ACAP registered with the Securities and Exchange Commission (“SEC”) as an investment adviser in 2008. Black Swan Investments, LLC is the principal owner of ACAP. As of December 31, 2023 the Company advised approximately $1,082 million on a non-discretionary or consulting basis, on behalf of 990 accounts and managed $552 million on a discretionary basis in 4 accounts. ACAP provides financial planning and investment advisory services to ultra-high net worth individuals and their related trusts, partnerships and charitable accounts. ACAP also provides investment advisory services to a pension plan client. ACAP provides individualized investment advice, due diligence, and recommendations on asset allocation, exchange traded funds (“ETFs”), third-party managers, mutual funds, and individual investment securities (e.g., stocks, bonds, options, direct investments in real estate and private companies). Clients may impose restrictions on investing in certain securities or types of securities. Additionally, ACAP will review and make recommendations on other outside managers and investments that the clients have retained. Services of ACAP may also include, but are not limited to, the following:  An investment policy statement that covers one’s risk tolerance and liquidity needs  Ongoing monitoring, due diligence, asset allocation, and additional review of investment portfolios  Retirement sufficiency analysis  Aggregate investment reporting through an independent third party  Annual, Biennial or quarterly contact with investment meetings ACAP’s primary investment recommendation is its passive index investing approach – which can entail either, investing in index tracking ETFs or, allocating assets to third party advisers to construct index tracking portfolios on behalf of clients. ACAP also conducts due diligence and makes recommendations on third-party advisers (for non-index tracking purposes) to clients. These opportunities may provide a wide range of investments including traditional equity investing, fixed income portfolios, as well as alternative strategies, such as hedge funds and private equity funds. Clients should review the disclosure documents of recommended investment managers for information on each manager’s investment selection, analysis methods, and sources of information and investment strategies. ACAP also conducts due diligence and provides recommendations on individual alternative investments, such as mezzanine loans, real estate investments, and operating companies. ACAP will at times advise clients upon investing assets directly in privately offered investments such as private operating companies and real estate offerings (“Privately Offered Investments”). Such investments may be sourced by ACAP or its clients. ACAP will not recommend that the client make such an investment unless they are eligible to do so. To be eligible to invest in a Privately Offered Investment, a client must meet all the requirements under state and federal security laws to be eligible to invest in a privately offered security. For example, depending on the investment, the client may be required to meet the definition of a “Qualified Purchaser” as defined in Section 2(a)(51) of the Investment Company Act and/or an “Accredited Investor” as defined in rule 501(a) of Regulation D. If a client sources a potential investment, and that client elects to fund the entirety of that investment, ACAP will not recommend such investment to any other client. However, ACAP may need to make an investment allocation decision in the event that: it determines that a potential investment it has sourced may be appropriate for certain clients; or a client that has sourced its own investment elects not to fund the entirety of that investment and ACAP determines that the remainder of the investment

may be appropriate for certain other clients. In such a situation, ACAP’s allocation of these investments will be based on the following factors. 1. Liquidity – does the client have sufficient liquidity to make the investment? 2. Time horizon/Structure issues – can the client withstand the lack of liquidity over the expected time horizon of the investment? 3. Returns sought/Risk tolerance – considerations include: a. Is the client comfortable investing in direct investments? b. Underlying risk of investment, and c. Diversity of other assets held by the client 4. Ability to make a decision - can the client make an investment decision with respect to the investment in the required time frame? 5. Size of investment - is the recommended size of investment appropriate relative to the client’s net worth? 6. Taxes - when assessing the potential return on the investment, ACAP will consider the tax impact to the client. Further, ACAP believes that all Privately Offered Investments it recommends will typically have similar potential for success. Thus, the allocation of any one Privately Offered Investment is less important than ensuring that such opportunities, generally, are allocated fairly over time. This could result in certain clients not being allocated certain specific investment opportunities or being allocated less of such an opportunity than could otherwise be the case. Prior to November 2018, if a client elected to make an investment in a Privately Offered Investment, such client typically made the investment directly. Starting in November 2018, if a client elects to make a Privately Offered Investment, the client may be required to make such investment via Argos Fund, LLC (the “Argos Fund”) or Argos Fund II (collectively “the Argos Funds” and each individually, “an Argos Fund”)). The Argos Funds are limited liability companies, for which ACAP acts as investment adviser on a discretionary basis. Although clients retain discretion as to if and when to make a Privately Offered Investment, once the investment is made via an Argos Fund, ACAP has investment discretion over the invested assets until such time that the investment is liquidated. Starting in November 2018, ACAP also began advising Argos Opportunity Fund 19, LLC (the “Opportunity Fund”), and starting in October 2019, ACAP began advising the SPC Family Office Fund II, LLC (“Fund II”). The Opportunity Fund and Fund II were both created to invest alongside the Argos Fund. However, after December 31, 2020, the Opportunity Fund ceased making new investments. Also, as of the date hereof, Fund II is not making new investments. Sail Point Capital, LLC (“SPC”) was created in 2021 as a subsidiary of ACAP. In 2022, SPC became a relying advisor of ACAP. In April of 2022, SPC began advising SPC Co-Invest Fund III, LLC (“Fund III”) and Fund II. SPC and ACAP collectively conduct a single advisory business, and with this in mind, all references to ACAP hereafter are intended to refer to SPC unless stated or the context indicates otherwise. Like the Opportunity Fund and Fund II, Fund III was created to invest alongside the Argos Fund, and will continue to invest alongside the Argos Fund and Argos Fund II. Fund III is limited to investing in privately offered real estate investment opportunities. Notwithstanding, but subject to, ACAP’s processes for allocating Privately Offered Investments among clients as discussed above, ACAP intends to offer up to 25% of each Privately Offered Investment opportunity that is a real estate investment matching Fund III’s investment profile to Fund III. Exceptions may apply in the case of client-sourced deals where the client is able to make the entirety of the sourced investment without the use of additional capital. Fund III is closed to new investors.