9AT: VALSPRING CAPITAL

other names

VALSPRING CAPITAL
VALSPRING CAPITAL MANAGEMENT, LP

Adviser Profile

As of Date	03/26/2026
Adviser Type - Large advisory firm
Number of Employees	7 17%
of those in investment advisory functions	5 25%
Registration	SEC, Approved, 07/28/2023
Other registrations (4)	SEC, 120-Day Approval, 07/28/2023 SEC, Terminated, 06/29/2023 SEC, 120-Day Approval, 03/31/2023 SEC, Terminated, 02/03/2023
Former registrations	VALSPRING CAPITAL MANAGEMENT, LP VALSPRING CAPITAL MANAGEMENT, LP VALSPRING CAPITAL MANAGEMENT, LP

AUM^*	336,927,417 136%
of that, discretionary	336,927,417 136%
Private Fund GAV^*	217,792,253 -11%
Avg Account Size	336,927,417 136%
SMA’s	No
Private Funds	2 1
Contact Info	617 xxxxxxx
Websites

Client Types

- Pooled investment vehicles

Advisory Activities

- Portfolio management for pooled investment vehicles

Compensation Arrangments

- A percentage of assets under your management

Fund Type	Count	GAV
Fund TypePrivate Equity Fund	Count1	GAV$217,792,253
Fund TypeVenture Capital Fund	Count1	GAV$

Adviser	Hedge Fund	Liquidity Fund	Private Equity Fund	Real Estate Fund	Securitized Asset Fund	Venture Capital Fund	Other Fund	Total Private Fund GAV	AUM	#Funds
Adviser CATHAY CAPITAL NA, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund63.0m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV63.0m	AUM76.6m	#Funds3
Adviser JLL PARTNERS FCH, INC.	Hedge Fund-	Liquidity Fund-	Private Equity Fund132.4m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV132.4m	AUM132.4m	#Funds1
Adviser FEATHERINGILL CAPITAL, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund117.9m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV117.9m	AUM142.9m	#Funds6
Adviser RAND CAPITAL MANAGEMENT	Hedge Fund-	Liquidity Fund-	Private Equity Fund73.8m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV73.8m	AUM136.7m	#Funds2
Adviser GOLDIRON GP LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund60.2m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV60.2m	AUM60.2m	#Funds1
Adviser ALLIANCE INVESTMENT MANAGEMENT, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund4.1m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV4.1m	AUM206.8m	#Funds1
Adviser DELTA CAPITAL PARTNERS MANAGEMENT LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM90.1m	#Funds-
Adviser STONE CREEK GROUP, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund16.8m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV16.8m	AUM250.6m	#Funds3
Adviser ASH INVESTMENT PARTNERS, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund385.7m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV385.7m	AUM185.7m	#Funds2
Adviser APEX INVESTMENTS MANAGEMENT US, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund392.5m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV392.5m	AUM392.5m	#Funds1

Brochure Summary

Overview

For purposes of this brochure, the “Adviser” means Valspring Capital Management, LP a Delaware limited partnership, together (where the context permits) with its affiliated general partners of the Funds (as defined below) and other affiliates that provide advisory services to and/or receive advisory fees from the Funds. Such affiliates may or may not be under common control with Valspring Capital Management, LP, but possess a substantial identity of personnel and/or equity owners with Valspring Capital Management, LP. These affiliates may be formed for tax, regulatory or other purposes in connection with the organization of the Funds, or may serve as general partners of the Funds. The Adviser provides investment supervisory services to investment vehicles (the “Funds”) that are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”) and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”). The Funds make primarily long-term growth, private equity and equity-related investments, as well as investments in debt instruments. In accordance with the Funds’ respective investment objectives, investments are generally made in companies doing business in the healthcare industry. The Adviser’s advisory 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 Adviser may serve as the investment adviser or general partner to the Funds in order to provide such services. The Adviser provides investment supervisory services to each Fund in accordance with the limited partnership agreement (or analogous organizational document) of such Fund or separate investment and advisory, investment management or portfolio management agreements (each, an “Advisory Agreement”). Investment advice is provided directly to the Funds, subject to the discretion and control of the applicable general partner, and not individually to the investors in the Funds. Services are provided to the Funds in accordance with the Advisory Agreements with the Funds and/or organizational documents of the applicable Fund. Investment restrictions for the Funds, if any, are generally established in the organizational or offering documents of the applicable Fund, Advisory Agreements and/or side letter agreements negotiated with investors in the applicable Fund (such documents collectively, a Fund’s “Organizational Documents”). The principal owner of Valspring Capital Management, LP is Yumin Choi. The Adviser has been in business since 2022.

VALSPRING CAPITAL

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Brochure Summary

Overview