Advisory Business Founded in December 2015, Cadogan Park Advisors Inc. (hereinafter, “Cadogan Park” or the “Firm”) is an investment advisor registered with the U.S. Securities and Exchange Commission (the “SEC”). The Firm is wholly owned by Paul Bains as the Principal. The Firm provides investment management services to its clients (individually, the “Client”). This Brochure is not: a) an offer or agreement to provide advisory services to any person, b) an offer to sell interests (or a solicitation of an offer to purchase interests) in any investment fund, or c) a complete discussion of the features, risks or conflicts associated with any investment fund, or any other product or service offered by Cadogan Park. Cadogan Park Advisors Inc. is also registered as a Portfolio Manager with each of the following Canadian Securities Commissions: British Columbia, Alberta, Ontario and New Brunswick. The Registrant provides investment advisory services to high-net-worth individuals, other individuals, corporations, businesses and on a sub-advisory basis. Investment decisions are based upon each client’s Investment Policy Statement (IPS). The assessment of a client’s risk and return objectives is achieved through the completion of the client’s personal profile questionnaire, including the client’s personal financial situation, investment objectives and risk tolerance. This information combined with any input from the client’s other professional advisors, is then finalized in a mutually agreed IPS. The client’s assets are then invested in accordance with the guidelines defined in the IPS, which may also indicate the eligible investments to be used to achieve the portfolio’s investment mandate. Cadogan Park engages in specialized services that may appeal to expatriate individuals or those individuals that reside in one jurisdiction while they continue to have assets in another jurisdiction (cross border services). Cadogan Park’s activities with respect to non- U.S. clients may differ from those described generally herein and Cadogan Park or its affiliate, Firethorn Partners, may provide additional or different services to non-U.S. clients. Furthermore, any discussion of activities with respect to non-U.S. clients is intended solely to provide recipients a more complete understanding of Cadogan Park’s business, including potential conflicts of interest. The Registrant may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers (Sub- Advisors) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) shall have day-to-day responsibility for the active discretionary management of the allocated assets. The Registrant shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which the Registrant shall consider in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The Registrants’ activities with respect to non-U.S. clients may differ from those described generally herein and the Registrant may provide additional or different services to non-U.S. clients. Furthermore, any discussion of activities with respect to non-U.S. clients is intended solely to provide recipients a more complete understanding of the Registrants’ business, including potential conflicts of interest. In addition to the IPS, each client will formally agree to engage the services of Cadogan Park through an Investment Management Agreement (IMA). This document includes information on the client’s identity and personal financial situation. It is the responsibility of the client to keep Cadogan Park updated on an ongoing basis with respect to any information contained in the IMA, including any significant changes to their personal or financial situation that could impact the appropriateness of the client’s IPS. 2. Investment Advisory Services Cadogan Park combines knowledge and experience, with objective financial advice from financial advisors who act in the best interest of our clients. We charge one all-inclusive fee for our Advisory Services. A Client’s assets are managed within a given Personal Strategy based upon the Client’s overall investment objectives. A Personal Strategy is a comprehensive investment portfolio. It is focused on achieving the Client’s financial goals and is designed to grow with the Client over time. Portfolios in

a Personal Strategy are custom designed and are flexible to meet the Client’s needs or wants. Personal Strategy asset allocations go beyond basic stock and bond portfolios. They invest globally, primarily utilizing individual equities and ETFs. Our tactical index weighting approach adds further diversification and potential return by ensuring exposure to all areas of the market while avoiding being overweight to high-risk segments. Cadogan Park believes that asset allocation is a key investment decision. The goal-based nature of a Personal Strategy means the Client’s asset allocation is continuously linked to their evolving situation, thereby maximizing the likelihood of long-term success. In most cases, the Registrant manages clients’ accounts on a discretionary basis where we have authority to manage a client’s portfolio directly and purchase or sell securities without obtaining approval before effecting each trade. In other cases, the Registrant provides advisory investment management services where a client’s portfolio is monitored on a day- to-day basis but buy and sell actions are executed by a Sub-Advisor(s). In this latter regard, we oversee the Sub-Advisors and coordinate, monitor and direct their activities as and where appropriate. Cadogan Park primarily provides investment advisory services to:
• Individuals
• High-net worth individuals
• Trust, estates or charitable organizations
• Multiple Family Offices IRA Rollover Recommendations For the purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, we are providing the following acknowledgment to clients. When Cadogan Park provides investment advice to clients regarding their retirement plan account or individual retirement account, Cadogan Park is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way Cadogan Park makes money creates some conflicts with client interests. Cadogan Park operates under an exemption that requires Cadogan Park to act in the clients’ best interest and not put Cadogan Parks’ or Cadogan Parks’ employees’ interests ahead of the clients. Under this exemption, Cadogan Park must: a. meet a professional standard of care when making investment recommendations (give prudent advice), b. never put Cadogan Parks’ or Cadogan Parks’ employees’ financial interests ahead of the clients when making recommendations (give loyal advice), c. avoid making misleading statements about conflicts of interest, fees, and investments, d. follow policies and procedures designed to ensure that Cadogan Park and Cadogan Parks’ employees give advice that is in the clients’ best interest, e. charge no more than is reasonable for services, and f. give the clients basic information about conflicts of interest. Cadogan Park benefits financially from the rollover of the clients’ assets from a retirement account to an account that Cadogan Park manages or provides investment advice, because the assets increase Cadogan Parks’ assets under management and, in turn, Cadogan Parks’ advisory fees. As a fiduciary, Cadogan Park only recommends a rollover when Cadogan Park and Cadogan Parks’ employees believe it is in the clients’ best interest. Pooled Investment Vehicles Cadogan Park serves as the manager of the Investment Manager for the Tilton Opportunities Canadian Feeder Fund and the Tilton Opportunities Cayman Master Fund I, LP (the “Fund”). The Fund’s objective is to provide unit holders with long-term capital appreciation primarily through exposure to investments in a professionally managed portfolio of developed market equity securities traded predominantly in the financial markets located in North America and Europe. The Fund is exempt from registration pursuant to Rule 506(b) of the Securities Act of 1933 and relies on an exemption from the Investment Company Act of 1940 under 3(c)-1. Investments in the Fund are deemed to be high risk investments and for that reason, the offerings are available only to accredited investors in eligible jurisdictions, who can bear the risk of loss of their investment. This Disclosure Brochure provides only a broad summary of the information provided in the offering documents. Investors should refer to the specific Fund Offering Document for definitive and more comprehensive information regarding a specific investment concept and the matters described in this Brochure. 3. Assets Under Management Cadogan Park has $36,334,985 direct assets under management.