Adviser Efficient Capital Management, LLC (“Efficient”) works as a commodity trading advisor (“CTA”) specialist alongside investors to target specific portfolio goals, styles and strategies within managed futures portfolios which are managed by third-party CTAs. Efficient can tailor funds for investors by targeting volatility levels, restricting the trading of certain futures contracts or securities and accepting currencies other than U.S. Dollars. Efficient’s Clients consist of commodity pools managed by Efficient as the Commodity Pool Operator (“CPO”) or Investment Manager of the Client. Qualified investors may invest in the Clients. Efficient also advises and acts as a Sub-Advisor or Advisor for certain non-U.S. funds that are not controlled or operated by Efficient. As of the date of this Brochure, Efficient manages only one “private fund” as defined by the SEC, Efficient US Funds, LLC – Gemstone-Enhanced Multi- Asset Series. This fund employs a combination of managed futures Trend Following strategies and multi-asset Risk Parity strategies. Efficient currently manages no registered investment companies, although it may do so in the future. As of December 31, 2023, Efficient managed $ 1,004,486,042 in aggregate securities “regulatory assets under management”, as such term is defined by the SEC. As of December 31, 2023, Efficient managed approximately $ 2,479,937,762 in aggregate nominal assets under management for its Clients, which is a term commonly used in the managed futures industry. “Nominal assets” refers to the amount of cash plus notional funds (i.e., trading level) to be utilized for trading in managed futures and other commodity interests pursuant to third-party CTAs’ trading programs, as agreed- upon between the Clients and the CTAs. History Founded in 1999 by its principal owner, Ernest L. Jaffarian, Efficient was built on many previous years of experience in the financial futures industry. After having worked at Chicago Research and Trading in a variety of roles, including as a market maker for listed options and at his own CTA, Sandpiper Trading, Mr. Jaffarian took a position in January 1997 at Hull Trading Company to develop and manage an off‐site proprietary trading business that developed and expanded CTA allocation methodologies over the succeeding few years. As a result of an initial public offering being offered by Hull Trading Company, Mr. Jaffarian was given the opportunity to form a separate company. Efficient officially launched as an independent company on May 1, 1999. As a separate legal entity, Efficient was free to manage outside assets. Efficient is organized as a Delaware limited liability company. Jaffarian Management Company, LLC, an Illinois limited liability company, is the majority owner and the manager of Efficient Capital Holdings, LLC, an Illinois limited liability company and Efficient’s parent, and the manager of Efficient. Mr. Jaffarian is the managing member and majority owner of Jaffarian Management Company, LLC. Through this holding company structure, Mr. Jaffarian controls Efficient. 5 | P a g e In 2004, Efficient launched its master trading fund, Efficient Trading Limited (“ETL”), a Cayman Islands exempted company and Mutual Fund registered with the Cayman Islands Monetary Authority, along with its feeder funds. The fund’s objective was to make the unique features of its large institutional managed account portfolios available to fund investors by providing access to a diversified multi-manager portfolio of CTAs, through managed accounts, with daily risk monitoring, back office operations and technology systems of institutional quality. This new fund structure allowed Efficient to begin offering different levels of volatility, fees and currency exposure. Current Business Activities In 2014, Efficient launched customized portfolios as a new service for investors. In addition to its master trading fund, ETL, Efficient now has various single CTA/advisor and multiple CTA/advisor funds (each, along with ETL and its feeder funds, a “Fund” and collectively, the “Funds”) and can provide customized portfolios through its Funds. The Funds may also collectively be referred to as the “Clients” hereinafter, and each, a “Client”. In offering such customization, investors in Clients can request that Funds be tailored to meet their needs which may include restricting certain instruments from trading or investing in futures or securities other than those currently traded. Investors in Clients may also negotiate special terms other that those stated in the Private Placement Memorandum or Offering Memorandum of a Client (each, an “OM”) which may result in the creation of an OM supplement or side letter. Not all Efficient’s Clients permit customization. There are various levels of customization, all of which can differ by Client. As a result of such customization, Clients can be organized and offered into separate segregated portfolios or series, or separate classes of shares/interests, each with their own business and investment terms (including but not limited to, leverage/portfolio exposure, fees, notices and transparency of information, and liquidity). Each segregated portfolio/series or class of shares/interests of a Client generally will have a separate Letter from the Directors (in the case of an offshore Client) or Letter from the Manager (in the case of a U.S. Client), as applicable, further outlining the material investment terms of the portfolio/series or class, while the OM itself will contain general terms, conditions and disclosures. The Letter from the Directors or Manager will thus supplement, and be considered a part of, the Client’s OM. References in this Brochure to the term “OM” will be deemed

to also include the applicable Letter from the Directors or Manager, as applicable, if any. Efficient’s role as the CPO for the Clients enables Efficient to select or terminate CTAs or other investment managers (each, an “Advisor” and collectively, the “Advisors”) to trade the Clients’ assets. Funds may include single-Advisor or multiple-Advisor Funds, selected by Efficient on a discretionary basis or recommended by Efficient on a non-discretionary basis, based on the specific investment objectives and strategies of the Client. The Advisors employ managed futures strategies (focused on futures contracts, options on futures, foreign currency forward contracts and other commodity interests). However, as a complement to their futures strategies, certain Advisors also may incorporate other investment instruments to a Client’s portfolios, such as security futures (single stock futures), securities-based swaps, options and other derivatives, cash securities such as stocks, bonds, notes and exchange-traded funds, such as in broad-based multi-asset risk parity strategies. A portion of a Client’s assets could also be allocated to Advisors that trade securities strategies exclusively, as opposed to futures-focused strategies that incorporate some securities 6 | P a g e instruments. Even so, however, the extent of any such non-futures trading is expected to be minimal, if any. The Clients will access each Advisor’s strategy via separately managed accounts held in the name of the Client directly, or indirectly through one or more Efficient-managed Clients that serve as master trading funds or subsidiary trading vehicles which will hold the managed accounts. Certain Clients may also access an Advisor’s strategy by investing in collective investment funds managed and sponsored by the Advisor, as opposed to Efficient. Cash Management and Custodian Except as described below, excess cash which is not utilized for margin for trading or deposited in a separate bank account is held in cash accounts which will be managed by an independent third party (the “Cash Manager”) held in the name of the Client. Given the leveraged nature of futures trading and managed futures investing, it is expected that such excess cash will comprise a significant portion of Client assets. The Cash Manager invests, on a discretionary basis, all or part of the funds held in the cash account in a portfolio of short-term, liquid, interest-bearing investments, potentially including but not limited to, U.S. Treasury securities, U.S. agency securities, U.S. government money market funds, repurchase agreements, commercial paper and other permitted liquid investments, subject to standing investment guidelines and the current liquidity needs of the particular account which Efficient determines and communicates periodically to the Cash Manager, Columbia Management Investment Advisers, LLC (“CTI”), an SEC-registered investment adviser. Efficient periodically reviews the Cash Manager’s activities for the accounts and may cause a Client to engage a new Cash Manager or additional Cash Managers at any time in its sole discretion (unless otherwise agreed with the Client). Clients will pay the Cash Manager a fee equal to a percentage of the account’s cash assets under management. Notwithstanding the foregoing, in Efficient’s sole discretion, certain Client accounts (particularly, small accounts) may not utilize the services of CTI as the Cash Manager. Such Clients’ cash will be held in one or more money market funds held by the Custodian, except as described below. Except as described below, custody of a Client’s cash assets is held at Midwest Institutional Trust Company (“MITC”) (the “Custodian”) in an institutional custody account. MITC succeeded to the institutional custody business of BMO Bank, N.A., Efficient’s prior custodian. MITC is a trust company licensed with and regulated by the State of Kansas Office of the State Bank Commissioner, and its principal business address is 5901 College Boulevard, Suite 100, Overland Park, Kansas 66211. MITC is part of the Midwest Family of Companies, which are privately held independent trust, investment management and service companies with approximately $500 billion in total trust and custody assets. In Efficient’s sole discretion, certain Client accounts may not have institutional custody accounts with the Custodian as described above, but rather may have non-custodial, deposit accounts at the Custodian, which may or may not bear interest. Please contact Efficient for confirmation regarding the cash management and custodial/banking arrangements that may be applicable to your particular account. Additional disclosure may be provided in the OM or other applicable Fund documentation. Clients will pay customary fees to the Cash Manager, Custodian, and bank, as applicable, for their services. Efficient’s cash management and custodial arrangements, and the fees for such services, 7 | P a g e are subject to change. Efficient may appoint additional or replacement Cash Managers and Custodians for any Client at any time without notice (except as otherwise agreed with a Client, where applicable). Alternatively, in the future Efficient may directly assume the foregoing cash management responsibilities instead of a third-party firm, and may receive a separate fee for its cash management services, if so disclosed. Futures Registrations Efficient is registered with the Commodity Futures Trading Commission (“CFTC”) as a CPO and a CTA and is a member of the National Futures Association (“NFA”) (NFA ID No. 293441). Such registrations and membership do not imply the CFTC or the NFA has endorsed Efficient’s qualifications to provide investment management services.