Clear Harbor is an investment adviser providing financial planning, consulting, and investment management services. Prior to engaging Clear Harbor to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with Clear Harbor setting forth the terms and conditions under which Clear Harbor renders its services (collectively the “Agreement”). Clear Harbor has been registered as an investment adviser since January 2010. Aaron Kennon, Ian Armstrong, and D. Roger B. Liddell are the principal owners of Clear Harbor. Clear Harbor had $1,463,680,113 in assets under management as of December 31, 2023, $1,459,694,239 of which was managed on a discretionary basis and $3,985,874 of which was managed on a non- discretionary basis. This disclosure brochure describes the business of Clear Harbor. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Clear Harbor’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on Clear Harbor’s behalf and is subject to Clear Harbor’s supervision or control. Financial Planning and Consulting Services Clear Harbor may provide its clients with a broad range of comprehensive financial planning and consulting services (which may include non-investment related matters). These services are customized to the individual needs of the clients. In performing its services, Clear Harbor is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Clear Harbor may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Clear Harbor recommends its own services. The client is under no obligation to act upon any of the recommendations made by Clear Harbor under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Clear Harbor itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Clear Harbor’s recommendations. Clients are advised that it remains their responsibility to promptly notify Clear Harbor if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Clear Harbor’s previous recommendations and/or services. Investment Management Services Clients can engage Clear Harbor to manage all or a portion of their assets on a discretionary or non- discretionary basis. Clear Harbor primarily allocates clients’ investment management assets among individual debt and equity securities, mutual funds, exchange-traded funds (“ETFs”), and/or options in accordance with the investment objectives of the client. In addition, where appropriate, Clear Harbor recommends that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities, which may include debt, equity, and/or pooled investment vehicles when consistent with the clients’ investment objectives. Clear Harbor tailors its advisory services to the individual needs of clients. Client may place reasonable restrictions on Clear Harbor’s management by prohibiting transactions in certain securities, sector or asset classes. Clear Harbor ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify Clear Harbor if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Clear Harbor’s management services. Management of Collective Investment Vehicle Clear Harbor is also the investment manager to OncoRev Global Oncology Ecosystem Fund, LP, and Spectrum Value Partners, L.P., privately offered pooled vehicles (the “Funds”). In addition, affiliates of Clear Harbor act as the general partners or managing members for the Funds. Interests in the Funds are privately offered pursuant to Regulation D under the Securities Act of 1933, as amended. Clear Harbor has discretionary authority to determine the broker or dealer to be used by the Funds. The Funds currently rely on an exemption from registration in reliance on Section 3(c)(1) of the Investment Company Act of 1940, as amended (the “Investment Company Act”). OncoRev Global Oncology Ecosystem Fund, LP’s investment objective is long-term capital appreciation which it aims to achieve by investing in companies that develop and/or provide a variety of products or services for cancer. Spectrum Value Partners, L.P. has been established to generate returns, primarily through investing in securities trading at market prices which differ substantially from what the portfolio manager deems to be their intrinsic value. If eligible, Clear Harbor recommends that certain clients invest in the Funds where appropriate. The Funds are managed in accordance with each funds’ objectives and are not tailored to any particular fund investor. Clear Harbor does not provide individualized advice to these investors. Investors in the Funds should consider whether a particular fund meets their investment objectives and risk tolerance prior to investing. All relevant information, terms and conditions relative to each Fund, including the compensation received by Clear Harbor or an affiliate, withdrawal rights, minimum investments, qualification requirements, suitability,

risk factors, potential conflicts of interest, are set forth in the relevant confidential private offering memorandum (the “Memorandum”), investor agreement, and Subscription Agreement (the Memorandum, investor agreement and Subscription Agreement together the “Offering Documents”), which each investor is required to receive and/or execute prior to being accepted as an investor in the Funds. While the Funds are generally Clear Harbor’s client, the term “client(s)” sometimes refers to the investors in the Funds. Clear Harbor will devote its best efforts with respect to its management of Funds and its individual client accounts. Given the above discussion relative to the objectives, suitability, risk factors, and qualifications for participation in the Funds, Clear Harbor may give advice or take action with respect to the Funds that differs from that for individual client accounts. To the extent that a particular investment is suitable for both the Funds and certain individual client accounts, such investments will be allocated between the Funds and the individual client accounts pro rata based on the assets under management or in some other manner which Clear Harbor determines is fair and equitable under the circumstances to all of its clients. The Funds are managed in accordance with each Fund’s objectives and are not tailored to any particular Fund investor. Clear Harbor does not provide individualized advice to these investors. They should consider whether a particular Fund meets their investment objectives and risk tolerance prior to investing. Participation as an investor in the Funds is restricted to investors that are both qualified clients pursuant to the requirements under Rule 205-3 under the Advisers Act, and “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended. Sourcing, Evaluation, Selection & Monitoring of Private Funds Clear Harbor selects, supervises and monitors the private investments it recommends to clients. Recommendations will vary depending on client specific needs and will be consistent with the client investment objectives and risk tolerance. Investment decisions are determined by the asset allocation strategy and goals set by the owners of the accounts. Clear Harbor identifies, screens, and analyzes potential investments and conducts quantitative and qualitative analysis on each Private Fund it recommends to clients. Clients must meet certain criteria, including asset minimums, to establish an advisory relationship with Private Funds. The criteria will differ depending on the investment vehicles in which client invests. Third Party Advisor Programs Clear Harbor has entered into agreements with various independent, third-party investment advisers (“TPAs”). Under these agreements, Clear Harbor has the ability to refer clients to TPAs for investment in various types of programs sponsored by these TPAs. Once enrolled in these programs, the selected TPA will manage clients' accounts on a discretionary basis. All TPAs to whom Clear Harbor will refer clients will be a registered investment adviser with the Securities and Exchange Commission. Clear Harbor prioritizes establishing relationships with reputable and experienced TPAs. When evaluating potential TPAs, Clear Harbor considers factors such as their track record, assets under management, client services, investment style, risk management practices, and overall investment process. Additionally, Clear Harbor takes into account the cost of TPA services and any specific criteria set by the TPA. Costs associated with TPA programs vary based on program type, services offered, investment minimums, and other factors. These costs will be disclosed in connection with formally establishing an arrangement with a TPA. Some TPA programs may operate on a "wrap fee" basis, where clients are charged a single fee for a bundle of services, such as investment management and trading services. Please refer to additional important disclosures regarding “wrap fee” programs in Item 5 of this brochure. Clear Harbor collaborates with clients to align their investment profiles with the objectives of the TPA programs under consideration. After receiving recommendations from Clear Harbor, clients retain final authority to select a TPA and a specific program. In some cases, the TPA may also assist in matching your investment objectives and personal and financial data with the programs available at the TPA. A complete description of the TPA’s services, fee schedules and account minimums will be disclosed in the TPA’s Form ADV which will be provided to clients at the time an agreement for services is executed and an account is established. Clients who select a TPA program will enter into an agreement directly with the TPA. In some cases, the agreement will be a joint agreement with both Clear Harbor and the TPA. These agreements detail the services provided, associated costs, reporting schedules, termination procedures, and other important information. Performance reporting will generally be the responsibility of the TPA. Such performance reports will be provided directly to you and Clear Harbor. Clear Harbor does not audit or verify that the performance results provided by a TPA are calculated on a uniform or consistent basis. In some cases, Clear Harbor will be available to answer your questions regarding your TPA account and act as the communication conduit between you and the TPA. Note, however, TPA accounts are managed by the selected TPA and Clear Harbor does not have any discretionary trading authority with respect to the day-to-day management of such accounts. You should know that Clear Harbor does not seek relationships with all possible TPAs and there may be TPAs that Clear Harbor has not vetted or decided not to include on its list of TPAs to recommend to clients that may charge lower fees for providing similar services.