Drum, a Connecticut limited liability company, provides private equity turnaround, special situations, deep value and distressed investment advisory services to clients on a discretionary basis through investments in private equity funds, hedge funds, co-investments, separate accounts and direct private investments. Investments are made through both fund of fund and direct investment fund vehicles managed by Drum, and offered to institutional investors and high net worth individuals. The funds of funds and direct investment funds managed by the registrant are not registered under the Investment Company Act of 1940, as amended, in reliance on Section 3(c)(7) thereof. Investments are made primarily in private equity pooled vehicles (e.g., limited partnerships), but occasionally, direct investments in privately-owned companies are made by the funds ("Direct Investments"). Private equity investments include but are not limited to the following: recapitalization; subordinated obligation; equity expansion; recovery; turnaround, special situations, deep value and other private equity-related strategies. Drum’s principal owner is Scott E. Vollmer, Founder and Chief Executive Officer. Drum serves as a manager to four privately-held funds of funds and three direct investment funds sponsored by Drum that make private equity investments in distressed, deep value and turnaround special situations (collectively, the "Funds"). Each of Drum Opportunities I GP LP (“DO I GP”), Drum, Drum Special Situation Investment LLC, Drum Special Situation Investment III LLC and Drum Special Situation Investment IV LP (collectively referred to herein as the “General Partner”) act as a general partner or investment manager to one or more Funds. The Funds currently comprise: Special Situation Partners II LP ("SSP II"), Drum Opportunities I LP (“DO I”), Drum Opportunities II LLC (“DO II”), EID Ultimate Holdings, LLC (aka Drum Opportunities III LLC) (“DO III”), Drum Special Situation Partners III LP ("SSP III"), Drum Special Situation Partners IV LP (“SSP IV”) and Drum Special Situation IV-C LP (“SSP IVC”). DO I GP acts as general partner to DO I, Drum acts as investment manager to DO II and DO III, Drum Special Situation Investment LLC acts as general partner to SSP II, Drum Special Situation Investment III LLC acts as general partner to SSP III and Drum Special Situation Investment IV LP acts as general partner to SSPIV and SSPIVC. Either Drum or Scott E. Vollmer has control over each entity comprising the General Partner as the managing member, managing partner or controlling manager thereof. In 2018, Drum began managing a new private fund, DO I. DO I was established to facilitate the purchase of the remaining

investments of one of Drum’s legacy private funds, PCG Special Situation Partners LP (“SSP I”), which has since been fully liquidated and dissolved. In December 2018, DO I purchased two investments from SSP I, which was the result of a competitive bid process to monetize SSP I’s last two remaining operating companies. Drum continues to manage the assets that were purchased by DO I. The Funds share a similar objective: to seek to provide investors with superior, risk-adjusted, long-term capital appreciation through the development of a diversified portfolio of turnaround, special situation, deep value and distressed debt investments, generally with a focus in the lower to middle market. Drum has full discretion in investment decisions made on behalf of the Funds. Investment advice is provided directly to the Funds according to each Fund’s particular investment objectives and not individually to the Fund’s investors. From time to time and as permitted by the relevant Funds’ governing documents, Drum expects to provide (or agree to provide) co-investment opportunities (including the opportunity to participate in co-invest vehicles) to certain investors or other persons, including other sponsors, market participants, finders, consultants and other service providers, Drum’s personnel and/or certain other persons associated with Drum. Such co-investments typically involve investment and disposal of interests in the applicable portfolio company at the same time and on the same terms as the Fund making the investment. As of December 31, 2023, Drum managed approximately $693,000,0001 of client assets on a discretionary basis and no client assets on a non-discretionary basis.
1 For Funds that are funds of funds (SSP II, SSP III, SSPIV and SSPIVC), Drum relies on the quarterly financial statements and capital statements from its underlying fund managers for most of its underlying valuations, which are not generally received until 90 days after each quarter end. Accordingly, the most recent financial statements and capital statements Drum has received for most of the underlying funds in which such funds of funds invest are as of September 30, 2023. Drum has calculated regulatory assets under management by adding: (i) the assets of Funds that are as of September 30, 2023 as well as DO I and (ii) the assets of the other Funds (DO II and DO III) as of December 31, 2023. The regulatory assets under management associated with DO II and DO III, and accordingly, Drum in aggregate, include investments valued at approximately $5,133,018 and $4,199,740 by SSP IV and SSP IVC into DO II and $5,748,220 and $3,832,147 by SSP IV and SSP IVC into DO III, and therefore represent duplicative amounts.