9AT: VALSPRING CAPITAL

Adviser Profile

As of Date	03/26/2026
Registration	SEC, Approved, 07/28/2023
Other registrations (4)	SEC, 120-Day Approval, 07/28/2023 SEC, Terminated, 06/29/2023 SEC, 120-Day Approval, 03/31/2023 SEC, Terminated, 02/03/2023
Former registrations	VALSPRING CAPITAL MANAGEMENT, LP VALSPRING CAPITAL MANAGEMENT, LP VALSPRING CAPITAL MANAGEMENT, LP
Contact Info	617 xxxxxxx
Websites

AUM^*	336,927,417 136%
of that, discretionary	336,927,417 136%
Number of Employees	7 17%
of those in investment advisory functions	5 25%
Private Fund GAV^*	217,792,253 -11%
Avg Account Size	336,927,417 136%
SMA’s	No
Private Funds	3 2

Adviser Type

- Large advisory firm

Client Types

- Pooled investment vehicles

Advisory Activities

- Portfolio management for pooled investment vehicles

Compensation Arrangments

- A percentage of assets under your management

	Count	GAV
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Adviser	Hedge Fund	Liquidity Fund	Private Equity Fund	Real Estate Fund	Securitized Asset Fund	Venture Capital Fund	Other Fund	Total Private Fund GAV	AUM	#Funds
Adviser CATHAY CAPITAL NA, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund63.0m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV63.0m	AUM76.6m	#Funds3
Adviser JLL PARTNERS FCH, INC.	Hedge Fund-	Liquidity Fund-	Private Equity Fund132.4m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV132.4m	AUM132.4m	#Funds1
Adviser FEATHERINGILL CAPITAL, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund117.9m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV117.9m	AUM142.9m	#Funds6
Adviser RAND CAPITAL MANAGEMENT	Hedge Fund-	Liquidity Fund-	Private Equity Fund73.8m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV73.8m	AUM136.7m	#Funds2
Adviser GOLDIRON GP LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund60.2m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV60.2m	AUM60.2m	#Funds1
Adviser ALLIANCE INVESTMENT MANAGEMENT, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund4.1m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV4.1m	AUM206.8m	#Funds1
Adviser DELTA CAPITAL PARTNERS MANAGEMENT LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM90.1m	#Funds-
Adviser STONE CREEK GROUP, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund31.3m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV31.3m	AUM250.6m	#Funds4
Adviser ASH INVESTMENT PARTNERS, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund185.7m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV185.7m	AUM185.7m	#Funds2
Adviser APEX INVESTMENTS MANAGEMENT US, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund392.5m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV392.5m	AUM392.5m	#Funds1

Brochure Summary

Overview

For purposes of this brochure, the “Adviser” means Valspring Capital Management, LP a Delaware limited partnership, together (where the context permits) with its affiliated general partners of the Funds (as defined below) and other affiliates that provide advisory services to and/or receive advisory fees from the Funds. Such affiliates may or may not be under common control with Valspring Capital Management, LP, but possess a substantial identity of personnel and/or equity owners with Valspring Capital Management, LP. These affiliates may be formed for tax, regulatory or other purposes in connection with the organization of the Funds, or may serve as general partners of the Funds. The Adviser provides investment supervisory services to investment vehicles (the “Funds”) that are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”) and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”). The Funds make primarily long-term growth, private equity and equity-related investments, as well as investments in debt instruments. In accordance with the Funds’ respective investment objectives, investments are generally made in companies doing business in the healthcare industry. The Adviser’s advisory services consist of investigating, identifying and evaluating

investment opportunities, structuring, negotiating and making investments on behalf of the Funds, managing and monitoring the performance of such investments and disposing of such investments. The Adviser may serve as the investment adviser or general partner to the Funds in order to provide such services. The Adviser provides investment supervisory services to each Fund in accordance with the limited partnership agreement (or analogous organizational document) of such Fund or separate investment and advisory, investment management or portfolio management agreements (each, an “Advisory Agreement”). Investment advice is provided directly to the Funds, subject to the discretion and control of the applicable general partner, and not individually to the investors in the Funds. Services are provided to the Funds in accordance with the Advisory Agreements with the Funds and/or organizational documents of the applicable Fund. Investment restrictions for the Funds, if any, are generally established in the organizational or offering documents of the applicable Fund, Advisory Agreements and/or side letter agreements negotiated with investors in the applicable Fund (such documents collectively, a Fund’s “Organizational Documents”). The principal owner of Valspring Capital Management, LP is Yumin Choi. The Adviser has been in business since 2022.

VALSPRING CAPITAL

VALSPRING CAPITAL

VALSPRING CAPITAL MANAGEMENT, LP

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Client Types

Advisory Activities

Compensation Arrangments

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Private Funds Structure

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Overview

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VALSPRING CAPITAL VALSPRING CAPITAL VALSPRING CAPITAL MANAGEMENT, LP

Related Companies

Adviser Profile

Details

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Private Funds Structure

Similar advisers

Brochure Summary

Overview

VALSPRING CAPITAL

VALSPRING CAPITAL

VALSPRING CAPITAL MANAGEMENT, LP