AlphaCat Capital are maintained electronically and in joint custody accessible by both Advisors. AlphaCat Capital specializes in providing investment advisory services in risk-linked instruments that enable access to property catastrophe insurance and reinsurance-linked assets and securities in concert with its affiliate AlphaCat Managers. Shares are offered exclusively on a private basis to a limited number of sophisticated qualified institutional and high net worth clients. AlphaCat Capital is wholly owned by Validus Specialty LLC., a Delaware based company that is wholly owned and controlled by AIG Property Casualty, Inc., which is owned by American International Group, Inc., a public company listed on the New York Stock Exchange (NYSE:AIG), and is the primary owner and the controlling affiliate of Validus Specialty LLC which wholly owns AlphaCat Capital and Validus Ventures, Ltd which wholly owns AlphaCat Managers. Validus owns and controls the interests in AlphaCat Capital through interim affiliates listed on Schedule B of Part 1 of Form ADV. Validus merged with American International Group, Inc. (“AIG”) and in July 2018. As of October 2021 the Chief Executive Officer of AlphaCat Capital is Christopher Schaper. AlphaCat Capital and its personnel provide the following advisory services:
• Portfolio strategy and development for existing AlphaCat Managers clients;
• Participation in the Fair Valuation Working Group of AlphaCat Managers;
• Communication with existing Fund investors;
• Developing new investment products for the Advisors;
• Structuring the Advisors’ products;
• Legal services;
• Project management services; and
• Assistance with recruitment AlphaCat Capital provides sub-advisory services in respect of AlphaCat Diversified Fund Ltd., AlphaCat Diversified Fund II Ltd., AlphaCat Advantage Fund Ltd., AlphaCat Prima Fund, Ltd., AlphaCat 2015 Ltd., AlphaCat Soteria Fund Ltd., AlphaCat Opportunities Ltd., AlphaCat Opportunities II Ltd., AlphaCat Master Fund Ltd. (collectively the “Funds”) and separately managed accounts for institutional investors (“Clients”) who have engaged AlphaCat Managers as an investment adviser or investment manager. The Advisors also perform their advisory services under the name AlphaCat. AlphaCat Managers sponsors the Funds. In relation to the Funds and Clients, AlphaCat Managers acts as the investment manager and receives certain sub-advisory services and research from AlphaCat Capital. The Advisors work together to construct portfolios for the Funds and Clients involving traditional reinstateable reinsurance contracts and collateralized reinsurance arrangements sourced through an affiliated licensed reinsurer. In addition, the Advisors structure insurance related investments in other vehicles or accounts which are not investment companies, “private funds,” or clients, as those terms are defined by the U.S. Securities and Exchange Commission (“SEC”). Client accounts are open to investors with qualifications substantially similar to investors in the Funds. Each Fund is open for investment only by qualified institutional or high net worth investors that meet the investor restrictions as set forth in the applicable Fund's subscription documents. The shares of the Funds are offered only to: (i) Non-U.S. Persons who are “qualified participants,” as defined in the Bermuda Investment Funds Act 2006 and (ii) U.S. Persons who are “qualified purchasers,” as defined in the U.S. Investment Company Act of 1940, as amended (the “U.S. Company Act”), “accredited investors,” as defined in Regulation D under the U.S. Securities Act of 1933, as amended, and “qualified participants,” as defined in the Bermuda Investment Funds Act 2006. The Funds and Clients will conduct trading activity pursuant to the investment strategies described generally below. Funds may be organized and offered for private investors generally, or may be customized for single investors or groups of

investors as agreed with AlphaCat Managers. The Advisors specialize in providing investment advisory services in property catastrophe event- linked insurance and reinsurance risk exposures including, but not be limited to, the following types of investments (together, “Risk-Linked Instruments”):
• private collateralized reinsurance arrangements sourced in traditional property catastrophe reinsurance markets, including reinstatement premium protection reinsurance contracts;
• Catastrophe bonds (principal-at-risk variable rate notes and other event-linked securities) being referred to collectively as “Cat Bonds”);
• Industry loss warranties (both indemnity-based and non-indemnity-based) binary reinsurance or derivative contracts triggered by industry-wide insurance losses (referred to collectively as “ILWs”);
• Exchange or over-the counter traded event-linked futures or derivative contracts; and
• Shares of special purpose reinsurers and other securities or instruments the return on which is linked to the occurrence of a predetermined event. The Funds and Clients themselves do not carry out insurance or reinsurance business in or from within Bermuda. All private collateralized reinsurance arrangements sourced in traditional property catastrophe reinsurance markets, including reinstatement premium protection reinsurance contracts business are entered into by AlphaCat Reinsurance Ltd., (“AlphaCat Re”) and OmegaCat Reinsurance Ltd., (“OmegaCat Re”), as applicable. AlphaCat Re was incorporated in January 2009 OmegaCat Re was incorporated in November 2018. AlphaCat Re and OmegaCat Re are registered in Bermuda as a Class 3 and Class 3A insurers, respectively, under the Bermuda Insurance Act 1978. AlphaCat Re and OmegaCat Re enable the Funds and Clients to participate in risks linked to traditional, fully-collateralized reinsurance contracts and indemnity-based ILW transactions through the issuance of variable funding notes, where necessary. AlphaCat Re and OmegaCat Re do not issue interests in themselves are not private funds as defined by the SEC. The Clients and Funds typically invest in Cat Bonds, non-indemnity based ILWs, event-linked futures and derivatives through AlphaCat Master Fund Ltd. (“Master Fund”). Master Fund was incorporated on July 23, 2008 as a Bermuda exempted, mutual fund company. The Master Fund operates as a special purpose vehicle issuing variable funding notes in relation to specific investments. The Clients and Funds may also, from time to time, invest directly in non-indemnity based Risk-Linked Instruments, including Cat Bonds and direct investments in shares of special purpose reinsurers. The respective Clients’ or Funds’ interests in Risk-Linked Instruments of AlphaCat Re, OmegaCat Re and Master Fund are documented through variable funding notes purchased from the respective vehicle which originated the investment, subject to the investment guidelines for the applicable Client or Fund. Some Clients or Funds and investment vehicles may have the ability to purchase catastrophe bonds and non-indemnity based contracts directly rather than through the Master Fund. The investments originated for all of the Clients and Funds are selected and managed by AlphaCat Managers with advice from AlphaCat Capital. The Advisors generally invest collateral, unearned premiums and uninvested assets of a portfolio in:
• Money market funds rated AAAm or Aaa-mf and holding primarily national government obligations;
• Direct U.S. Treasury obligations or direct obligations of an OECD member country rated at least AA-/Aa3;
• Cash held by a bank rated at least AA-/A3; and
• Collateral pool guaranteed by a financial institution rated at least A-/A3. AlphaCat Capital does not tailor its advisory services to the individual needs of investors (although AlphaCat Capitals’ advisory services are tailored to meet the investment mandates of the Clients and Funds, as described in the Funds’ Offering Documents and the Client investment management agreements with AlphaCat Managers). The investors may not restrict investments by the Funds in any capacity. The Funds have entered into side letter agreements with certain investors. Such agreements may provide such investors with additional notification and disclosure rights and special fee arrangements (but not preferential liquidity terms), among others. The Funds generally enter into side letters only with investors who make substantial commitments of capital. AlphaCat Capital does not participate in wrap fee programs. AlphaCat Capital provides sub-advisory services on a non discretionary basis in respect of approximately $3,438,020,483 in Regulatory Assets Under Management (“RAUM”), calculated as of January 1, 2023. RAUM is a defined term of the SEC that reflects cash and securities managed for clients as well as all assets of a “private fund” as the SEC defines that term, on a leveraged or gross basis as reflected on the gross asset value line of the balance sheet of the Funds, including committed uncalled capital. After including the proceeds from structured notes in issue and assets managed in reinsurance sidecars, AlphaCat Managers net assets under management calculated as at January 1, 2023 is approximately 3,277,568,266. The Advisors also provide advice on structuring various insurance portfolios, which fall outside of the RAUM definition.