A. Background Verdad is a Delaware limited partnership that that was formed in March 2014 for the purpose of providing investment advisory services to pooled investment vehicles and separately managed accounts. Verdad is headquartered in Boston, Massachusetts. The primary sole beneficial owner of Verdad is Mr. Daniel Rasmussen. B. Description of Advisory Firm Verdad currently provides investment advisory services to private funds (referred herein as the “Funds” or “Clients”) on a fully discretionary basis and may sponsor and /or advise additional private funds or separately managed accounts (the “Managed Account Clients”). Verdad invests primarily in leveraged small value stocks – small companies with a high ratio of net debt to enterprise value and a low ratio of enterprise value to cash flow. Verdad believes that investing in companies that will generate equity returns through the pay down of debt may generate superior returns for investors. Verdad primarily invests in securities, consisting principally, but not solely, of equity and equity- related securities of issuers that are traded publicly in U.S. and non-U.S. markets. The Adviser may also seek to invest in preferred stocks, convertible securities, options (including covered and uncovered puts and calls and over-the-counter options), derivative instruments, bonds and other fixed income securities, non-U.S. currencies, commodity interests, private securities, money market instruments and cash and cash equivalents. See Item 8 - Methods of Analysis, Investment

Strategies and Risk of Loss of this Brochure for more information on Verdad’s investment strategies philosophy, context and process, including portfolio construction. C. Types of Advisory Services Offered Verdad’s advisory services to the Funds primarily consists of managing a Fund’s portfolio, pursuant to an investment management agreement or other similar agreement (the “Management Agreement”), to each respective Fund in accordance with each Fund’s respective private placement memorandum, offering memorandum, offering circular, limited partnership agreement, indenture or other similar disclosure and governing documents (collectively, the “Offering Documents”). Managed Account Clients may place investment restrictions on the Adviser and tailor the advisory services to their individual needs. The Managed Account Clients may also have certain portfolio liquidity, concentration and exposure limits, in addition to being prohibited from trading specified instruments.  D. Services Tailored to Individual Needs of Clients Verdad tailors its advisory services to the specific investment objectives and strategy of the Clients it advises, in accordance with the investment objectives, policies, and guidelines set forth in the Funds’ Offering Documents. E. Wrap Fee Programs Verdad does not participate in wrap fee programs. F. Client Assets Under Management As of December 31, 2023, Verdad manages $740,543,488 of regulatory assets under management on a discretionary basis.