16th AA is an investment management firm specializing in the trading and investing of U.S. Municipal Bonds. It serves as the Advisor to a variety of separately managed accounts for high- net-worth individuals and to two private investment funds representing the proprietary equity capital of the Managing Members, their spouses and family trusts, and certain employes of 16th AA. Subsequent to the launch of 16Rock, 16th AA will serve as the Sub-Adviser to all of 16Rock’s asset management business. It does not get paid a fee for its services to 16Rock. As a general matter, the Firm’s management, or advisory fee for a discretionary engagement service ranges from 0.1% to 1.00%, depending on the nature and complexity of the assignment. Such amounts are typically paid monthly or quarterly in advance and are calculated on the market value plus accrued interest of the assets on the month-end or quarter-end, as the case may be. For more complex engagements, which may include leverage, hedging, shorting of securities etc., we may also include an incentive or performance allocation of up to 20% which is paid annually. Notwithstanding the foregoing, depending on the nature of the assignment, the Adviser may enter into engagements with higher management fees or include incentive allocations. There is no fee charged on the management of the proprietary equity capital of the Managing Members and employees. The Registrant’s investment services are generally memorialized in an Investment Advisory Agreement or through execution of private fund offering documents which often include a limited partnership agreement and/or subscription agreement. These documents contain the relevant investment guidelines as well as representations of the client and Adviser. Additionally, these documents list risks, including the potential for loss of principal, and the associated fees. In certain instances, the client may request reasonable restrictions, in writing, on the Adviser’s services, which must be agreed upon by the Adviser. The Adviser has policies and procedures in place that distinguish between investment strategies and provide for fair allocation of securities to all clients. Included in the policies are the assets the Registrant manages for 16Rock. These policies are available to be reviewed by clients and prospects upon request, in writing, to the Adviser. The Adviser does not provide financial planning, estate planning, insurance planning or any related or unrelated financial planning. 16th AA does not serve as a law firm, accounting firm, or insurance agency, and no portion of its services should be construed as legal, accounting, or insurance implementation services. Accordingly, 16th AA does not prepare estate planning documents, tax returns, or sell insurance products. To the extent requested by a client, the Adviser may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are reminded that they are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by 16th AA, its affiliates and/or representatives. Please Note: If the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not the Adviser, shall be responsible for the quality and competency of the services provided. Client Obligations. In performing its services, the Adviser shall not be required to verify any information received from the client or from the client’s other professionals (in each case whether written or oral) and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify the Adviser in writing if there is ever any change in their financial situation or investment

objectives for the purpose of reviewing/evaluating/revising Adviser’s previous recommendations and/or services. Disclosure Brochure A copy of the Adviser’s written Brochure as set forth on Part 2A of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement. Internal Private Funds and Accounts, 16th AA, serves as the investment manager for the proprietary capital of the Managing Members, their spouses and family trusts and to certain employees. The proprietary capital is invested in two internal private investment funds (“Vicksburg Municipal Trading Fund LP” and its offshore feeder fund, “Vicksburg Municipal Trading Offshore Fund Ltd”, and “Chestnut Investment Limited,” together and collectively the “Internal Private Funds”). The Internal Private Funds are not open to clients of the Adviser and are managed pari-passu to one another. Please Note The investment strategies and objectives of the Internal Private Funds, Muni Ops and the separate account strategies are, in general, very different. The Internal Private Funds rely on persistent use of leverage, hedging, shorting of securities, and active trading. Tax efficiency is not considered. In addition, the Internal Private Funds may take positions in equities, commodities, and other forms of fixed income on a long or short basis. Although the portfolio is primarily municipal bonds, there is no limitation on the scope of securities or assets these funds can invest in. By comparison, Muni Ops uses a muti-muni-strategy framework, comparatively less leverage, and its approach to hedging is different than the Internal Private Funds. As holding periods will, in general, be longer, Muni Ops will likely pass through some tax-exempt income to US investors. Our separate account strategies are generally designed to be tax-efficient and investment decisions tend to be focused on portfolio guidelines and needs. For example, duration, coupon structure, or state specific qualities. To the extent margin leverage is used in certain cases, it is designed to be episodic, and event driven, rather than persistent. Conflict Of Interest At times, the Internal Private Funds, Muni Ops and the separate account strategies may invest in the same securities or CUSIPS. At times, certain strategies may choose not to invest in a given CUSIP while other strategies do invest. Similarly, the timing of a sale of a CUSIP may be different. As discussed above, the investment strategies and objectives are different so one strategy may choose to sell a CUSIP while another may elect to hold it for a longer period. 16th AA and 16Rock use the same policies and procedures to distinguish between and among all strategies and accounts to provide for fair allocation of securities to all clients. These policies are available to be reviewed by clients and prospects upon request, in writing, to the Adviser. Wrap/Separate Managed Account programs: In the event that the Adviser is engaged to provide investment advisory services as part of an unaffiliated wrap-fee program, the fees paid by the client may be more than what is paid to the Adviser directly. Generally, under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody, and reporting services for a single specified fee. As a result, participation in a wrap program may cost the participant more or less than purchasing such services separately. Please Note: Since the custodian/broker-dealer is determined by the unaffiliated program sponsor, the Adviser may have limited ability to manage with whom trades are conducted and the ability to seek best execution may be limited. As a result, clients may pay overall costs or greater spreads, or receive less favorable net prices on transactions for the account than would otherwise be the case through alternative clearing arrangements recommended by the Adviser. As of December 31, 2023, the Adviser managed $ 228,789,175 in assets as the Advisor or Sub- Advisory on a discretionary basis.