Afsaneh Beschloss founded The Rock Creek Group, LP (the “Adviser” or “RockCreek”), a Delaware limited partnership that has been in the investment management business since 2002. Ms. Beschloss is the Founder and CEO of the Adviser and the managing member of the Adviser’s general partner.

The Adviser is owned by estate planning family trusts of the Adviser’s Founder and CEO and other RockCreek management team members (through the Adviser’s management equity plan).

As further described below, the Adviser primarily invests in securities directly or, indirectly (through investments in Portfolio Funds (as defined below) and investments with Sub Advisers (as defined below)), across a range of strategies, including without limitation, mult i- strategy; small/emerging managers; non-U.S., emerging, and frontier markets; diversified; long/short equity; long-biased equity; short-biased equity; credit; activist relative value; market neutral; equity-hedged; global event-driven macro/commodities; opportunistic; real estate, and other strategies.

Commingled Funds. The Adviser provides investment advisory and invest me nt management services to multi- investor private investment vehicles (“Commingled Funds”) that are structured as limited partnerships, limited liability companies, corporations, or other investment vehicles. Certain Commingled Funds invest in other investment vehicles or invest me nt funds managed by underlying third-party asset managers, including alternative investment funds investing in marketable securities and other investments and private funds investing in illiq uid securities such as private credit and other less liquid private investments, including without limitation, private equity, venture capital, and real estate and illiquid investments or directly investing in publicly traded securities, including but not limited to, U.S. and non-U.S. equity securities (both on the long and short side), debt securities, money market instruments, non-U.S. dollar currencies, options and futures contracts, forward contracts and other derivatives, and other asset classes (“Portfolio Funds”).

Assets of Commingled Funds may also be allocated to Sub Advisers (as defined below) for investment. The Adviser’s services to the Commingled Funds include investment manageme nt and portfolio services, including portfolio construction; the identification, selection, monitor ing, and evaluation of the Portfolio Funds, portfolio managers (“Portfolio Managers”), and Sub Advisers with which the Commingled Funds invest; and risk management. The term “Sub Advisers” refers to certain asset managers that have entered into sub-advisory or similar agreements with the Adviser that are discretionary (i.e., a Sub Adviser has authority to purchase or sell securities) or non-discretionary (i.e., the Adviser authorizes or pre-approves a Sub Adviser’s proposed transaction) and opening managed accounts with such Sub Advisers rather than by investing in their commingled investment funds. Consistent with their strategies, certain Commingled Funds invest directly in publicly listed securities traded on exchanges in the U.S. market and in non-U.S. exchanges, including emerging and frontier markets. Certain Commingled Funds may invest in certain other Commingled Funds and Intermediate Vehicles (as described below). The investing Commingled Fund, in such cases, purchases a share class or special interest of the relevant investee Commingled Fund so as the investing Commingled Fund does not incur duplicative management fees or such fees are offset to avoid the duplication of fees. Separate Accounts, Funds of One, Segregated Portfolios, Series Portfolios, and Advisory Clients (each as defined below) may invest in certain Commingled Funds

Fund of One. The Adviser provides investment advisory and investment manage me nt services to customized private investment vehicles (“Funds of One”) that are structured as limited partnerships, limited liability companies, corporations, or other investment vehicles that have been organized for a single investor (or a group of affiliated investors) seeking a customized portfolio tailored to an investor’s specific investment needs, guidelines, risk tolerances, reporting, and other specific requirements. The fees and expenses charged to an investor in a Fund of One, are set forth in the documentation on a case-by-case basis depending upon such factors as the size and scope of mandate, overall relationship with the investor, type of strategies, and unique portfolio features and requirements.

The Adviser invests assets of a Fund of One as set forth in the applicable guidelines, and generally may invest such assets in certain Funds, the emerging markets platform, and Intermed iate Vehicles. The Fund of One, in such cases, purchases a share class or special interest of the relevant Fund made available so as not to incur duplicative management fees or such fees are offset so as to avoid the duplication of fees. Assets of Funds of One may be invested in Portfolio Funds, with Sub Advisers and may also include direct investments in securities (including publicly listed securities), futures and other derivatives.

The Adviser’s services to the Funds of One include investment management and portfolio services, including portfolio construction; the identification, selection, monitoring, and evaluatio n of the Portfolio Funds, Portfolio Managers, and Sub Advisers with which the Funds of One invest; and risk management.

Unless otherwise specified herein, the Commingled Funds and the Funds of One may be referred to herein as the “Funds.”

Separate Accounts. In addition to providing services to the Funds, the Adviser provides investment management services to separate accounts (“Separate Accounts”) for a single investor (or a group of affiliated investors). A Separate Account may have terms (e.g., regarding fees, transparency and liquidity) that are different from those of the Funds. Such accounts may have unique guidelines, customized operating guidelines, and investment or other restrictions or requirements of the respective investor. Accordingly, these customized arrangements, includ ing the fees and expenses charged to Separate Accounts, are set forth in the specific documentat io n and depend upon such factors as the size and scope of mandate, overall relationship, type of strategy, and unique features and requirements of the account. Separate Accounts may invest in different combinations of the strategies described herein or others. The Adviser may invest assets of a Separate Account in certain Funds, with Sub Advisers (including the emerging markets platform), and Intermediate Vehicles in accordance with such Separate Account’s investment guidelines. The Separate Account, in such cases, purchases a share class or special interest of the relevant Fund, or the Separate Account is structured, such that the Separate Account does not incur duplicative management fees or such fees are offset so as to avoid the duplication of fees. Assets of Separate Accounts may be invested in Portfolio Funds, invested with Sub Advisers, or invested directly in securities (including publicly listed securities), futures, derivatives, and other investment products.

Unless otherwise specified herein, the Funds and Separate Accounts (and not the investors in a Fund or invested in a Separate Account) may be referred to herein as “Clients.”

Intermediate Vehicles. A Client may access one or more particular Portfolio Managers or one or more particular Portfolio Funds through an intermediate entity managed by the Adviser (or an affiliate of the Adviser) in which other Funds, Separate Accounts, or assets managed by the Adviser may have an interest (each, an “Intermediate Vehicle”). Intermediate Vehicles may invest into one or into multiple underlying Portfolio Managers or Portfolio Funds. Generally, if such an Intermediate Vehicle is utilized for purposes of obtaining access to a particular Portfolio Manager or Portfolio Fund and satisfying minimum investment size or other requirements, the Adviser will not charge or apply any additional Adviser management fees or performance-based allocations or fees at the Intermediate Vehicle level, but the applicable Client will bear its pro rata share of the costs and expenses associated with the establishment and ongoing operation of such Intermed iate Vehicle. Each shareholder in an Intermediate Vehicle does not directly own any interests or shares in the underlying Portfolio Funds to which it has indirect exposure through its investment in the Intermediate Vehicle. In the event of the removal or termination of the Adviser, with respect to any Intermediate Vehicle in which the Client is invested, each shareholder will be entitled to receive its pro rata share of redemption proceeds equal to the net asset value of the Client’s interest in such Intermediate Vehicle as of the effective date of redemption. Generally, redemptions from the Intermediate Vehicles in which the Client is invested will be subject to the terms of such Intermediate Vehicles, including without limitation, restrictions on the timing or amount of liquidity. An Intermediate Vehicle will generally have liquidity similar, but not identical, to the underlying Portfolio Funds in which such Intermediate Vehicle is invested given there may be additional notice time periods for redemptions, but there may also be inflows into the Intermed iate Vehicle to satisfy redemption requests. Segregated Portfolios. The Adviser serves as the investment adviser to each segregated portfolio of certain Cayman Islands segregated portfolio companies (each a “Segregated Portfolio”). The investment activities of each Segregated Portfolio are generally conducted by third-party unaffiliated sub-advisers, or by non-discretionary trading advisors (“Trading Advisors”), some of which may be locally based teams in certain emerging market countries, that engage in investment activities pursuant to written advisory agreements with the Adviser. The Adviser has investment discretion, subject to applicable portfolio guidelines and parameters, to allocate assets of applicable Separate Accounts, Funds of One, Commingled Funds and Advisory Clients (as defined below) under its management to the Segregated Portfolios that comprise the Adviser’s emerging markets platform or a managed account platform to access particular investment funds, Trading Advisors, and markets. In certain cases, the Adviser may directly engage in investment activities on behalf of a Segregated Portfolio. Each Segregated Portfolio operates with the benefit of statutory segregation under Cayman Islands law of assets and liabilit ies between each Segregated Portfolio. Although not judicially tested, the principal advantage of a Cayman Islands segregated portfolio company is that it protects the assets of one Segregated Portfolio from the liabilities of other Segregated Portfolios. It is uncertain, however, whether such segregation of assets and liabilities would be enforced in other jurisdictions. Series Portfolios. The Adviser serves as the investment adviser to each series of certain Delaware series limited liability companies (each a “Series Portfolio”). A Fund that is a Delaware series limited liability company may establish one or more segregated Series Portfolios to potentially segregate liability, for administrative reasons and for other purposes, and the Adviser has the ability to combine a series. Generally, each Series Portfolio is expected to be wholly owned by the applicable Fund. The principal purpose of a Series Portfolio is for liability segregation among various investments in a Series Portfolio held by the applicable Fund. Within a Series Portfolio, the Adviser may directly engage in direct securities trading strategies with regard to certain Funds or the investment activities may be conducted by Portfolio Managers and their respective Portfolio Funds with regard to certain other Funds. Under Delaware law, the investments and other assets of each series generally will not be available to satisfy the liabilit ies of any other series or the fund. However, the limits on inter-series liability have not been conclusively determined in a court of competent jurisdiction.

Advisory Services. The Adviser may provide non-discretionary advisory services relating to investments in Portfolio Funds, asset allocation, and manager selection to endowments and foundations, pension or profit-sharing plans, or other institutional clients (“Advisory Clients”), possibly using investment strategies similar to those employed for the Funds or Separate Accounts. Among other customized services, Advisory Client services may include assistance with the performance of due diligence on underlying funds and managers of such funds as well as portfo lio construction, portfolio risk analysis, and risk management. Furthermore, in certain cases where the Adviser has been granted discretionary investment authority over particular portfolios and accounts, the investors in such portfolios and accounts may have certain rights with regard to approval or disapproval of the investments for those portfolios and accounts.

Transition Management Services. The Adviser may assist Clients and Advisory Clients seeking management of the liquidation or transfer of their portfolios of underlying invest me nt funds and other investments previously managed by other investment managers. The Adviser may, subject to applicable laws and regulations, agree with the Client to transfer at fair value certain investments from the transition portfolios to Funds or Separate Accounts it manages and will notify the Client and/or its custodian of the transition portfolio’s transfers and other liquidation. Pursuant to specific mandates if requested by a Client the Adviser may assist in managing and monitoring such Client’s portfolio as the management of its portfolio is transitio ned. As of February 28, 2019, the Adviser had a total of approximately $14.3 billion in regulatory assets under management (approximately $13 billion on a discretionary basis and $1.3 billion on a non-discretionary basis). Please see Item 7 for a list of the types of the Adviser’s Clients. please register to get more info

Management and Incentive Fees. The Adviser does not have one fee schedule that applies to all Clients; the Adviser’s fees generally vary depending upon the nature, size, structure, and extent of the mandate and whether the investment is being made into a Commingled Fund, Fund of One, or Separate Account; or, the Adviser’s fees are pursuant to an Advisory Client relationship and other factors. The Adviser charges investment management fees to Clients as a percentage of assets under management (e.g., management and/or incentive fees or allocations). The amount and structure of the management fee, incentive fee and/or allocation varies across Funds and Accounts and are set out within the governing documents, offering documents (including share class supplements, if any), and/or the investment management agreements between the Adviser and the Client, all as applicable. The actual fees and investment sizes for an account may be negotiated, and a Client may pay more or less than the fees generally described in this Brochure, or more or less than similar Clients or Clients invested in similar strategies. As further described below, amounts may vary as a result of negotiations, discussions and/or factors about the mandate.

With respect to the Funds (Commingled Funds and Funds of One), the Adviser’s fees are set forth in each Fund’s offering documents or constituent documents, as applicable with details regarding management and/or incentive fees for Commingled Funds usually provided in the applicable share class supplement. The amount and structure of the management fee, incentive fee and/or allocation varies from fund to fund (and may vary significantly depending on the investment fund). Funds generally will pay the Adviser a manageme nt fee equal to a percentage of net assets, quarterly, in advance or arrears (as the case may be) as set forth in the applicable Fund’s offering documents. Management fees may be fixed or the management fee of certain Funds and certain share classes fees may be a sum of breakpoints with lower management fees when net assets exceed specific thresholds in a portfolio. In general, for Funds, the Adviser’s standard range of management fees is 0.70% to 1.50% (annually) of assets under manageme nt, and for the management fee and incentive fee option, incentive (performance-based) fees or allocations may be up to 15% (annually) of realized and unrealized capital appreciation, with a high water mark or certain hurdle rates (the thresholds of which may vary across applicable Funds). Fees and allocations (if any) charged to investors may differ depending on the class of shares or other interests purchased; certain share classes for investments over a certain size or for a founder’s share class for founders or initial investors or other circumstances as determined on a case-by-case basis may have lower fees as set forth in the applicable private placement memorandum and/or supplement. Certain Funds may also enter into side letter agreements with certain investors that may offer such investors preferential fees based on factors such as the size of investment, overall relationship with the Adviser, and lock up period. As described above, certain Clients may also pay the Adviser or its affiliates an incentive fee or allocation based upon an annual percentage of the net capital appreciation at the end of each calendar year (generally for Funds, after completion of the annual audit for such Fund). Such incentive fees and allocations may also be subject to a hurdle rate of the Client’s advised assets for the year and/or a high water mark (as the case may be) as set forth in the applicable documents. Incentive fees or allocations charged by the Adviser are in compliance with Rule 205-3 under the Advisers Act. For further information regarding the particular fee schedules for the Funds, please refer to the applicable private placement memorandum and supplements. With respect to Separate Accounts and Advisory Clients, the Adviser’s fees (includ ing management and incentive fees or allocations, as applicable) are negotiated on a case-by-case basis with the client. The fees are generally assessed depending upon the size of the mandate, the scope of the services, the scope of the client relationship, the type of strategy, the extent of reporting or other deliverables and administrative services required, the complexity of assets invested, liquid it y requirements, and any unique features of the arrangement. Fees may be fixed, fees may be a sum of breakpoints with lower management fees for clients that exceed specific assets under management thresholds, and a flat fee option may also be available. The Adviser or its affiliates may also be entitled to receive incentive fees with regard to certain Separate Accounts, and such fees may range from 3.5% to 10.00% (annually), with a high water mark or certain hurdle rates (the thresholds of which may differ across applicable Separate Accounts) or certain preferred returns (i.e., performance-based compensation that is paid only after a specified return has been achieved), varying depending upon a particular customized arrangement.

The Adviser may invest assets of a Separate Account or a Fund in certain other Funds (as described herein) in accordance with applicable law and guidelines. In such cases, the fees are structured so as to avoid duplication of fees through a separate share class or an offset, as the case may be.

In certain cases, investors may receive fee reductions of all or a portion of the manage me nt fee (and/or incentive fee or allocation) attributable to an investor’s interest in the pooled invest me nt vehicle, or invest fee free in pooled investment vehicles and pay negotiated fees outside of the pooled investment vehicle, which may be based on a separate fee schedule agreed upon by the Adviser and the applicable investor. Certain investors that are invested in pooled invest me nt vehicles may pay higher or lower fees or may be subject to higher or lower incentive allocatio ns or fees than similarly situated investors that are invested in the same pooled investment vehicle. Amounts may vary as a result of negotiations, discussions and/or factors that may include the particular circumstances of the investor, the size and scope of the overall relationship, or as may be otherwise agreed with specific investors. Fees and allocations charged to investors may differ depending on the class of shares or other interests purchased. In certain cases, the Adviser may charge a Fund investor or Separate Account client a flat fee. Any such flat fee and its terms are negotiated on a case-by-case basis with the investor or client.

With respect to certain non-discretionary services provided by the Adviser to Advisory Clients, such Advisory Clients may pay negotiated fixed dollar amounts based on the type of services provided (e.g., manager due diligence, portfolio risk analysis). With respect to the Adviser’s transition management services, the Adviser may charge a fee for such transitio n management services, or in its sole discretion, perform such services as an accommodation for existing Clients and waive any applicable Adviser fees. Additional Fees and Expenses. Additional fees and expenses that may apply vary based upon the nature and extent of the mandate and whether the investment is being made into a Commingled Fund, Fund of One, or Separate Account or as part of an advisory relations hip, including fees associated with transition monitoring and management services. Advisory Clients are charged fees and expenses as agreed upon with each such client for such matters as legal, audit, brokerage, administrative, and custody services provided by third parties. With regard to investments in the emerging markets platform or separate account platform, the applicable Fund or Separate Account will generally bear its pro rata share of such fees and expenses, except as otherwise provided in this section or as otherwise agreed with such applicable Fund or Separate Account. Some Funds pay the Adviser an annual administration fee, in advance, on a quarterly basis, in an amount equal to 0.25% annually of the investment account’s average monthly net assets per annum or such lesser amount that may be agreed to by the Adviser (including, for the avoidance of doubt, a lesser negotiated amount in respect of one or more investors in the applicable Fund). This amount may be more or less than the actual operating expenses of the Fund borne by the Adviser under this arrangement. In such cases where the administration fee is applicable, the Adviser has agreed to pay or absorb the ordinary operating expenses of such applicable Funds (e.g., brokerage commissions, research and consulting fees and expense; fees of any consultant retained by the Adviser to provide risk management analysis and reports; legal fees and disbursements (other than litigation fees and expenses); fees of the administrator; fees of the custodian, if any; accounting, audit, and tax preparation fees and expenses; organizatio na l expenses; and any expenses relating to the offer and sale of such applicable Fund’s shares or interests, as applicable), excluding the management fee and the incentive fee, if any. The Adviser has influence over the selection of service providers and over the amount of certain of such applicable Fund’s ordinary operating expenses. To the extent that such expenses are reduced, the benefit of such reduction would accrue to the Adviser, unless the amount of such administra t io n fee paid to the Adviser were reduced by agreement with the Fund. Separate Accounts may pay the Adviser an administration fee annually in the range of 0.10% to 0.15% of monthly net assets per annum or may pay certain actual expenses. Certain expenses may be capped at a fixed amount per annum. Additionally, to the extent that an investor does not agree to bear its share of a particular expense, the Adviser will bear such portion of the cost and will not charge other investors for such borne costs. Investors will indirectly incur fees and expenses applicable to the underlying Portfolio Funds, including asset-based, performance-based, carried interest, incentive allocatio n, and other compensation payable to the Portfolio Managers or their affiliates and brokerage and other transaction costs incurred by the Portfolio Funds as well as expenses incurred by such Portfolio Funds. (See “Layering of Fees” below). The Adviser may engage Sub Advisers or Trading Advisors in connection with the management of certain portfolios, including in emerging and frontier markets, and fees and expenses of such Sub Advisers or Trading Advisers may be borne by the applicable portfolio. Fee arrangements with some Clients may be structured so that they are inclusive of fees paid to Sub Advisers or Trading Advisors. Sub Advisers’ fees can differ from one another and the fee earned by the Adviser will vary depending upon actual fees paid to Sub Advisers (see below). The Adviser does not consider the fees earned when making invest me nt decisions. Please see Item 12 for more information about the Adviser’s practices as well as potential conflicts of interest. In relation to Separate Accounts, at the instruction of the Separate Account client, fees may be paid from Separate Accounts assets or may be invoiced to the Separate Account client or its custodian for fees incurred on a quarterly basis. For the avoidance of doubt, the Adviser does not charge, and the Adviser is not reimbursed for, its own overhead or other internal costs, such as employee payroll and benefits, office space and furnishings, travel, and telecommunications. please register to get more info

Fees and Allocations
As discussed above, the Adviser charges Funds and Separate Accounts a management fee, and, in certain cases, an incentive fee or allocation. Management fees charged by the Funds to a particular investor share class may be based on the level of liquidity offered such share class so that generally if a longer lock up is elected by the investor, the management fee charged would be lower than had a shorter lock up been elected. Once the lock up expires, unless a new lock up is entered into with the investor, the fee generally would increase to reflect the more liquid share class the investor has converted to after the lock up has expired. Clients may also pay the Adviser or its affiliates an incentive fee or allocation based upon an annual percentage of the net capital appreciation at the end of each calendar year (generally for Funds, after completion of the annual audit for such Fund). Such incentive fess and allocations may also be subject to a hurdle rate of the Client’s advised assets for the year and/or a high water mark (as the case may be) as set forth in the applicable Fund’s documents. Incentive fees and allocations charged by the Adviser or its affiliates are in compliance with Rule 205-3 under the Advisers Act. For further informa t io n regarding the particular fee schedules for the Funds, please refer to the applicable private placement memorandum and supplements.

The Adviser, however, in its discretion, may manage other Funds or Separate Accounts with higher or lower fees, and different fee structures. Funds and Separate Accounts that pay the Adviser a higher fee could create an incentive for the Adviser to favor those Funds or Separate Accounts or to recommend riskier investments; however, those Funds or Separate Accounts are subject to their respective investment objectives and guidelines and the Adviser has processes in place regarding the investment of all portfolios under management further described below.

For certain portfolios, management fees of the Sub Advisers, Trading Advisors, or Portfolio Managers (i.e., fees based on the value of assets under management) are paid by the Adviser from its management fee. The fee rate applicable to each Sub Adviser, Trading Advisor, or Portfolio Manager may be different and is subject to negotiation between the Adviser and each Sub Adviser, Trading Advisor, or Portfolio Manager. In the event that a Sub Adviser, Trading Advisor, or Portfolio Manager charges an incentive fee or allocation, such fee or allocation will generally be borne by investors and not by the Adviser. Sub Advisers, Trading Advisors, or Portfolio Managers to which the Adviser pays a lower fee rate could create a potential for conflict of interest with an incentive for the Adviser to favor those Sub Advisers, Trading Advisors, or Portfolio Managers; however, the decision to invest with such Sub Advisers, Trading Advisors, and Portfolio Managers is approved by the Adviser’s Investment Committee based upon the applicable client investment objectives and guidelines that relate to among other things, authorized investment vehicles, strategy, country allocations, and types of permitted investments, that could serve to mitigate to a certain extent such potential conflicts of interest. As the management fees, performance-based fees and allocations made to the Adviser are based directly on the net asset value of the Client accounts, there is a potential conflict of interest with regard to asset valuation. Therefore, the Adviser has developed policies and procedures regarding valuation, including the use of third-party administrator valuations. In general, with respect to investments in Portfolio Funds, the Adviser relies on the valuations provided by Portfolio Managers of the Portfolio Funds. The Adviser also performs due diligence on the underlying Portfolio Funds with respect to valuation policies and procedures as well as a review of the applicable Portfolio Funds’ audited financial statements where available.
Investment Allocations
The Adviser manages assets for Funds and Separate Account with similar invest me nt objectives and strategies, and may manage accounts with different objectives or strategies that trade in the same and same types of investments. Despite these similarities, the Adviser’s decisions about each Client’s investments and the investment performance may differ from those of other Clients. It is the Adviser’s policy to:


• Allocate investment opportunities among each Client (in a manner believed by the Adviser to be fair and equitable to each such Client over time. The allocation of invest me nt opportunities should never favor any Client account to the detriment of another Client;


• Where the strategies are the same, the Adviser will generally allocate investment opportunities pro rata between the applicable Clients;


• However, pro rata allocations between Clients may not always be possible because of certain differences including ERISA, client guidelines and other specific client requirements (including liquidity requirements), tax consequences, legal consideratio ns, and the available cash for investments;


• Where pro rata allocation is not possible, the Adviser’s Investment Committee will allocate investment opportunities in a manner it believes to be fair and equitable to each Client over time. In making these allocations, the Investment Committee takes into account the following factors, including, among other things:

o The Client’s specific investment objectives and strategies; o The composition, size, characteristics, and liquidity profile of the Client, includ ing the plans for other upcoming proposed investments; o The cash availability and flows; o The amount already committed by each Client to a specific investment and the target weight of the related strategy in the portfolio; o Each Client’s risk tolerance and the relative risk of the investment; and o The marketability of the security being considered. please register to get more info

The Adviser advises Commingled Funds; Funds of One; Separate Accounts, Segregated Portfolios, foundations; endowments; sovereign wealth funds; and Taft-Hartley, corporate, municipal, state, and non-U.S. pension plans. Requirements to Open or Maintain an Account. Certain Funds may not be available to all U.S. investors, may limit the number of U.S. investors that they accept, or may require that any U.S. investors certify that they are a “qualified purchaser” as defined in Section 2(a)(51)(A) of the Investment Company Act of 1940, as amended (the “Company Act”), and an “accredited investor” as defined by Regulation D promulgated under the Securities Act of 1933, as amended. Certain Funds’ Boards of Directors have sole discretion to decline to accept the subscription of a Fund’s interests for any prospective investor. With regard to the Commingled Funds, in general, there is a required minimum investment of $5 million and a required minimum additional subscriptio n amount of $1 million. Moreover, with regard to the Delaware-domiciled Commingled Funds, such a Fund’s general partner or managing member (as the case may be) in its sole discretion, however, may accept either initial or additional subscriptions of a lesser amount. Furthermore, with regard to the Cayman Islands-domiciled Commingled Funds, such a Fund’s Board of Directors, in its sole discretion, may accept either initial or additional subscriptions of a lesser amount (but in no event less than such amounts as required to comply with section 4(3) of the Mutual Funds Law (2009 Revision) of the Cayman Islands, as amended from time to time.

In general, a minimum investment of approximately $50 million-$100 million is generally imposed on an investor that wishes to invest in a Fund of One or a client that wishes to open a Separate Account, depending on strategy, scope of mandate, and other factors, including other investment mandates such investor or client has with the Adviser. This minimum investment may be waived at the discretion of the Adviser.

The Funds generally limit the ability of investors to withdraw capital or redeem or transfer their interests for a period of time after investment. These lock-ups may differ among the Clients and among the classes of interests in the same Fund. Generally, a Fund may waive or alter these requirements. For further information regarding the particular withdrawal and redemption terms of the Funds, please refer to the applicable private placement memorandum and supplements.

Qualifying Employee Investments. Certain qualifying employees are able to invest in certain Funds; investments may consist of closed-end private equity, private credit, hybrid, or other investments and funds offered by Portfolio Managers. All participants in such investment vehicles are required to be a qualified purchaser as defined in Section 2(a)(51)(A) of the Company Act or a “knowledgeable employee” as defined in Rule 3c-5 under the Company Act. In each case, such qualifying employees are required to be directly engaged in providing investment advisory or other services to the respective Fund in which they invest. please register to get more info

Methods of Analysis. In the multi- manager alternative portfolios, the Adviser will engage Portfolio Managers to manage assets primarily by investing such assets in Portfolio Funds managed by such Portfolio Managers or third-party Sub Advisers, using a wide variety of investment styles. Portfolio Managers and Sub Advisers use investment strategies covering a wide range of asset classes. The Adviser employs an investment process covering: (a) market review and asset allocation among different investment strategies and asset classes, (b) Portfolio Manager and Sub Adviser identification and due diligence, including legal and operational due dilige nce, (c) portfolio construction, (d) risk management, and (e) portfolio monitoring. The Adviser invests with Portfolio Managers and Sub Advisers that use investment strategies and risk manageme nt processes consistent with the Clients’ investment objectives and policies. There can be no assurance that the Adviser will always be able to invest in a particular Portfolio Fund or that the investment strategy used by a Portfolio Fund, Sub Adviser, or portfolio will be successful.

The Adviser relies on research produced internally and externally for purposes of manager selection and asset allocation. The Adviser utilizes internal and external quantitative tools for evaluating portfolios of hedge funds and other managers, quantitative tools to assess the cyclicalit y of various strategies, risk management tools to manage the risk of the overall portfolio and individual Portfolio Managers, and proprietary tools for monitoring the portfolios of underlying hedge funds and other Portfolio Managers.

Investment Strategies. The Adviser primarily invests, directly or indirectly (through Portfolio Funds (as defined below) and Sub Advisers (as defined below)), across a range of strategies, including multi-strategy; small/emerging managers; non-U.S., emerging, and frontier markets; diversified; long/short equity; credit long-only; short-biased equity; activist relative value; market neutral; equity-hedged; global event-driven macro/commodities; opportunistic; and real estate. Assigning strategy classifications requires the Adviser’s subjective judgement. The Adviser may create and assign new strategy and sub-strategy classifications to reflect the Adviser’s judgement of available strategies and Portfolio Managers. The Portfolio Managers’ strategies are also flexible. Therefore, assigned strategy classifications may change over time. In addition, mult i- strategy Portfolio Managers may employ any of the aforementioned strategies, as well as any other strategy that such Portfolio Managers determine presents the opportunity for profit in light of then- current market conditions. The Adviser may utilize local access products, derivatives, exchange traded funds, and futures, including index futures, in certain portfolios.

All investments risk the total loss of capital and Clients should be prepared to bear this loss. The following comprise risks associated with the Adviser’s asset management practices as well as specific risks associated with Portfolio Managers, Portfolio Funds, and Sub Advisers: Risk of Loss. Although this part of Item 8 is divided for ease of reference among
general considerations and more specific considerations based upon strategy and investment
type, the risks of loss described below are not limited to the particular section in which the y
appear, and may apply generally or to a variety of investment types described regardless of
section.
General Risk of Loss. Clients and investors in pooled investment vehicles should understand that all investment strategies and the investments made pursuant to such strategies involve risk of loss, including the potential loss of the entire investment, which clients and investors should be prepared to bear. The investment performance and the success of any investment strategy or particular investment can never be predicted or guaranteed, and the value of a client’s or an investor’s investments will fluctuate due to market conditions and other factors. The investment decisions made and the actions taken will be subject to various market, liquid it y, currency, economic, political, and other risks, and investments may lose value.

Significant Risks. The Adviser may invest or advise on the allocation of a Client’s capital into a wide range of investments and transactions directly or indirectly across global markets, including, but not limited to, Portfolio Funds and Sub Advisers. Investing in Portfolio Funds and investing directly or indirectly in securities, futures, and derivatives involves risk of loss that investors in the Funds and advisory clients should be prepared to bear.

General Investment Risks. In general, the success of a portfolio depends on the Adviser’s ability to select and invest assets with individual Portfolio Funds and with Sub Advisers, and the Adviser’s portfolio construction and risk management expertise. The Portfolio Managers and Sub Advisers, or in limited cases when permitted, the Adviser on behalf of its Clients, may use investment techniques such as margin transactions, short sales, option transactions, forward and futures contracts, or the purchase or sale of exchange traded funds. In certain circumstances, these practices can maximize adverse investment impacts. No guarantee or representation is made that the investment program including, without limitation, the investment objectives, diversifica t io n strategies, or risk monitoring goals, will be successful, and investment results may vary substantially over time.

No assurance can be given that the investment strategies to be used will be successful under all or any market conditions. Past investment results are not necessarily indicative of their future performance. No assurances can be made that profits will be achieved or that substantial losses will not be incurred.

Although the Adviser conducts due diligence and monitors portfolio performance, there is no assurance that the Adviser’s oversight will permit a Client to avoid losses.

Redemptions from Portfolio Funds; Limited Liquidity; In-Kind Distributions. Clients may have limited rights to redeem, transfer, or otherwise liquidate investments in Portfolio Funds. Investments in Portfolio Funds are not themselves marketable, and therefore Clients are not able to readily dispose of interests in Portfolio Funds. Accordingly, with respect to the Funds that invest in Portfolio Funds, the submission of a duly executed redemption request by an investor in a Fund does not mean that such Fund will necessarily be able to provide liquidity at the time requested in the redemption request as the Portfolio Fund may be subject to limitations of liquid it y and potential restrictions on redemptions. Under the terms of the governing documents of the Portfolio Funds, the ability to redeem any amount invested therein may be subject to certain restrictions and conditions, including restrictions on the redemption of shares for a period of time (“lock-up”), restrictions on the amount of redemptions at a given time by an investor and at the Fund level, and the frequency with which redemptions can be made, and investment minim ums that must be maintained. Additionally, the Portfolio Funds typically reserve the right to reduce (“gate”) or suspend redemptions and to satisfy redemptions by making distributions in-kind, under certain circumstances. The ability to redeem all or any portion of shares may be adversely affected to varying degrees by such restrictions depending on, among other things, the length of any restricted periods imposed by the Portfolio Funds, the amount and timing of a requested redemption in relation to the time remaining of any restricted periods imposed by related Portfolio Funds, the aggregate amount of redemption requests, the next regularly scheduled redemption dates of such Portfolio Funds, the imposition of “gates” or suspensions, the decision by a Portfolio Fund to satisfy redemptions in kind, and the satisfaction of other conditions. Additionally, in some cases Portfolio Managers may also suspend the determination of the net asset value of all or a portion of their portfolios. The absence of such valuations would make it more difficult for the Adviser to accurately value the portfolio.

In addition, the Portfolio Funds may invest a portion of their assets in restricted or non- publicly traded securities, securities that are subject to legal or other restrictions on transfer or for which no liquid market exists, securities of distressed issuers, securities traded on non-U.S. exchanges, and futures contracts. The sale of restricted and illiquid securities often requires more time and results in higher brokerage charges or dealer discounts and other selling expenses than does the sale of securities eligible for trading on national securities exchanges or in the OTC markets. Futures positions may be illiquid because certain commodity exchanges limit fluctuations in certain futures contract prices during a single day by regulations referred to as “daily price fluctuation limits” or “daily limits.” Under such daily limits, during a single trading day no trades may be executed at prices beyond the daily limits. Once the price of a contract for a particular future has increased or decreased by an amount equal to the daily limit, positions in the future can neither be taken nor liquidated unless traders are willing to effect trades at or within the limit. Such investment positions could prevent a Portfolio Manager from liquidating unfavorab le positions promptly and subject a Client’s portfolio to substantial losses. (See “Futures Contracts” above). Similar limits may apply to securities traded on a non-U.S. exchange. (See Non-U.S. Issuers and Non-U.S. Securities Markets” below).

Portfolio Funds may be permitted to satisfy redemption requests by distributing their interests in kind. Thus, upon the withdrawal of all or a portion of its interest in a Portfolio Fund, a Client may receive securities that are illiquid or difficult to value. Similarly, although the Advis er expects to distribute cash to redeeming investors and to separate account clients liquidating their accounts, there can be no assurance that the Portfolio Funds will have sufficient cash to satisfy redemption or liquidation requests, or that the Adviser will be able to liquidate a Client’s investments at the time of such redemption or liquidation requests. An in kind distribution may not be readily marketable or saleable and may have to be held by the recipient (e.g., a Client, investor, or advisory client) for an indefinite period of time. The Adviser has no control over the liquidity of Portfolio Funds and depends on the Portfolio Manager to provide appropriate valuations as well as liquidity to process investor redemptions. Moreover, restrictions on liquidity that Portfolio Managers impose under certain circumstances may materially restrict or delay investor redemption rights. If a material portion of a Fund’s or a Separate Account’s assets are allocated to Portfolio Funds that take such actions, such relevant Fund or Separate Account likely will not be able to withdraw from such Portfolio Funds for an extended period of time. This could expose the applicable Fund or Account to losses they may have avoided if they had been able to allocate away from such Portfolio Funds. The complicated and often protracted process of withdrawing from Portfolio Funds could hinder the Fund’s or Account’s ability to timely meet an investor’s or client’s withdrawal and redemption requests, as well as the applicable Fund’s or Separate Account’s ability to adjust its Portfolio Fund allocations. It could also cause a Fund or Separate Account to become unbalanced in the event they withdraw from their more liquid Portfolio Funds to fund their withdrawals or expenses. Also, to the extent that a material portion of a Fund’s or Separate Account’s Portfolio Funds suspend net asset value calculations, the Adviser may be unable to calculate the relevant Fund’s or Separate Account’s net asset value.

Layering of Fees. By investing in the Portfolio Funds indirectly through a Fund or a Separate Account, an investor or advisory client bears a pro rata portion of the management fee and incentive fee or allocation and other expenses of such Fund or Separate Account and also indirectly bears a pro rata portion of the asset-based fees, performance-based compensation and other expenses borne by the Fund or Separate Account as an investor in Portfolio Funds.

Volatile Markets. The prices of commodities contracts and various types of derivative instruments are highly volatile. Price movements of forward contracts, futures contracts, and other derivative contracts are influenced by, among other things, interest rates; changing supply and demand relationships; trade, fiscal, monetary, and exchange control programs and policies of governments; and national and international political and economic events and policies. In addition, governments from time to time intervene in certain markets, particularly those in currencies and interest rate-related futures and options, which may cause all of such markets to move rapidly in the same direction because of, among other things, interest rate fluctuations. When investing in non-U.S. instruments, portfolios are also subject to the risk of failure of the exchanges on which their positions trade or of their clearinghouses resulting from less governme nta l regulation and intervention, and there may be a higher risk of financial irregularities or lack of appropriate risk monitoring and controls. Risks associated with investing in securities of non-U.S. issuers are more pronounced with respect to investments in securities of issuers in emerging and frontier markets. Certain portfolio assets are invested with Portfolio Managers that invest globally in the U.S. and in other developed markets and in emerging and frontier markets outside the United States.

The strategies may be adversely affected by deteriorations in the financial markets and economic conditions throughout the world, some of which may magnify the risks described herein and have other adverse effects. Such conditions may cause certain instruments, includ ing historically liquid instruments, to become less liquid and more difficult to value, and thus harder to dispose of. These issues may be exacerbated by, among other things, uncertainty regarding the potential duration and scope of the problem and the degree of exposure of financial institut io ns and other market participants. While such conditions persist, the strategies will also be subject to heightened risks associated with the potential failure of custodians, futures clearers, brokers, clearinghouses, exchanges and counterparties, as well as increased systemic risks associated with the potential failure of one or more systemically important institutions. Systemic Risk. Credit risk may arise through a default by or because of one of several large institutions that are dependent on one another to meet their liquidity or operational needs. A default by or because of one institution may cause a series of defaults by the other institutio ns. This is sometimes referred to as a “systemic risk” and may adversely affect financ ia l intermediaries, such as clearing houses, banks, securities firms and exchanges with which a Client and the Portfolio Funds interact. A systemic failure could have material adverse consequences on Clients and the Portfolio Funds and on the markets for the securities in which the Portfolio Funds seek to invest.

Managed Account Allocations. The Funds or Separate Accounts may invest with certain portfolio managers (i.e., the Sub Advisers and Trading Advisors) by opening managed accounts (through the Adviser establishing sub-advisory agreements with such portfolio managers), rather than by investing in Portfolio Funds. This permits the Adviser to customize the invest me nt guidelines and tailor other features to suit particular portfolios that may not be permissible if investing in a Portfolio Fund. Although there may be certain advantages to managed accounts, such accounts may expose a Client’s portfolio to theoretically unlimited liability, and it is possible, given the leverage at which certain of the Sub Advisers and Trading Advisors trade, that a Client’s portfolio could lose more in a managed account with a particular Sub Adviser or Trading Advisor than with an investment in a Portfolio Fund. To mitigate this risk, the Adviser may structure a separate account investment with a Sub Adviser or Trading Advisor, as applicable, through a special purpose vehicle. The Adviser may also invest in commingled funds managed by a managed account manager, depending upon the particular circumstances and applicable investor guidelines and portfolio.

Intermediate Vehicles to Facilitate Investments. To structure or facilitate an invest me nt with a particular Portfolio Fund by the Funds or Separate Accounts for multiple investors, the Adviser may form a separate vehicle or segregated portfolio (i.e., an Intermediate Vehicle) through which such investments into a Portfolio Fund may be made by multiple Funds and Separate Accounts for purposes of obtaining access to a particular Portfolio Manager or Portfolio Fund . The Funds and Separate Accounts may also utilize such vehicles to make managed account allocations to limit their potential liability. Such Funds and Separate Accounts will bear their proportionate share of the costs and expenses associated with the establishment and ongoing operation of such vehicles. Each shareholder and prospective investor in the Intermediate Vehicle will not directly own any interests or shares in the Portfolio Funds to which it has indirect exposure through its investment in the Intermediate Vehicle. In the event of the removal or termination of the Adviser, with respect to any Intermediate Vehicle in which the Client is invested, each shareholder will be entitled to receive its pro rata share of redemption proceeds equal to the net asset value of the Client’s interest in such Intermediate Vehicle as of the effective date of redemption. Redemptions from the Intermediate Vehicles in which the Client is invested will generally be subject to the terms imposed by such Intermediate Vehicles, including without limitation, restrictions on the timing or amount of liquidity. An Intermediate Vehicle will generally have the liquidity that is associated with the underlying Portfolio Funds in which such Intermediate Vehicle is invested, but in some cases it may differ depending upon the number of investors in the vehicle and such vehicle’s size and strategy. Side Letters. The Adviser (or an affiliated general partner) may enter into side letter agreements or other similar agreements with investors in a Fund in connection with their admissio n to such Fund without the approval of any other investor. The side letters or other similar agreements may have the effect of establishing rights under, altering, or supplementing the terms of the governing documents of such applicable Fund with respect to one or more such investors in a manner more favorable to such investors than those applicable to other investors. Such rights or terms in any such side letter may include, without limitation, reporting obligations or rights or terms necessary in light of particular legal, public policy, or regulatory characteristics of an investor.

Limited Diversification. In the normal course of making investments on behalf of a Client, the Adviser may, but depending upon the portfolio may not be obligated to, diversify investme nts. A Client’s portfolio could become significantly concentrated, for example, in any one Portfolio Fund, issuer, industry, sector, strategy, country or geographic region, and such concentration of risk may increase any losses suffered by the Client. In addition, it is possible that the Adviser may select investments that are concentrated in a limited number or type of financial instruments. This limited diversification could expose a Client to losses disproportionate to market movements in general if there are disproportionately greater adverse price movements in those financ ia l instruments.

“Side Pocket” or Special Investments. The Portfolio Funds may invest a portion of the value of their total assets in investments that are illiquid, including “side pocket” investments or “special investments.” “Side pockets” may be created by a Portfolio Fund in order to accommodate illiquid investments prior to the time when they are either sold or become readily marketable. If a side pocket is created, an allocable portion of the interests held by investors in the Portfolio Fund typically will be converted at net asset value to a separate class of interest in the Portfolio Fund corresponding to the underlying investment in the side pocket. New investors in the Portfolio Fund generally will not receive any interest issued in connection with pre-existing side pocket investments. Side pocket investments will generally be carried on the books of the Portfolio Funds (and consequently on the books of the Fund or Separate Accounts) at fair value (which may be cost) as determined by the Portfolio Managers. There is no guarantee that fair value will represent the value that will be realized by the Portfolio Fund on the eventual dispositio n of the side pocket investment or that would, in fact, be realized upon its immediate disposition. If an investor (e.g., a Fund or Separate Account) were to redeem its interest in a Portfolio Fund that makes side pocket investments, such investor would typically remain exposed to the risk of loss on its indirect interest in any side pocket until such investments were realized or deemed realized. Management fees, performance fees, and other expenses of the Portfolio Fund would typically continue to accrue until the side pocket investment is realized or deemed realized. If the proceeds from the disposition of a side pocket investment were insufficient to cover any accrued expenses, such accrued expenses might be borne disproportionately by other investors in such Portfolio Fund, including the Clients. Valuation Risks. With respect to Funds and Separate Accounts that invest in Portfolio Funds, the valuations of investments in non-registered investment funds are based on the net assets/partner’s capital reported by the managers of such Portfolio Funds as a practical expedient in conformity with U.S. GAAP. Accordingly, the Adviser relies primarily on information provided by Portfolio Managers in valuing a Client’s investments in their Portfolio Funds and determining the value of the Client’s portfolio. A Client’s investment in the Portfolio Funds will generally be valued in accordance with the net asset value/partner’s capital information provided by the managers and/or fund administrators of such Portfolio Funds as part of their periodic investor statements. These investor statements generally will be provided for such Portfolio Funds based on the interim unaudited financial records of the Portfolio Fund, and, therefore, could be subject to adjustment (upward or downward) based on the annual independent audit of such financ ia l records.

In addition, generally, neither a Client’s administrator nor the Adviser will have access to detailed information regarding the underlying portfolios of the Portfolio Funds; each relies on the limited information provided to them by the Portfolio Funds or their administrators. The failure of the Portfolio Funds or their administrators to appropriately value the investment securities of the Portfolio Funds could adversely affect a Client and performance information that is reported to the client.

Investments in securities (other than non-registered investment funds) are valued using publicly available pricing information provided by unaffiliated service providers. A service provider could provide an inaccurate price, and the Fund Administrator and Custodians that serve the Funds and Separate Accounts could fail to accurately record the prices provided by the pricing service providers. The Adviser has a series of controls in place to mitigate such risks of pricing errors by using multiple service providers and price reconciliations for each Valuation date. Additionally, investments in certain securities may be illiquid, requiring the Adviser to estimate the fair value of such securities according to the Adviser’s valuation policies and procedures.

Valuation Estimates. With respect to Funds and Separate Accounts that invest in Portfolio Funds, in most cases, the Adviser has limited or no ability to assess the accuracy of the valuatio ns received from a Portfolio Manager. Furthermore, the monthly net asset values of Portfolio Funds provided to the Adviser from Portfolio Managers are unaudited, subject to revision upon conclusion of such underlying Portfolio Fund’s annual audit. Revisions to a Client’s gain and loss calculations are an ongoing process, and actual net capital appreciation or net capital depreciation figures may not be final until an annual audit is completed. Further, some Portfolio Funds may include illiquid investments (which may be in side pockets), and the valuations of such securities are subject to significant portfolio manager discretion.

Investments in securities (other than non-registered investment funds) may be (or become) illiquid, requiring the Adviser to estimate the fair values in good faith. The Adviser follows the fair value hierarchy under U.S. GAAP, which requires the applicable portfolio to utilize the most publicly discoverable information available to estimate the fair values of such securities. Counterparty Risks; Counterparty and Service Provider Relationships. The Adviser with respect to certain Funds and the Portfolio Managers and Sub Advisers establish relationships to obtain brokerage, prime brokerage, custody and banking services, financing, and derivative intermediation and to act as the counterparty to derivative transactions. There can be no assurance, however, that the Adviser, the Portfolio Managers and the Sub Advisers will be able to mainta in such relationships or establish others. An inability for the Adviser, a Portfolio Manager or Sub Adviser to establish or maintain such relationships would limit its trading activities and prevent the Adviser, Portfolio Fund or Sub Adviser from trading at optimal rates and terms, could create losses, preclude the Adviser or Portfolio Fund from engaging in certain transactions, concentrate the holdings of the assets of certain Funds, the Portfolio Fund, or Sub Adviser with a limited number of counterparties, and limit the availability of financing, each of which could materia lly adversely affect the Clients. Moreover, a disruption in the services provided by any such relationships before the Adviser, a Portfolio Manager, or Sub Adviser is able to establish additiona l relationships (which may not be successful) could have a significant impact on its business due to its reliance on such counterparties.

Creditworthiness of Prime Brokers and Other Service Providers. The Adviser and the Portfolio Managers have established relationships with broker-dealers, banks, and their affiliates (both in the United States and outside the United States) for the provision of services, includ ing holding and maintaining the funds, securities, commodity interests, and other property and the clearance of their securities transactions. These arrangements can cover securities, loans, derivatives, swaps, options, futures, foreign exchange, and securities lending transactions and usually involve the provision of financing to the applicable Fund and Portfolio Fund. A Fund’s and Portfolio Fund’s assets held by a prime broker that is providing financing generally will be secured in favor of that prime broker and its affiliates.

The Portfolio Managers generally engage U.S. broker-dealers as their prime brokers. The prime brokerage arrangements, however, will often include contractual relationships within a prime broker's group of affiliates, some of which may be located outside of the United States. A Portfolio Fund’s prime brokerage arrangements typically allow for transfer of the Portfolio Fund’s assets to the prime broker’s affiliates and also to sub-custodians that may be located in various jurisdictions, including jurisdictions outside the United States. These entities may hold securities, commodities, cash, collateral, or other assets of the Portfolio Fund in such jurisdictions as may be necessary to facilitate the provision of the services to the Portfolio Fund. The agreements with the financial institutions are also complex and generally include cross-collateral, netting, and cross- default provisions to protect the financial institution from the failure of the Portfolio Fund to meet its obligations under a variety of agreements. Bankruptcy laws and other laws and regulat io ns relating to the protection of assets of the Portfolio Fund held by the financial institution vary substantially by jurisdiction, type of legal entity, and are very complex and uncertain and can involve the risk of loss or inability to access any or all of the assets of the Portfolio Fund held by a financial institution that becomes subject to the bankruptcy or insolvency regime. Portfolio Fund assets may be held with U.S. broker-dealers or U.S. or non-U.S. banks or their affiliates and the risks associated with assets held at each of these various institutions may differ substantia l ly. Although there are various laws and regulations in various jurisdictions that may provide some protection to customers of brokerage firms and commercial banks in the event of their insolve nc y, these protections are not uniform across jurisdictions and it is not always clear when such protections may apply. Because of the large number of entities and jurisdictions involved and the range of possible factual scenarios involving the insolvency of a counterparty, it is impossible to generalize about the effect of their insolvency on the Clients or the Portfolio Funds and their assets. Investors and Separate Account clients should assume that the insolvency of any counterparty would result in a loss to the portfolio (directly or through the Portfolio Funds), which could be material. Even in countries where applicable law provides protection to client assets, such protections may not adequately protect a Portfolio Fund (and, indirectly, a Client’s portfolio) from risk of loss. For example, although U.S. rules and regulations applicable to broker-dealers are designed to protect client assets (including a Portfolio Fund’s assets), it is possible that, if one of the Portfolio Fund’s brokers were to become insolvent, the assets of the Portfolio Fund held at such broker could be at risk. Although U.S. broker-dealers are required to segregate client assets from their proprietary assets and are required to hold specified amounts of capital in reserve, client assets are normally held in pooled client accounts for the benefit of all clients. Additionally, the broker may be able to transfer client assets out of such client accounts or use such assets (includ ing cash) in the ordinary course of its business. A Portfolio Fund could experience losses if the clients’ claims exceed the amount of client assets such brokers actually held at the time of the insolve nc y. With respect to U.S. broker-dealers, in the event client claims are greater than client property, the clients’ remaining claims may be satisfied, along with all general unsecured claims, from the broker's non-customer assets (including its regulatory capital). In addition, while the return of client property is designed to occur on an expedited basis (usually by transfer of the accounts to a solvent broker), there exists the risk of delay in, or inability to make, such a return or transfer, in whole or in part, by the insolvent broker. Furthermore, a Portfolio Fund may be unable to trade such securities or other property held by the insolvent broker during this transfer period or during a pending insolvency proceeding. Such a situation would create the possibility of a substantia l loss to a Portfolio Fund (and, indirectly, a Client) with respect to its assets held at such broker. Since the amount and type of property ultimately received by a Portfolio Fund may remain indeterminate until actually returned, or upon resolution of any insolvency proceeding, as applicable, such Portfolio Fund may be unable to adequately hedge its positions in such property.

Many Portfolio Funds rely on prime brokers to provide financing for many of their investment activities. Financial institutions may re-evaluate their prime brokerage business from time to time, which may impact the availability of credit to a Portfolio Fund and the terms on which it is offered, including the cost thereof, creating a more difficult financing environment for many asset classes and this may potentially adversely affect the Portfolio Fund’s returns and investment activity. In addition, the Portfolio Fund may face an increased risk of being subject to significant changes in margin requirements as prime brokers modify their risk models to determine how much to lend to their customers. Furthermore, prime brokers may face additional regulat io n in the foreseeable future, which may affect their willingness or ability to provide prime brokerage services, and the costs of such services. Financing costs are likely to be significantly higher or assets may become impossible to finance if they cannot be financed by prime brokers. Risk of Counterparty Default. The stability and liquidity of repurchase agreements, swap transactions, forwards, and other over-the-counter (“OTC”) derivative transactions depend in large part on the creditworthiness of the parties to the transactions. The failure of a prime broker could have a material adverse effect on a Portfolio Fund (and a Client’s portfolio) and certain Funds. Although the Adviser and the Portfolio Managers evaluate the creditworthiness of their respective Fund’s and Portfolio Fund’s prime brokers and other service providers, it is often impossible to obtain sufficient information to make fully informed judgments or determinations of the risk that a particular financial institution may fail, particularly given the speed with which a financ ia l institution’s creditworthiness may decline when faced with liquidity pressures. Strategies to minimize such risk include moving assets from one prime broker to another prime broker, custodian, or bank or establishing segregated accounts for securities, if possible, which creates additional operational risk. If there is a default by the counterparty to such a transaction, the Adviser and the applicable Portfolio Manager will under most normal circumstances have contractual remedies pursuant to the agreements related to the transaction. Exercising such contractual rights, however, may involve delays or costs that could result in the net asset value of a particular Fund or a Portfolio Fund being less than if such Fund or Portfolio Fund had not entered into the transaction. Furthermore, there is a risk that any of such counterparties could become insolvent. If one or more of the Funds’, Separate Accounts’, or the Portfolio Funds’ counterparties were to become insolve nt or the subject of liquidation proceedings in the United States (either under the Securities Investor Protection Act or the United States Bankruptcy Code), there exists the risk that the recovery of the Funds’, Separate Accounts’, or the Portfolio Funds’ securities and other assets from such prime broker or broker-dealer will be delayed or be of a value less than the value of the securities or assets originally entrusted to such prime broker or broker-dealer.

In light of the extensive, and sometimes complex, financing and trading arrangements that the Portfolio Funds have with their prime brokers, each Portfolio Fund may face the risks, among other things, that the assets of the Portfolio Fund might be transferred out of its accounts or might be in accounts that do not benefit from client asset protection or that a prime broker will have a security interest in the assets of the Portfolio Fund that it holds. Because of the large number of entities and jurisdictions involved and the range of possible factual scenarios involving the insolvency of a prime broker or any of its sub-custodians, agents or affiliates, it is impossible to generalize about the effect of their insolvency on the Portfolio Fund and its assets. Investors and Separate Account clients should assume that the insolvency of any of the Portfolio Fund’s prime brokers could result in the loss of all or a substantial portion of the Portfolio Fund’s assets held by such prime broker. Should the Portfolio Fund be unable to identify, access, or value its assets or establish with any certainty the amount or likelihood of recovery of any claim, such circumsta nces could cause substantial losses to such Portfolio Fund (and, indirectly, a Client’s portfolio). Such losses might not be limited to the assets that were held by that prime broker, including replacement costs of relevant assets and fees and expenses. Moreover, the affected Portfolio Fund might be required to make future payments or deliveries to the insolvent prime broker without set-off of amounts due to it.

Risks Associated with Exchanged Traded Funds (“ETFs”). Funds or Separate Accounts may invest, either directly or through Portfolio Funds in ETFs, including those that seek to replicate stock indices. ETFs may be used by the Adviser from time to time in certain circumstances where the timing and extent of particular exposure or investment exposures may be efficiently obtained through ETFs, as appropriate in the Adviser’s discretion. All ETF products are subject to risk that may result in the loss of principal. Emerging market ETFs involve additional risks, including currency fluctuations and the potential for adverse developments in specific countries or regions. Hedging Transactions. The Adviser may for certain Clients when guidelines permit, from time to time, utilize a variety of financial instruments, such as futures, options, swaps, and forward contracts and similar derivatives, both for investment purposes and for hedging purposes. Although the Adviser may enter into hedging transactions to seek to reduce a Client’s risk, such transactions may not be fully effective in mitigating the risks in all market environments or against all types of risk (including unidentified or unanticipated risks), thereby incurring losses to the Client. In addition, such hedging transactions may result in a poorer overall performance for a Client than if the Adviser had not engaged in any such hedging transactions. Moreover, it should be noted that the Adviser may determine not to hedge against, or may not anticipate, certain risks and that a Client’s portfolio will always be exposed to certain risks that cannot be hedged, such as credit risk (relating both to particular securities and counterparties).

Stock Index Options and Futures. The Adviser with respect to certain Funds and the Portfolio Managers may purchase and sell call and put options on stock indices listed on securities exchanges or traded in the over-the-counter market for the purpose of realizing its invest me nt objectives or for the purpose of hedging its portfolio. A stock index fluctuates with changes in the market values of the stocks included in the index. The effectiveness of purchasing or writing stock index options for hedging purposes will depend upon the extent to which price movements in the portfolio correlate with price movements of the stock indices selected. Because the value of an index option depends upon movements in the level of the index rather than the price of a particular stock, whether certain Funds and the Portfolio Managers will realize gains or losses from the purchase or writing of options on indices depends upon movements in the level of stock prices in the stock market generally or, in the case of certain indices, in an industry or market segment, rather than movements in the price of particular stocks. Accordingly, successful use by the Adviser or a Portfolio Manager of options on stock indices will be subject to an ability to correctly predict movements in the direction of the stock market generally or of particular industries or market segments. This requires different skills and techniques than predicting changes in the price of individual stocks. Put and call options are highly specialized activities and entail greater than ordinary investment risks. For example, traders who sell options are subject to the entire loss that occurs in the underlying item (less any premium received).

The price of stock index futures contracts may not correlate perfectly with the movement in the underlying stock index because of certain market distortions. First, all participants in the futures market are subject to margin deposit and maintenance requirements. Rather than meeting additional margin deposit requirements, investors may close futures contracts through offsetting transactions that would distort the normal relationship between the index and futures markets. Second, from the point of view of speculators, the deposit requirements in the futures market are less onerous than margin requirements in the securities market. Therefore, increased participat io n by speculators in the futures market also may cause temporary price distortions. Successful use of stock index futures contracts is subject to the Adviser’s and the Portfolio Managers’ ability to correctly predict movements in the direction of the market. Derivatives. A Client’s portfolio may include direct investments in derivatives or indirect exposure to derivative instruments through investing in Portfolio Funds that enter into derivative transactions. Derivative financial instruments include, without limitation, futures, options, interest rate swaps, forward currency contracts, and credit derivatives such as credit default swaps. Derivatives are based on the performance of an underlying asset, index, interest rate or other investment. Derivatives may be volatile and involve various risks, depending upon the derivative and its function in a portfolio. Portfolio Funds or a Client may take positions in derivatives either to increase or to decrease the level of risk, or to change the types of risks to which the portfolio is exposed. Swaps, options and other derivative instruments may be subject to various types of risks, including market risk; liquidity risk; risk of non-performance by the counterparty, including risks relating to the financial soundness and creditworthiness of the counterparty; legal risk; and operations risk. The regulatory regime regarding derivatives is changing. The U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) granted the CFTC and SEC broad rulemaking authority to implement various provisions of the Dodd-Frank Act, includ ing comprehensive regulation of the OTC derivatives market. These regulations include derivative exchange trading and clearing requirements, as well as requiring OTC derivatives dealers and major OTC derivatives market participants to register with the SEC and/or CFTC. The implementation of such regulations could adversely affect financial firms that enter into derivative transactions by increasing transaction costs and imposing restrictions on the investment or other operations of such firms.

Regulated Investors. Certain prospective investors may be subject to Federal and state laws, rules, and regulations that may regulate their participat ion in the Funds as well as their entering into a Separate Account with the Adviser, or their engaging directly, or indirectly through an investment in the Funds, in investment strategies of the type which the Portfolio Managers may utilize from time to time (e.g., short sales of securities and the use of futures, leverage, and limited diversification). While the investment programs are generally appropriate for tax-exempt organizations for which an investment in the Funds or Separate Accounts would otherwise be suitable, each type of exempt organization may be subject to different laws, rules, and regulat io ns and prospective investors should consult with their own counsel and advisers as to the advisabilit y and tax consequences of any investment. Investment by entities subject to ERISA and other tax- exempt entities requires special consideration. Trustees or administrators of such entities are urged to carefully review all investment information.

Identity of Beneficial Ownership and Withholding on Certain Payments. In order to avoid a U.S. withholding tax of 30% on certain payments (including payments of gross proceeds) made with respect to certain actual and deemed U.S. investments, the Adviser’s Funds that are a “foreign financial institution” have registered with the U.S. Internal Revenue Service (the “Service”) and generally will be required to identify, and report information with respect to, certain direct and indirect U.S. account holders (including debtholders and equityholders). The Cayman Islands has signed a Model 1B (non-reciprocal) inter-governmental agreement with the United States (the “US IGA”) to give effect to the foregoing withholding and reporting rules. If the US IGA is applicable to the Adviser’s Funds, so long as such Funds comply with the US IGA and the enabling Cayman Islands legislation, such Funds will not be subject to the related U.S. withhold ing tax. A non-U.S. investor in the Adviser’s Fund that is a foreign financial institution will generally be required to provide to the Fund information that identifies its direct and indirect U.S. ownership. Under the US IGA, any such information provided to the Fund and certain financ ia l information related to such investor’s investment in the Fund will be shared with the Cayman Islands Tax Information Authority or its delegate (the “Cayman TIA”). The Cayman TIA will exchange the information reported to it with the Service annually on an automatic basis. A non- U.S. investor that is a “foreign financial institution” within the meaning of Section 1471(d)(4) of the IRC will generally be required to timely register with the Service and agree to identify, and report information with respect to, certain of its own direct and indirect U.S. account holders (including debtholders and equityho lders). A non-U.S. investor who fails to provide such information to the Fund or timely register and agree to identify, and report information with respect to, such account holders (as applicable) may be subject to the 30% withholding tax with respect to its share of any such payments attributable to actual and deemed U.S. investments of the Fund, and the Fund’s Board of Directors may take any action in relation to an investor’s shares or redemption proceeds to ensure that such withholding is economically borne by the relevant investor whose failure to provide the necessary information or comply with such requireme nts gave rise to the withholding. Affected shareholders should consult their own tax advisors regarding the possible implications of these rules on their investments in the applicable Fund.

Non-U.S. shareholders may also be required to make certain certifications to the applicable Fund as to the beneficial ownership of the Shares and the non-U.S. status of such beneficial owner, in order to be exempt from U.S. information reporting and backup withholding on a redemption of Shares.

Assumption of Business, Terrorism and Catastrophe Risks. The Adviser, Clients, and the Portfolio Funds may be subject to the risk of loss arising from exposure that they may incur, indirectly, due to the occurrence of various events, including, without limitation, hurricanes, earthquakes, and other natural disasters; terrorism; and other catastrophic events. These risks of loss can be substantial and could have a material adverse effect on a Client’s portfolio.

Application of Law Regarding Segregated Portfolio Companies. With regard to Funds structured as a segregated portfolio company in the Cayman Islands, although the segregated portfolio legislation as a matter of Cayman Islands law is intended to insulate the various segregated portfolios from the liabilities of any other segregated portfolio in a segregated portfolio company, a shareholder or creditor may challenge such segregation and there is little guidance on how a court in the Cayman Islands would address such a claim. Further, individual classes of shares issued within each segregated portfolio are not segregated. Accordingly, if the assets attributed to one class of shares in a segregated portfolio were completely depleted by losses and a deficit remained, a creditor could enforce a claim against the assets of the other classes of the segregated portfolio. In addition, to the extent that underlying assets of a segregated portfolio are located in other jurisdictions, such jurisdictions may not recognize the segregation provided for by the Cayman Islands legislation. Application of Law Regarding Delaware Series Limited Liability Companies. The Adviser may form an investment fund that is a Delaware series limited liability company. The segregation of liabilities of one series from the assets of other series under Delaware law has yet to be definitively tested in court. Accordingly, there is a risk that a court could determine that the assets of one series should be applied to meet the liabilities of another series or all series, notwithstanding any provisions of Delaware law to the contrary. No Independent Advice. Prospective investors in a Fund or Separate Account should seek their own legal advice before making an investment in a RockCreek Fund or entering into an investment management agreement with the Adviser. A number of law firms represent RockCreek in a variety of different matters. None of these law firms represent any investors and clients in connection with matters relating to the Funds, Separate Accounts or the underlying investme nts entered by the Adviser on behalf of the Funds and Separate Accounts, including the structuring of these investments, their negotiation and the legal agreements reflecting the investments. Cybersecurity. The Adviser, with the assistance of third-party service providers, endeavors to review and upgrade its Information Technology software and hardware, its electronic network, and its protocols in light of the SEC’s release of its “Cybersecurity Risk Alert” (April 2014) and subsequent releases to mitigate the chance and/or harm of a breach to its IT network due to attacks by hackers, employee error, or malfeasance or other disruptions. Although the Adviser has implemented security measures, any IT network remains vulnerable to an attempted breach. As cybersecurity is an evolving field, the Adviser follows industry developments to determine where improvements to its cybersecurity policies, procedures, and infrastructure can be made and how to prevent and respond to potential cybersecurity breaches.

Cybersecurity – the Adviser, the Funds, the Portfolio Managers, and the Portfolios Funds. As part of its business, the Adviser processes, stores and transmits large amounts of electronic information, including information relating to the transactions of the Fund or a Portfolio Fund. Similarly, service providers of the Adviser, the Funds, a Portfolio Manager or a Portfolio Fund, especially the Administrator, may process, store and transmit such information. The Adviser has procedures and systems in place that it believes are reasonably designed to protect such information and prevent data loss and security breaches. Such measures, however, cannot provide absolute security. The techniques used to obtain unauthorized access to data, disable or degrade service, or sabotage systems change frequently and may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design or manufacture or other problems that could unexpectedly compromise information security. Network connected services provided by third parties to the Adviser or a Portfolio Manager may be susceptible to compromise, leading to a breach of the Adviser’s or a Portfolio Manager’s network. The Adviser’s or a Portfolio Manager’s systems or facilities may be susceptible to employee error or malfeasance, government surveillance, or other security threats. On-line services that may be provided by the Adviser to the investors may also be susceptible to compromise. Breach of the Adviser’s or a Portfolio Manager’s information systems may cause information relating to the transactions of the Fund or a Portfolio Fund to be lost or improperly accessed, used or disclosed. The service providers of the Adviser, the Fund, a Portfolio Manager or a Portfolio Fund are subject to the same electronic information security threats as the Adviser or a Portfolio Manager. If a service provider fails to adopt or adhere to adequate data security policies, or in the event of a breach of its networks, information relating to the transactions of the Fund or a Portfolio Fund and personally identifiable information (to the extent applicable in the context of investors that are natural persons) may be lost or improperly accessed, used or disclosed. The loss or improper access, use or disclosure of the Adviser’s, the Fund’s, a Portfolio Manager’s or a Portfolio Fund’s proprietary information may cause the Adviser, the Fund, a Portfolio Manager or a Portfolio Fund to suffer, among other things, financial loss, the disruptio n of its business, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing events could have a material adverse effect on the Fund or a Portfolio Fund and the shareholders’ investments therein. Cybersecurity – Third Parties. Due to the Adviser’s interconnectivity with third-party vendors, third-party managers and advisers, exchanges, clearing houses and other financ ia l institutions, the Adviser may be adversely affected if any of them are subject to a successful cyber attack or other information security event, including those arising due to the use of mobile technology or a third-party cloud environment. The Adviser cannot ensure that it or such third parties have all appropriate controls in place to protect the confidentiality and integrity of information and data that is transmitted between the Adviser and third parties against cyber attacks,

Although the Adviser takes protective measures and endeavors to strengthen its computer systems, software, technology assets and networks to prevent, detect, react to and recover from potential cyber attacks, there can be no assurance that any of these measures prove effective. Any information security incident or cyber attack against the Adviser or third parties with whom it is connected, or issuers of securities or instruments in which the client portfolios invests, includ ing any interception, mishandling or misuse of personal, confidential or proprietary information, have the ability to cause disruptions and impact business operations, potentially resulting in financ ia l losses, the inability to transact business, violations of applicable privacy and other laws, loss of competitive position, regulatory fines and/or sanctions, breach of client contracts, reputationa l harm or legal liability.

Portfolio Funds in Early Stages of Formation. A Client may invest in Portfolio Funds that are in an early stage of formation or operation. Such an investment in a fund managed by an emerging manager can pose a number of operational and other issues. For example, in its early stages a Portfolio Fund may have little capital available to cover expenses and, accordingly, may have difficulty attracting qualified personnel. Portfolio Managers may face competition from other investment funds, which may be more established, have a larger number of qualified management and technical personnel, and benefit from a larger capital base.

Evolving Regulatory Oversight; Business and Regulatory Risks of Hedge Funds. The regulatory environment for private investment funds continues to evolve, and could limit activit ies and investment opportunities or change the functioning of capital markets. This document does not address or anticipate every possible current or future domestic or non-U.S. law, rule, or regulation that may affect the Adviser, the Portfolio M please register to get more info

Information required by this Item 9 is not applicable to the Adviser. please register to get more info

The Adviser is registered with the SEC as an investment adviser; this registration does not constitute an endorsement of the Adviser by the SEC.

The Adviser is registered with the China Securities Regulatory Commission in connection with being a Qualified Foreign Institutional Investor (“QFII”) in the People’s Republic of China.

The Adviser is registered with the Securities Exchange Board of India as a Foreign Portfolio Investor.

The Adviser is registered with the Capital Market Authority of the Kingdom of Saudi Arabia as a Qualified Foreign Investor.

Certain affiliates of the Adviser act as general partners or managing members in certain Funds and other investment vehicles managed by the Adviser. The Adviser may present qualified and suitable clients information about the opportunity to invest in the Funds or Separate Accounts and in turn in the Portfolio Funds. The Adviser and its employees do not receive any compensatio n in connection with such investments, other than the receipt of ordinary advisory compensation and incentive fees/allocations, if applicable, from the Funds or Separate Accounts in which investors invest.

Additionally, the Adviser may from time to time cause a Commingled Fund, Fund of One, a Separate Account, or Advisory Client to invest (or recommend to a Client that the Adviser advises that it invest) any portion of its assets in another privately offered fund that the Adviser manages. The Adviser may have a potential incentive to select or recommend third- party Portfolio Funds because of fees or other considerations; however, there could also be potential countervailing considerations to select a Fund managed by the Adviser. To mitigate potential conflicts, the Adviser would make any such investments if such investments are consistent with applicable Client investment objectives and guidelines, including without limitat io n, authorizations and limitations on investments in affiliates of the Adviser as set forth in the applicable agreements and guidelines and the interests of the portfolios. The Portfolio Managers selected by the Adviser manage other accounts and may have financial incentives to favor certain of such accounts over the Funds or the Separate Accounts. Any of the Portfolio Managers’ proprietary accounts and other client accounts may compete with the Funds or Separate Accounts for specific trades, or may hold positions opposite to positions maintained on behalf of the Funds or Separate Accounts. The Portfolio Managers may give advice and recommend securities to, or buy or sell securities for, the Portfolio Funds in which the Clients’ assets are invested, which advice or securities may differ from advice given to, or securities recommended or bought or sold for, other accounts and customers even though their invest me nt objectives may be the same as, or similar to, those of the Clients.

Furthermore, the Portfolio Managers may be engaged in substantial investment activit ies other than managing the assets of Portfolio Funds and allocate their time and activity among Portfolio Funds, and their other clients. Moreover, each Portfolio Manager and its affiliated companies and their principals, officers, and employees may buy and sell securities or othe r investments for their own accounts and may have actual or potential conflicts of interest with respect to investments made on behalf of Clients or Portfolio Funds.

The Adviser, among other things, maintains internal policies and procedures, including a Code of Ethics, along with controls and a compliance program designed to prevent and aid in the detection and prevention of breaches of fiduciary duties; address and/or monitor conflicts of interests, insider trading, certain disallowed political activities, violations of the securities laws and regulations, improper allocations of investment opportunities, breaches of confidentiality, and violations of security and privacy policies; and promote the proper valuation and reporting of investment activities and holdings. Third-party administrators are also utilized to provide independent valuation and administration services for the Funds and Separate Account. As part of the due diligence process on Portfolio Funds, the Adviser conducts reviews and ongoing monitoring of Portfolio Funds, Portfolio Fund Managers, Trading Advisors, and Sub Advisers.

The Adviser has an advisory board available for consultation with the Adviser on a variety of topics. Any advisory board recommendations are advisory in nature and non-binding. please register to get more info

Trading
The Adviser has adopted a Code of Ethics that is designed to detect and prevent potential conflicts of interest between the Adviser and its clients. The fundamental position of the Adviser is that, in effecting personal securities transactions, personnel of the Adviser must place at all times the interests of clients ahead of their own pecuniary interests. Certain key elements of the Adviser’s Code of Ethics include the following:
• Officers, directors, and employees are prohibited from trading, either personally or on behalf of others, in securities while in possession of material non-public informa t io n regarding these securities or communicating material non-public information to others.
• Employees are required to place the interest of clients above the interests of the Adviser or other employees whenever a conflict may be present.
• Certain employees are required to submit annual securities holdings reports and quarterly securities transaction reports for their own accounts or any account in which they have a direct or indirect beneficial interest. In addition, such employees are required to report the establishments of new trading accounts on a quarterly basis.
• Reports, however, are not submitted for transactions in money market instruments, direct obligations of the United States government, and shares of U.S. registered open-ended mutual funds.


• Employees are required to certify annually that they have complied with the Adviser’s Code of Ethics.


• Employees may not give or accept gifts or entertainment that are inappropriate or could be seen as overly generous or which could influence employee decision-making.


• Certain employees are required to obtain advance approval to serve as a director or trustee of for-profit organizations and to disclose any service on the board of any organizat io n, including non-profit organizations.


• Certain employees are required to pre-clear any transactions in privately offered securities and initial public offerings.


• Employees that become aware of any violation of the Code of Ethics are required to report such violation to the Chief Compliance Officer.

A copy of the Adviser’s Code of Ethics is available to any existing or prospective investor or Client upon request to the Chief Compliance Officer at (202) 331-3425 or 1133 Connecticut Ave., NW, Washington, DC 20036.

The Adviser may recommend that prospective clients invest in certain Funds managed by the Adviser. Specifically, the Adviser and its officers, managers and employees, as well as affiliated entities, may have a financial interest, as general partner, partner, investor, managing member, or otherwise, in one or more of the Funds being recommended, subject to the restrictio ns of the Code of Ethics. The Adviser may affect transactions, generally for rebalancing purposes or based upon Client specific portfolio guidelines, whereby one account will sell an interest in an underlying Portfolio Fund or Segregated Portfolio and another Client account is purchasing such an interest. Generally, such transactions are structured as separate redemptions and subscriptions for the respective Clients; in certain circumstances, the underlying Portfolio Fund may not agree to that structure and require a transfer; in addition, it may be in the best interests of such Clients to structure these transactions with the Portfolio Fund as a transfer (e.g., to retain the benefit of an underlying Portfolio Fund high-water mark or credit for an existing lock up) if the Portfolio Fund so permits. The Adviser has and may form other investment vehicles that are made available to qualifying RockCreek employees and other individuals to participate in a closed-end private equity, private credit, hybrid, or other investments offered by third-party Portfolio Managers. Generally, no advisory fees are charged to such investors. The employees invested may be individuals responsible for allocating investment opportunities among client accounts and may have an interest in fund allocations. The employee fund could be allocated limited invest me nt opportunities. Such investment decisions are approved by the Adviser’s Investment Committee and reviewed for compliance with the Adviser’s policies regarding fair and equitable allocation of investment opportunities. Generally, where there may be limitations on capacity no more than 10% of an investment opportunity available to the Adviser and its Clients may be allocated to qualifying RockCreek employees and other participants collectively.

The Adviser may from time to time on behalf of a Commingled Fund, Fund of One, or a Separate Account invest (or recommend to a Client that the Adviser advises that it invest) a portion of its assets in another privately offered fund that the Adviser manages. To mitigate potential conflicts, the Adviser would make any such investments if such investments are consistent with applicable investment guidelines, including without limitation, restrictions on investments in affiliates of the Adviser.

As noted above, the Adviser, among other things, maintains internal policies and procedures, including a Code of Ethics, along with controls and a compliance program that aid in the detection and prevention of breaches of any fiduciary duties; address and/or monitor conflicts of interests, insider trading, certain disallowed political activities, violations of the securities laws and regulations, improper allocations of investment opportunities, breaches of confidentiality, and violations of security and privacy policies; and promote the proper valuation and reporting of investment activities and holdings. Further, several of the Funds currently have independent directors. Third-party administrators are also utilized to provide independent valuation and administration services for the Funds and Separate Account. As part of the due diligence process on Portfolio Funds, the Adviser conducts reviews and ongoing monitoring of Portfolio Funds, Portfolio Fund Managers, Trading Advisors, and Sub Advisers. please register to get more info

Brokerage Transactions. With respect to multi- manager portfolios, the Adviser does not direct brokerage transactions or have any soft dollar arrangements. Investments in the Portfolio Funds generally do not involve brokers or dealers. The Adviser does not control or direct which brokers and dealers that the Portfolio Funds, Portfolio Managers, Sub Advisers, and Trading Advisors use. The Adviser generally has authority to determine the broker or dealer that would be used to conduct securities transactions. The Adviser may enter into securities transactions includ ing futures contracts, foreign currency contracts, exchange traded funds, and other securities for certain Clients if specified in their investment guidelines. In such instances, the risks discussed under Item 8 above regarding derivatives, futures, foreign currency trading, and exchange traded funds, among others, would be applicable. As such, the Adviser has adopted policies related to the selection of broker dealers, derivative counterparties, and custodians. Subject to each Client’s investment objectives, policies, and strategies, the Adviser generally has authority to determine, without obtaining specific client consent, the securities to be bought and sold, the amount of the securities to be bought or sold, the broker dealer to be used, and the commission rates paid, if applicable. With respect to investments in securities, futures, derivatives, and other financial products, the Adviser will select brokers or counterparties based on, among other factors, competitive commission rates, expertise, and the capacity and willingness to execute the given transactions. Moreover, when brokerage services are required, the Adviser will seek “best execution” in selecting brokers to execute transactions by evaluating factors such as price, size of order, difficulty of execution (including unique aspects related to emerging markets trading), operational facilities of the brokerage firm, the scope and quality of brokerage services provided, and the brokerage firm’s risk in positioning a block of securities. The Adviser will have no obligation to deal with any broker or group of brokers in executing transactions.

The Adviser’s Broker and Counterparty Review Committee (the “BRC”), comprised of the Adviser’s investment, operations, risk, trading, and legal/compliance team members is responsible for review and approval of brokers or dealers, derivative counterparties, and custodians retained by the Adviser. Appropriate due diligence and a review of the agreements are conducted prior to the approval of such service providers. The BRC meets periodically to oversee and monitor the services provided by the Adviser’s counterparties, including “best execution” review and analysis.

The Adviser does not have “soft dollar” arrangements in place with broker-dealers or third parties in connection with client transactions but may utilize research provided by brokers. The Adviser does not suggest broker-dealers to clients. The Adviser has policies and practices with regard to trade aggregation and allocation where it trades securities directly and is purchasing or selling the same security for more than one portfolio (including circumstances where it is also trading the same security for third-party investment advisers for which it performs administra t ive services) at the same time. The Adviser will endeavor to aggregate and allocate securities in a manner believed by the Adviser to be fair and equitable to each such Client while taking into account circumstances and certain differences including, but not limited to, ERISA or other legal considerations; specific client objectives, guidelines or other directives; and differing liquid it y profiles of the account depending on timing of investments in the portfolio.

Cross and Agency Cross Transactions. Cross transactions involve the purchase or sale of a security between two accounts managed by the Adviser. For example, in some instances a security to be sold by one client account may independently be considered appropriate for purchase by another client account. With respect to Commingled Funds that invest directly in publicly traded equity securities, the Adviser may, but is not required, to cause the security to be “crossed” or transferred directly between the relevant accounts at an independently determined market price and without incurring brokerage commissions, although customary custodian fees and transfer fees may be incurred, no part of which will be received by the Adviser. The Adviser will generally not engage in cross transactions between an ERISA plan account and any other account managed by the Adviser, unless an exception is satisfied. Prices for cross trades will generally be at the average day price or a price set by some other fair and equitable methodology. As the Adviser has no affiliated broker dealer engaged in the trading of securities, the Adviser does not engage in agency cross transactions. In certain cases with respect to Segregated Portfolios and the Adviser’s emerging markets platform, where permitted by applicable law or regulation and when the Adviser believes that doing so will minimize transaction costs, the Adviser may transfer the assets of one Segregated Portfolio to another Segregated Portfolio. In such instances, the underlying assets of such Segregated Portfolios typically do not technically “cross” the exchange, but are reflected either as a change in the beneficial owner of such assets or not as a change in beneficial owner (and in which case would be reflected as a change in the books and records of the emerging markets platform’s custodian). Depending on the applicable market regulation, such transfers may incur customary custodian and transfer fees, and in certain cases, additional brokerage commissions but no part of which will be received by the Adviser. The Adviser will generally follow the same policies regarding ERISA plan accounts as described in the preceding paragraph.

Additionally, in certain cases the Adviser may be subscribing for interests in an Intermediate Vehicle on behalf of one Client and redeeming from the same Intermediate Vehicle for a separate Client. Where the amount of such subscription equals or exceeds the value of the redemption, the Adviser generally will not submit a redemption request to the Intermed iate Vehicle’s underlying Portfolio Fund. In such instances, the liquidity constraints of the underlying Portfolio Fund may not be imposed on the redeeming Client, subject to the discretion of the Intermediate Vehicle’s board of directors. Although these simultaneous subscriptions or redemptions are not considered “cross” trades, the Adviser generally follows the same policies regarding ERISA plan accounts as described above when the Intermediate Vehicle or a participating Client are subject to ERISA. please register to get more info

The Adviser’s Investment Committee oversees the entire investment process, includ ing asset allocation, portfolio construction, and portfolio monitoring and regularly reviews the accounts. In addition to periodic reviews, the Adviser may perform reviews as it deems appropriate or as otherwise required. The Investment Committee, headed by Ms. Beschloss, has the final authority to make investment decisions.

Reviews of portfolios includes a review of the performance, investment objectives, security positions and other investment opportunities, as well as portfolio guidelines and liquid it y requirements, if applicable. Additional reviews may be undertaken at the discretion of the Adviser. Compliance with investment guidelines is generally judged at time of purchase of securities or other investments; however, there may exist certain circumstances when compliance with applicable investment guidelines will be tested post-trade. In addition to periodic reviews, the Adviser may perform reviews of portfolios as it deems appropriate or as otherwise required. Additional reviews may be undertaken for reasons includ ing changes in market conditions or changes in a client’s investment objective or policies. Generally, Clients receive monthly, quarterly, or other periodic reports that may include market updates, investment commentary, and performance reviews. To the extent practicable, the Adviser will provide investors and Separate Account clients with a preliminary estimate on the monthly performance of their investments within 15 business days after the end of each month. Generally, investors and Separate Account clients will receive a final monthly performance statement after the end of the following month. The Adviser and its Clients may also agree that the Adviser will provide certain other reports that may be customized to a Client’s specificatio ns. With regard to portfolios investing in underlying Portfolio Funds, the Adviser will rely on information provided by such underlying funds.

Audited financial statements and tax forms (if applicable) will be completed within a reasonable time after the end of a given fiscal for investors. Annual financial statements for the Funds are audited by an independent certified public accounting firm and distributed within 180 days of such Funds’ fiscal year-end (in the case of Funds that are ‘fund of funds’) and 120 days of such Funds’ fiscal year-end (in the case of direct funds).

The Adviser provides the Separate Account clients with periodic unaudited reports at such times as mutually agreed upon. In addition, since a Separate Account client directly owns the positions in its account, such client may have full, real-time transparency as to transactions and holdings in such account, and may be better able to assess the future prospects of a portfolio that is substantially similar to that of a Fund. The clients in such Separate Accounts may have the right to withdraw all or a portion of their capital from such accounts on shorter notice and/or with more frequency than the terms applicable to an investment in the Funds. please register to get more info

The Adviser does not have any arrangements, oral or in writing, where it is paid cash by or receives some economic benefit (including commissions, equipment, or non-research services) from a non-client in connection with giving advice to clients. The Adviser’s Code of Ethics generally prohibits employees from accepting gifts, favors, and other inducements from counterparties or service providers, except certain common business courtesies. please register to get more info

Under Rule 206(4)-2 under the Advisers Act, the Adviser may be deemed to have custody of funds or securities of Clients even though the Adviser does not have actual physical possession of these assets and they are not registered in the Adviser’s name. Generally, the underlying Portfolio Funds’ cash and securities are held by banks and/or broker-dealers. The Funds to which the Adviser is deemed to have custody, as applicable, are audited in accordance with U.S. generally accepted auditing standards on an annual basis by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. Audited financial statements prepared in accordance with U.S. generally accepted accounting principles are distributed by a third-party administrator to Fund investors within 120 days (or within 180 days as required for a ‘fund of funds’) of the end of each Client’s fiscal year. Certain investors also utilize their own custodians and receive statements on a monthly basis directly from such custodians. The Adviser does not have custody in the case of Separate Accounts of institutional clients. All investors should carefully review financial statements and investors utilizing their
own qualified custodian should carefully review custodian statements they receive directly
and compare them to any account statements or other information provided by the Adviser. please register to get more info

The Adviser generally has discretion to determine the securities and amount thereof to be bought or sold for Funds or Separate Accounts as generally set forth in an investment manageme nt agreement, subscription agreement, or similar documentation. An investor in a Fund of One may have a variety of notice and approval rights requested by such investor. Advisory Clients may be advised on a nondiscretionary basis. The activities engaged in by the Adviser on behalf of the Funds will be subject to the investment objectives, policies, and restrictions of each Fund and the control of the respective Funds’ Boards of Directors; activities engaged in by the Adviser on behalf of a Separate Account will be subject to the investment objectives set forth in the respective investment management agreement or similar provisions contained within governing documents.

Investors in the Funds generally may not place any limits on the Adviser’s authority beyond the limitations set forth in the offering and governing documents of such Funds. On a case-by- case basis, Separate Accounts clients may negotiate certain investment guidelines that the Adviser will adhere to when exercising its authority. please register to get more info

The Adviser has adopted written proxy voting policies and procedures as required by Rule 206(4)-6 under the Advisers Act. Given the nature of the interests held by the Adviser’s portfolios (investing primarily in underlying Portfolio Funds), votes cast by the Adviser generally occur in relation to private securities issued by the Portfolio Funds themselves (such as terms and structure changes governing the Portfolio Funds) and not the underlying public or private securities that may be owned by the Portfolio Fund. In such instances, the Adviser will seek to vote in the best interest of Clients.

Additionally, with respect to certain Funds, the Adviser will seek to vote in the best interest of Clients. The Adviser may engage an independent third-party vendor to assist with the administrative functions of receiving and processing proxy votes. The Adviser is not responsible for voting proxies if it does not receive timely notice from the Client’s custodian. It is the responsibility of the custodian appointed by the Client to ensure that the Adviser receives notice of the relevant vote sufficiently in advance. The major provisions of the Adviser’s proxy voting policies include:
• Consistent with its fiduciary duty, the Adviser is responsible for exercising voting authority on behalf of each Client if/when any Portfolio Fund holds a vote on any issue affecting its investors. Pursuant to the investment management agreements between the Adviser and each Fund and Separate Account client, the Adviser is granted voting authority unless there is a non-discretionary account or an advisory only mandate.
• The Adviser will evaluate each voting issue solely in light of the Client’s best interests, including any written requirements specific to a Fund or Separate Account and vote accordingly. In carrying out this responsibility, the Adviser is obligated to (i) review any written materials provided regarding the issue subject to a vote, and (ii) determine what vote represents each voting Client’s best interests.


• In the event a specific voting issue arises in which the Adviser or one or more Adviser personnel has a material conflict, the Adviser will (a) in the case of a Fund, contact the relevant Fund and each investor in such Fund and follow the voting recommendations of a majority of such investors or in the case of a Separate Account, contact Separate Account client and follow the voting recommendations of such Separate Account client; or (b) require recusal of the conflicted person from the deliberation and decision-making process.

Copies of the Adviser’s proxy voting policy and procedures and information about how the Adviser votes the proxies involved may be requested by submitting a written request to the Adviser. please register to get more info

Information required by this Item 18 is not applicable to the Adviser.
Item 19. Requirements for State-Registered Advisers
Information required by this Item 19 is not applicable to the Adviser. please register to get more info