Prodigy Asset Management, LLC (“Prodigy”) was founded in 1993 by Philip J. Ruden and Michael J. Eglseder (Principals) who are Prodigy’s principal owners. Our business model is designed to provide our clients with an Outsourced Chief Investment Officer (“OCIO”). We will work with every client to develop an investment portfolio, with a view towards increasing the breadth of asset classes in which clients invest. In our role as an outsourced Investment Office, we believe we are a cost-effective alternative to retaining an in-house staff for our clients. We work with every client to develop an investment policy statement to establish investment goals, return objectives, risk tolerances and identify investment constraints relative to a client’s specific needs. This leads to a customized asset allocation for our clients. Based on the investment policy statement, we invest the client’s assets in various asset classes, make tactical asset allocation decisions and rebalance the portfolio as necessary. In our discretionary role, we find investment firms that manage assets in the various sectors of our multi-asset strategy. It is our opinion that the most effective way to obtain access into these firms is by using low cost mutual funds and exchange traded funds (“ETFs”) that represent the various segments of the global financial markets. So that we can provide continuous and ongoing supervision over your specified accounts, you must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations) of the Account. The Account is managed by us based on accordance with your customized asset allocation we develop. We actively monitor the Account and manage the Account by buying, selling, reinvesting or holding securities, cash or other investments of the Account. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance, or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities or to retain certain securities. It is important that you understand that we manage investments for other clients and can give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell, or recommend to you any security or other investment that we may buy, sell, or recommend for any other clients or for our own accounts. Differences arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. If a higher net worth client or institution is eligible to invest in privately-offered funds (including so called “hedge funds” and “private funds” that invest in private interests) and private funds that invest in other private funds, or funds of funds (any of these funds are referred to below as “private funds”), we will also give advice concerning these interests. If a client is qualified to invest in and it is appropriate to invest in interests of private funds, the following procedures and client understanding apply regarding our efforts to invest the client’s account assets in such fund interests:
• A number of factors impact the availability of obtaining such interests for the client’s account. Investors in these funds

must meet suitability and accreditation requirements to be eligible investors, must indicate they wish to invest in these private funds (which are typically illiquid and non-transferable) and must be able to meet the fund’s required stated minimum (or lesser amount if the fund or its authorized person waives the minimum). To the extent that eligible clients cannot meet these minimum investments (or lesser amount if the general partner of a particular fund waives the minimum) or it would not be prudent for the client to meet the minimum investment from an overall suitability perspective, we will generally not indicate interest in a private fund offering for the client.
• Prodigy has an obligation to allocate investment opportunities to all clients on a fair and equitable basis, and that certain private investments may have limited capacity available to qualified clients. To the extent that private investment opportunities are part of a client’s investment strategy and if a client provides Prodigy with investment opportunities, i.e. a client is the source of such opportunities, then that client shall be allocated its full desired allocation of such investment should it be pursued and other clients will be allocated any remaining capacity pro rata, rotational or other fair basis if appropriate. If Prodigy should develop and source investment opportunities, clients shall be allocated such investment opportunities on a pro rata, rotational, or other fair basis to ensure all of Prodigy’s clients are treated fairly over time. If private fund investment capacity is available, we evaluate the risk tolerance and suitability of investing in these higher risk, more speculative investments for those clients (including our private fund of funds) meeting the investor accreditation or investment criteria and evaluate the extent to which the account(s) can meet the minimum capital commitment (or lesser amount if the fund or its authorized person waives the minimum). If there is sufficient investment capacity available and based on our understanding of the client’s ability to assume the risk associated with these more speculative investments, a private fund investment will be made at the client’s direction. In certain cases, Prodigy will recommend the use of a separately managed account (“SMA”) with a sub-adviser for implementing a sub-strategy within a client’s overall asset allocation. The use of SMAs is subject to availability from the sub-adviser and is generally restricted by characteristics such size of the investment (primary factor), type of client custodial arrangements, or other factors. SMAs offered by sub-advisers may carry different management fees or other operating expense arrangements and costs other than alternative investment vehicles available for the same investment strategy. It is possible that these fees may be lower than other vehicles. Other factors considered when recommending a SMA may include operating efficiency, reporting complexity, or lower tracking error of results across clients, etc. Prodigy serves as the investment manager to a private fund of funds, Prodigy Absolute Return Fund, LLC (“the PAR Fund”). The PAR Fund is a private fund exempt from registration PAR as an investment company under the Investment Company Act of 1940. The offer and sale of interests in the Fund are also exempt from registration under the Securities Act of 1933 and similar state laws. As investment manager, Prodigy will have sole and complete responsibility for managing the PAR Fund’s investment portfolio pursuant to the investment objectives and investment policies of the PAR Fund. We will recommend the PAR Fund as an investment opportunity to our clients which is a conflict of interest. Please refer to Items 5, 10 and 11 for more information about this conflict of interest and our procedures designed to mitigate the potential conflict of interest. Prodigy has discretionary authority and is responsible for establishing and implementing the PAR Fund’s investment objectives and policies. (See Item 15 for more information). The PAR Fund is organized as a private fund of hedge funds to allocate its assets among various investment strategies in an effort to generate long term positive returns with a low correlation to the equity market. Potential investors receive a copy of the applicable Confidential Private Offering Memorandum and are required to execute a subscription agreement in order to subscribe for interests in the PAR Fund. As of December 31, 2022, we had $3,393,279,476 in regulatory assets under management on a discretionary basis. We do not participate in a wrap fee program.