Brevet Capital Management, LLC Based in New York, New York, BCM is an independent, privately-held investment adviser that was founded in 2006. It is a wholly owned subsidiary of Brevet Holdings, LLC (“Brevet Holdings”), which is majority-owned by Douglas Monticciolo. BCM’s relying advisers are discussed in Item 10 (“Other Financial Industry Activities and Affiliations”) of this Brochure. Services; Investment Objectives and Strategies Brevet Capital provides investment advisory services to a variety of alternative investment vehicles, focusing primarily on pooled investment vehicles (collectively, the “Funds”) and separately managed accounts (“SMAs”). Funds and SMAs make investments directly and/or indirectly through, and Brevet Capital provides investment advice to, special purpose entities formed to hold investments. The types of clients to which Brevet Capital provides investment management services are disclosed in BCM’s Form ADV Part 1 and summarized in Item 7 (“Types of Clients”) of this Brochure. Brevet Capital provides both discretionary and non-discretionary investment advisory services, depending on the client. Its services generally include: conducting research on potential investments; analyzing investment opportunities; recommending investment opportunities; and executing and monitoring investments. Each Fund is advised in accordance with the investment guidelines and restrictions set forth in its offering documents, and such advice is not tailored to the individualized needs of any of such Fund’s investors. Investment in a Fund does not, in and of itself, create an advisory relationship between any such investor and Brevet Capital. One of the Funds that is advised by BCM, BC Immigration Fund LLC (“BCIF”), focuses on investments in “job creating entities” (within the meaning of the EB-5 Immigrant Investor Program (the “EB-5 Program”) established pursuant to 8 U.S.C. § 1153(b)(5) and Section 610 of the Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies Appropriations Act of 1993) that invest in real estate development, infrastructure development, or other ventures to create jobs as required under the EB-5 Program to enable investors to obtain an EB-5 visa or conditional or permanent U.S. resident status. However, Brevet Capital’s primary focus is investments in specialized lending solutions for middle and lower middle-market private companies with an attractive underlying asset or assets, in an underserved or overlooked sector, or that represent niche financing opportunities. In recent years, Brevet Capital has increasingly focused on investments that are related in various ways to government programs in the United States and abroad.1 Notwithstanding the foregoing, Brevet Capital provides advice on a wide variety of investment strategies and activities, as investment guidelines and restrictions are developed in consultation with clients and are tailored to their needs. See Item 8 (“Methods of Analysis, Investment Strategies and 1 Although a number of the investments that Brevet Capital recommends to clients or causes clients to invest in are related to or dependent on various government programs, none of the Funds or SMAs is guaranteed by any local, state, or federal government or agency. Risk of Loss”) of this Brochure for additional details regarding Brevet Capital’s investment strategies and activities. For SMAs, applicable investment guidelines and restrictions typically are set forth in the applicable investment management agreement. For each Fund, applicable investment guidelines and restrictions are set forth in the applicable investment management agreement and such Fund’s offering documents, which generally provide for a wide investment mandate. Brevet Capital may recommend that clients, or may cause clients to, engage in any investment strategies and activities – even those not described in this Brochure – that Brevet Capital considers to be consistent with its clients’ overall investment objectives. Investments are most frequently structured as secured financings, though Brevet Capital also recommends that clients, or causes clients to, invest in: loan, bond, or trade debt or equity or equity-like securities; direct acquisitions of assets, warrants, and participations; related hedges and options, as appropriate; and alternative investment structures with similar return profiles. Investment opportunities that may be suitable for more than one client are typically offered in the form of participation arrangements. A domestic Fund (other than BCIF) or a holding vehicle affiliated with Brevet Capital that acquires an investment (such Fund or holding vehicle,

as applicable, an “Asset Holder”) may subsequently (but in no event fewer than five (5) days after acquisition) offer, if/as appropriate, to Funds and/or SMAs that have entered into a master participation agreement (each, an “MPA”) with such Asset Holder the opportunity to acquire a participation interest in such investment pursuant to the terms of the relevant MPA. Investments are frequently made through special purpose vehicles or alternative investment vehicles formed for the specific purpose of making and holding such investments. From time to time, Brevet Capital causes domestic Funds and/or SMAs with respect to which it has discretionary authority to acquire participation interests from an Asset Holder. While Brevet Capital recommends that offshore Funds and/or SMAs with respect to which it does not have discretionary authority invest in such investment opportunities through the acquisition of participation interests, the ultimate investment decision is made by (i) with respect to each such offshore Fund, its majority-independent board of directors, majority-independent board of managers, or majority-independent investment committee, as applicable, and (ii) with respect to each such SMA, the representatives of such SMA, and not, in either case, Brevet Capital. The use of such participation arrangements allows Brevet Capital’s clients to achieve greater liquidity and portfolio diversification than if such participation arrangements were not employed. Further, such arrangements streamline the administration and management of investments by allowing borrowers to deal with a single counterparty instead of a diverse group of investors. In determining the allocation of investment opportunities, including in connection with such participation arrangements, Brevet Capital is expressly prohibited from taking into consideration the structure and amount of fees and incentive compensation paid to Brevet Capital and/or its affiliates by different clients. Brevet Capital has adopted investment allocation guidelines that take into account: the investment criteria of each of its clients; legal, tax, regulatory, and other considerations of each of its clients; the expected collateral liquidity duration of investment opportunities, as projected at the time of origination; the size and nature of the investment opportunity; available capital; concentration targets; and other applicable investment constraints. While Brevet Capital provides investment advice regarding a variety of investments, it does not currently provide investment advice with respect to securities portfolios or any type of mutual fund, convertible bond, corporate bond, municipal bond, government bond, or exchange-traded fund. Recipients of this Brochure should be aware that while this Brochure includes information about the Funds and SMAs, it is not a complete description of the terms, risks, or conflicts associated with engaging Brevet Capital as an investment adviser or investing in a pooled investment vehicle advised by Brevet Capital. More complete information is set forth in the Funds’ offering documents, which are provided to prospective investors prior to them making an investment, and the SMAs’ investment management agreements, as applicable. The information contained in this Brochure concerning the Funds is qualified in its entirety by reference to the disclosures made in the Funds’ respective offering documents, which should be carefully reviewed prior to making an investment decision. In no event should this Brochure be considered an offer to sell or a solicitation of an offer to buy interests in any investment vehicle or relied upon in determining to invest in any investment vehicle managed by Brevet Capital. This Brochure is designed solely to provide information about Brevet Capital for purposes of complying with certain obligations under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and, as such, responds to relevant regulatory requirements under the Advisers Act that may differ from the information required to be provided in the Funds’ offering documents. In the event of any inconsistency between a Fund’s offering documents and this Brochure, such offering documents shall control. There is no assurance that any Funds’ investment objectives will be met or that Brevet Capital’s investment strategies will be successful. Wrap Fee Programs Brevet Capital does not participate in any wrap fee programs. Assets Under Management As of December 31, 2023, Brevet Capital had assets under management as follows:
• Assets managed on a discretionary basis $1,813,151,291
• Assets managed on a non-discretionary basis $270,233,627 The foregoing figures include assets and unfunded commitments, calculated in accordance with the methodology prescribed by the SEC for calculating Regulatory Assets Under Management.