A. Description of Firm: CPM is a Colorado limited liability company that provides investment advisory services to private investment funds (“Funds”) and separately managed accounts (“SMAs” and together with the Funds “clients”). Kevin C. Smith, CFA, is the principal owner of CPM, and has been the primary portfolio manager for each of CPM’s private investment funds and SMA strategies since their inception. Mr. Smith started the “Large Cap Long-Only SMA” strategy (defined below) in 1999 and launched the “Long/Short Funds” (defined below) in 2000 (originally a single fund). He formed CPM in 2005 and then launched the “Global Macro Funds” (defined below) in 2006 (originally a single fund), the “Precious Metals SMA” strategy (defined below) in 2019, and the “Precious Metals Funds” (defined below) in 2020. CPM currently advises five master-feeder structures, the Global Macro, Long/Short, Precious Metals, Institutional Commodity, and Institutional Macro Funds. The SMAs advised by CPM are primarily owned by high-net-worth individuals, family offices and retail investors, and generally follow two strategies: (i) large cap long-only (each a “Large Cap Long-Only SMA”); and (ii) precious metals (each a “Precious Metals SMA”). CPM is a wholly owned subsidiary of Crescat Capital LLC and is a global macro asset management firm. CPM and its affiliates each provide a variety of administrative and management services to CPM’s clients. CPM’s affiliates include: Crescat Partners LLC, the general partner of the Global Macro and Precious Metals Funds; Crescat Hedge Partners LLC, the general partner of the Long/Short Funds; Crescat Institutional Commodity Partners LLC, the general partner of the Institutional Commodity Funds; Crescat Institutional Macro Partners LLC, the general partner of the Institutional Macro Funds; and Crescat Capital LLC, the parent company of CPM. B. Description of Advisory Services Offered: As described above, CPM advises the following clients:  The “Global Macro Funds” are organized as a master-feeder structure comprised of: Crescat Global Macro Master Fund LTD, a Cayman Islands exempted company (the Master Fund); Crescat Global Macro Fund LTD, a Cayman Islands exempted company (the Offshore Feeder); Crescat Global Macro Fund LP, a Delaware limited partnership (the Onshore Feeder); and Crescat Global Macro QP Fund LP, a Delaware limited partnership (the Qualified Purchaser Onshore Feeder). There is no limitation on the duration of the Global Macro Funds.  The “Long/Short Funds” are organized as a mini-master structure comprised of: Crescat Long/Short Master Fund LTD, a Cayman Islands exempted company (the Master Fund); and Crescat

Long/Short Fund LP (the Onshore Feeder). There is no limitation on the duration of the Long/Short Funds.  The Precious Metals Funds are organized as a master-feeder structure comprised of: Crescat Precious Metals Master Fund LTD, a Cayman Islands exempted company (the Master Fund); Crescat Precious Metals Fund LTD, a Cayman Islands exempted company (the Offshore Feeder); Crescat Precious Metals Fund LP, a Delaware limited partnership (the Onshore Feeder); and Crescat Precious Metals Fund II LP, a Delaware limited partnership (the Qualified Purchaser Onshore Feeder). There is no limitation on the duration of the Precious Metals Funds.  The Institutional Macro Funds are organized as a master-feeder structure comprised of: Crescat Institutional Macro Master Fund LTD, a Cayman Islands exempted company (the Master Fund); Crescat Institutional Macro Fund LTD, a Cayman Islands exempted company (the Offshore Feeder); and Crescat Institutional Macro Fund LP, a Delaware limited partnership (the Onshore Feeder).  The Institutional Commodity Funds are organized as a master-feeder structure comprised of: Crescat Institutional Commodity Master Fund LTD, a Cayman Islands exempted company (the Master Fund); Crescat Institutional Commodity Fund LTD, a Cayman Islands exempted company (the Offshore Feeder); and Crescat Institutional Commodity Fund LP, a Delaware limited partnership (the Onshore Feeder).  The Large Cap Long-Only SMA is a separately managed account strategy offered to retail investors.  The Precious Metals SMA is a separately managed account strategy offered to retail investors. C. Flexibility of Services: CPM serves SMA clients whose objectives are a combination of growth, income, capital preservation, and diversification. CPM also caters to SMA clients whose investment time horizons are long-term. CPM’s strategies may not be suitable for all SMA clients, and CPM tailors its recommended allocation of SMA client assets among its investment strategies based on the unique objectives and risk tolerance of each client. CPM can work with clients who impose investment restrictions only if they are invested in a SMA strategy. CPM manages the Funds in a manner consistent with the investment strategy described in the Funds’ offering documents. Investment advice is provided directly to the Funds. CPM does not provide specifically tailored advice to investors in the Funds D. Description of Wrap Fee Programs: CPM does not participate in wrap fee programs. E. Mix of Client Assets: As of December 31, 2023, CPM manages $273,769,442 of client regulatory assets under management. All assets are managed on a discretionary basis.