BPCM is an SEC-registered investment adviser whose principal place of business is 1300 El Camino Real Suite 100 Menlo Park, CA 94025. BPCM began conducting business in 2006. Sanjeev Sardana, Chief Executive Officer, is the firm's sole principal owner (i.e., those individuals and/or entities controlling 25% or more of this company). BPCM provides investment management and consulting services to clients listed in Item 7 below. INVESTMENT MANAGEMENT SERVICES BPCM provides investment advice to clients based on the individual needs of each of its clients. After reviewing each client’s financial circumstances and determining each client’s goals and objectives, we create and manage a portfolio based on those goals and objectives. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. We will manage accounts on either a discretionary or non-discretionary basis. Based on the client’s needs, portfolios will include some or all of the below-listed investments: o Exchange-listed securities o Securities traded over the counter (“OTC”) o Securities of foreign issuers o Warrants o Corporate debt securities o Commercial paper o Certificates of deposit o Municipal securities o Mutual fund shares o Exchange-traded funds (“ETFs”) o United States governmental securities o Options contracts on securities o Interests in partnerships investing in real estate o Interests in partnerships investing in oil and gas o Interests in private equity, venture capital funds, and private companies o Hedge funds and private funds o Cash or cash equivalents The foregoing investments will only be implemented when consistent with the clients’ stated investment restrictions, limitations, and prohibitions. Moreover, since some investments involve certain additional degrees of risk relative to others; they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Where appropriate, BPCM also recommends the use of independent investment manager(s) (“Independent Manager(s)”) to manage certain types of investments in the client’s portfolio. We will monitor and review the performance of the recommended Independent Managers. Before making a recommendation, we conduct extensive due diligence of an Independent Manager, generally examining the following items:
• Management style
• Performance
• Reputation in the industry generally
• Financial strength
• Reporting
• Pricing
• Research
• Keyperson risk BPCM also may render non-discretionary investment management services to clients relative to their individual employer-sponsored retirement plans. In so doing, BPCM either directs or recommends the allocation of client assets among the various security subdivisions that comprise the retirement plan. The client assets shall be maintained at the custodian designated by the sponsor of the client’s retirement plan. As of December 31, 2023, BPCM managed $500,691,655 on a discretionary basis and $263,515,836 on a non-discretionary basis, resulting in total assets under management of $764,207,491. CONSULTING SERVICES Clients may receive investment advice on a more focused basis. We provide specific consultation and administrative services regarding investment and financial concerns of the client. We will also consult on insurance matters, including any underlying securities. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. POOLED INVESTMENT VEHICLES BPCM is the manager of BluePointe Private Equity Partners, LLC; a Delaware limited liability company ("BluePointe PE Fund" or “the Fund”). BPCM formed BluePointe PE Fund as a fund of funds to provide its clients and certain other qualified investors with access to a diversified portfolio of private equity investments and private real estate investments through investment in a group of investment funds. The objective of the Fund is to generate significant, long-term

capital appreciation for the Fund's investors. The Fund is a closed investment vehicle and is currently not accepting new subscriptions. BPCM is the manager of BluePointe Distressed Credit Fund, LLC; a Delaware limited liability company ("BluePointe DC Fund"). BPCM formed BluePointe DC Fund in order to provide its clients and certain other qualified investors with access to Colony Distressed Credit Fund II, L.P., a Delaware limited partnership (“CDCF II”). The objective of BluePointe DC Fund is to generate current income and long- term capital appreciation for that fund’s investors. The BluePointe DC Fund has been organized to invest substantially all of its capital in a limited partnership interest or interests in CDCF II. CDCF II will seek investments in, and active management of, a diversified investment portfolio of performing, sub-performing and nonperforming commercial mortgage loans and other attractively priced real estate-related debt investments. The BluePointe DC Fund is a closed investment vehicle and is currently not accepting new subscriptions. BluePointe Ventures, LLC (“BPV”) is a Delaware limited liability company that is owned by Sandeep Sardana and Sanjeev Sardana. BPV acts as the investment manager to pooled investment vehicles structured as limited liability companies (each referred to in this Brochure as a “BPV Fund”) and is responsible for all investment decisions by and investment activities of the BPV Funds. BPV is also responsible for the day- to-day operations of the BPV Funds. Sandeep Sardana is primarily responsible for the BPV Funds’ investment activities and acts as the Managing Director of BPV and investment manager to the BPV Funds. Sanjeev Sardana acts as the Chairman of BPV and provides general oversight and fundraising for the BPV Funds. Because BPV is “operationally integrated” with BPCM, BPCM will be responsible for the reporting of the BPV Funds as private funds on its regulatory filings and in this disclosure brochure. Because of his ownership in BPV, Sanjeev Sardana is entitled to receive a pro rata share of the special profit allocation payable to BPV by the BPV Funds. Some BPV Funds are structured so that Sanjeev Sardana, and BPCM, as a firm, are entitled to receive a special profit allocation payable by the BPV Funds as outlined in the applicable limited partnership agreement. BPCM, including Sanjeev Sardana therefore have an incentive to encourage clients to invest in the BPV Funds, which could be viewed as a conflict of interest between BPCM and its clients. For certain BPV Funds in which BPCM clients invest, the client will not directly pay an advisory fee to BPCM for their investment in BPV Funds, and for certain BPV funds in which BPCM clients invest, a portion of the management fee received by BPV will be paid to BPCM. For BPV TechFund III, LP and BPV SOF 1, LP, BPCM advisory clients pay advisory fees to BPCM, however they pay a reduced BPV management fee on those funds. Furthermore, there is a possibility that certain vendors, funds, or fund managers in which BPCM directs investments, could be investors in BPV Funds. While BPCM is motivated to maximize returns and minimize risk for its clients, the foregoing factors could impact BPCM’s objectivity as it relates to affiliated funds and could be a factor considered by BPCM in choosing among the various investment alternatives otherwise available to its clients. Tomitigate this conflict, BPCM recognizes its fiduciary duty to its advisory clients and puts the clients’ interests first. All such decisions must follow these procedures regardless of compensation structure, perceived incentives to BPCM, or any other conflicts. BPCM is the investment sub-advisor of BluePointe Insurance Dedicated Fund of the SALI Multi-Series Fund, L.P. (“BluePointe ID Fund”), a Delaware Limited Partnership. The investment objectives of BluePointe ID Fund are (i) to achieve absolute returns on a risk-oriented basis; and (ii) to generate returns through a multi-manager strategy while attempting to control risk. The emphasis will include all sectors of publicly traded United States equities, foreign securities, options, convertible securities, debt securities, and all other types of securities and securities of privately held companies and private funds.