Rimrock is an investment adviser registered with the SEC. The Firm was organized in 2001 as a limited liability company under the laws of the State of California and is based in Irvine, California. The Firm has five principal employee owners (“Principals”), specifically, David H. Edington, Stephen Foulke, Christopher Chester, Paul C. Westhead, and Scott Dubchansky. Rimrock offers a long-term incentive compensation plan, whereby certain key employees, in addition to the principal employee owners named above, can participate in the long-term growth in value of the Firm. This program offers certain eligible employees the right to benefit from the Firm’s long-term growth and success by sharing in the appreciation in value of the Firm, achieved by delivering investment products and results consistent with the objectives of clients. Rimrock management believes such a program to be in the best interests of clients, consultants, and employees as the plan aligns the interests of all parties by encouraging long-term thinking, stability of personnel, and maintains focus on meeting client objectives. Rimrock provides discretionary investment management services to private funds established by Rimrock (the ”Private Funds”) and private funds or separately managed accounts established by third parties (“Managed Accounts”), as well as the Rimrock Core Bond Fund, an open-end registered investment company (together with the Private Funds, the “Rimrock Funds” or the “Funds”). Rimrock has sole discretion to manage its Funds’ investment portfolios. Generally, Rimrock does not accept instructions from clients with respect to investments by or for their accounts. Rimrock Managed Accounts can impose restrictions in the form of investment guidelines, return benchmarks, and restricted transactions. Rimrock Managed Account holders can also negotiate other terms with Rimrock. Rimrock Managed Account restrictions and Rimrock Core Bond Fund investment guidelines are formalized in executed advisory agreements with Rimrock. The Funds and Managed Accounts will invest predominantly in mixed strategy fixed income securities including (but not limited to), mortgage-backed, asset-backed, corporate, term loans, treasuries and derivatives. Rimrock does not provide general investment advice outside of agreed client investment mandates. Please refer to the applicable Fund’s prospectus or offering documents for detailed disclosure on the types of investments which may be purchased by that Fund. We reserve the right to purchase any other type of investment deemed appropriate based on the Fund’s stated goals and objectives. Rimrock Funds The Private Funds are private pooled investment vehicles formed by Rimrock to provide a means by which qualified and sophisticated investors may pursue alternative investment strategies. The Private Funds are not required to register under the Securities Act of 1933 or the Investment Company Act of 1940 in reliance upon certain exemptions available to issuers whose securities are not publicly offered. For most such strategies, Rimrock typically creates a master-feeder structure consisting of a master fund in the form of a Cayman Islands exempted company, and one or more feeder funds consisting of Cayman Islands exempted companies or trusts and California limited partnerships. Rimrock also manages the Rimrock Core Bond Fund, which is an open-end, registered investment company, organized as a Delaware statutory trust, available to all investors. Our Firm has organized and serves as the General Partner and/or investment adviser to the Funds listed below:
• Rimrock High Income PLUS (Master) Fund, Ltd. –5–
• Rimrock High Income PLUS Fund, L.P.
• Rimrock High Income PLUS (QP) Fund, L.P.
• Rimrock High Income PLUS (Cayman) Fund, Ltd.
• Rimrock High Income PLUS (JPY) Trust
• Rimrock Low Volatility (Master) Fund, Ltd.
• Rimrock Low Volatility Fund, L.P.
• Rimrock Low Volatility (Cayman) Fund, Ltd.
• Rimrock Low Volatility (QP) Fund, L.P.
• Rimrock Low Volatility (QP) (Cayman) Fund, Ltd.
• Rimrock Low Volatility (QP) (JPY) Trust
• Rimrock Structured Product (Master) Fund, Ltd.
• Rimrock Structured Product Fund, L.P.
• Rimrock Structured Product (Cayman) Fund, Ltd.
• Rimrock Structured Product (JPY) Trust
• Rimrock Strategic Income Fund, Ltd.
• Rimrock Total Return Strategies Fund II, Ltd.
• Rimrock Core Bond Fund Rimrock Managed Accounts Managed Accounts are private domestic or foreign accounts or entities, each of which is typically managed by Rimrock for the benefit of one investor or group of investors. Rimrock has been engaged by Copperstone Insurance Services, LLC, the general partner of the Rimrock Series of Copperstone Multi Series IDF, LP (the “Rimrock-Copperstone Series”), to assume responsibility for management, operation and control of the investment and trading activities of that Series. Similarly, Rimrock has been engaged by SALI Fund Management, LLC, the investment manager of Rimrock Relative Value Fixed Income IDF, a series of the SALI Multi-Series Fund V, L.P. (the “Rimrock-SALI Series”) to act as subadviser to the Rimrock-SALI Series. Rimrock acts as an independent contractor to each of the Series and allocates assets across the Rimrock Funds, as well as other funds and securities, in accordance with Section 817(h) of the Internal Revenue Code. Each Series, an insurance dedicated fund, is one where Rimrock serves as the investment adviser or subadviser, allocating to private funds in addition to serving as general partner and/or investment manager of certain of the underlying private funds. Rimrock does not charge a separate fee for its investment management role for the Rimrock Copperstone Series. Rimrock charges separate fees to investors in the Rimrock-SALI Series, but then offsets the investment management and incentive fees of the underlying Rimrock Funds against those of the Rimrock-SALI Series. Rimrock maintains standard fee schedules and liquidity terms for the underlying Rimrock Funds. Rimrock’s service as investment adviser or subadviser allocating each of the Series capital to Rimrock Funds poses a conflict of interest which is disclosed in the Series’ private placement memoranda. In addition to the Funds and Managed Accounts described above, Rimrock’s Principals have created Rimrock Capital Management Holdings, LLC (“RCM Holdings”). The purpose of RCM Holdings is to collectively invest the Principals’ capital in various investment opportunities, including Rimrock Funds and other investments. RCM Holdings is not a parent company or a subsidiary of Rimrock; it is affiliated with Rimrock only through its ownership by Rimrock’s Principals. Our Firm may sponsor or manage additional private investment funds and SEC-registered investment funds in the future. For the Private Funds, we restrict the number of investors and offer interests in those Funds –6– only through non-public transactions in order to maintain the Funds’ exclusion from “investment company” status under the Investment Company Act of 1940, as amended. As of December 31, 2019, Rimrock Capital Management, LLC had Regulatory Assets Under Management of $7,414,524,674 in client assets on a discretionary basis, and Net Assets Under Management of $4,114,675,688. Regulatory Assets Under Management includes all gross assets without any deduction for debt or leverage; net assets under management are calculated by subtracting outstanding liabilities from client assets. please register to get more info

Rimrock generally is compensated for its advisory services based on a percentage of assets under management (“management fee” or “advisory fee”). Additionally, Rimrock Funds (other than the Rimrock Core Bond Fund) and Managed Accounts generally pay performance-based fees (“performance fees” or “incentive fees”). Investors and prospective investors in a specific Fund should refer to the prospectus or private placement memorandum for that Fund for detailed information on the management and performance fees associated with investing in the Fund. Rimrock Total Return Strategy Funds, such as Rimrock Total Return Strategy Fund II, Ltd., do not charge a management fee, only performance fees. The incentive fees for the Private Funds are subject to a hurdle rate and payable only at times of redemption. Managed Account management and incentive fees are described in individually executed investment management agreements. At the end of each calendar year, for most Funds, Rimrock will receive an annual incentive fee up to 20% of the net profit allocated to each Fund investor’s capital account (including net realized and unrealized gains and losses of net income). These Funds will maintain a loss recovery account for each investor (“Loss Recovery Account”). Each Loss Recovery Account will be debited with any net capital depreciation (taking into account an investor’s share of the management fee, where applicable) allocated to the capital account. Rimrock will not receive any incentive fee regarding a capital account until the investor has recovered all amounts debited to its Loss Recovery Account (as adjusted for withdrawals or additions of capital). Performance fees will meet all requirements for such fees as specified under Rule 205-3 of the Investment Advisers Act. Similarly, Rimrock will maintain a contingent loss account for Managed Account clients with a performance fee (a “Contingent Loss Account”). The Contingent Loss Account will be debited with any net loss incurred in such Managed Account. Rimrock will not receive any performance fees with respect to a client’s account until the client has recovered all amounts debited to the client’s Contingent Loss Account (as adjusted for any withdrawals or additions of capital). This Contingent Loss Account effectively imposes a “high water mark” on the client’s account so that Rimrock is not paid a performance fee for recovering past losses experienced by the client. Rimrock Funds With regard to most Private Funds, Rimrock receives an annual management fee of up to 1.25% of the net asset value of committed capital. Certain Private Funds have two or more classes of units or shares. As described in more detail in the private placement memoranda for those Funds, investors in those multi-class Funds can choose a class with lower management fees and performance fees in return for more restrictive redemption provisions. The management fee is paid monthly in advance. At Rimrock’s discretion, Rimrock may waive all or a portion of the management fee or may agree to other changes to the –7– management fee on an individual investor basis. Rimrock currently does not charge management fees to Rimrock employees who are investors in Rimrock Funds, other than the Rimrock Core Bond Fund. Rimrock Managed Accounts Generally, advisory fees for Rimrock Managed Accounts are based upon a percentage of assets under management and vary depending upon the nature of the portfolio to be managed. Managed Account advisory fees range from 0.25% to 1.25% of client assets under management. With regard to Rimrock Managed Accounts, Rimrock calculates management fees on a monthly basis and invoices the Managed Account clients on a quarterly basis, mainly in arrears. The Managed Account client must instruct and approve the payment from the custodial bank to pay Rimrock directly. Rimrock does not deduct fees directly from Rimrock Managed Accounts. Rimrock Core Bond Fund The fees and expenses of the Rimrock Core Bond Fund are described in the Fund’s prospectus, and include a management fee of 0.30%. The Rimrock Core Bond Fund has also adopted a distribution plan pursuant to Rule 12b-1 of the Investment Company Act of 1940. The plan authorizes that Fund to pay annual fees of up to 0.25% of the Fund’s average daily net assets attributable to its shares in consideration for distribution and shareholder services and the assumption of related expenses. General Information Fee Comparison The Private Funds’ expenses, including our Firm’s performance fees and management fees, constitute a higher percentage of average net assets than would be found in certain other investment vehicles providing similar services. In addition, since our performance fee, determined on an annual basis, is generally calculated on a basis which includes unrealized appreciation of the Private Fund’s assets, it is greater than if such allocation were based solely on realized gains. Different Fee Schedules Rimrock’s management fee and the performance fee in a Private Fund may be discounted or waived with respect to any investor for any particular period of time at the sole discretion of the Firm (or the General Partner, as applicable). This discounted rate or waiver is not available to all or even most investors in the Private Funds. Other Fees and Expenses Money market mutual funds generally are used to “sweep” unused cash balances until the cash can be appropriately invested. Investors should recognize that all fees paid to Rimrock for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders. These fees will generally include a management fee and other Fund expenses. In addition to fees paid to our Firm (or the Fund’s General Partner, as appropriate), investors will also be responsible for the fees and expenses charged by custodians, spreads and expenses charged by brokerage- dealers or other counterparties with whom Rimrock effects transactions, and other transaction-related expenses including, without limitation, outside counsel fees, court costs, costs of due diligence, escrow fees –8– and closing costs, and broken deal expenses, Fund administration fees, auditing, accounting and tax preparation fees, insurance, interest on borrowings, governmental fees and taxes, ongoing legal expenses and bookkeeping. Please refer to Item 12 of this brochure for additional information regarding brokerage. Except for the investors in Rimrock Total Return Strategy Fund II and Rimrock Strategic Income Fund, Ltd., investors in Private Funds invest through a feeder fund. Feeder funds are responsible for all direct, and their pro rata share of the related master fund’s, operating and other expenses. These fees and expenses include, but are not limited to, (i) routine legal, bookkeeping, administration, registrar, transfer agency, accounting, auditing and tax preparation fees, and other related fees and expenses, (ii) all operational and overhead expenses of the feeder and master fund, including, but not limited to, a proportional share of fees payable to third parties to provide software, data and other information used for the Funds’ recordkeeping and reporting (including, but not limited to, fees paid for the use of CUSIP identifiers and ratings information and the provision of information necessary to complete and file Form PF), photocopying, postage and telephone expenses, as well as director fees and travel expenses, the expenses of governmental registrations, licensing and filing fees, and (iii) extraordinary expenses. Rimrock may, in its sole discretion, pay or reimburse a Fund for any or all such expenses. Rimrock maintains written policies and procedures concerning the allocation of expenses among clients. Expenses that benefit more than one client and are tied to a particular client investment are allocated among those clients that hold the investment, in accordance with the percentage of the investment held by those Funds at the time the invoice is received. Expenses that benefit more than one client that are not tied to a particular investment are allocated on a pro rata basis among all those clients, based on the net asset values of the clients at the time the invoice is received. Valuations Rimrock has a responsibility to ensure that client portfolios and investments reflect fair and accurate valuations. In general, most of the securities in the Funds and Managed Accounts have readily available market quotations. However, it is not uncommon for securities or investments to be assigned a “fair market value” as determined in good faith by Rimrock. Valuations of client holdings are in accordance with the Statement of Financial Accounting Standards Topic 820 (“FSAB ASC Topic 820” or the “Standard”) and are categorized within the Fair Value Hierarchy as stated in the Standard. FASB ASC TOPIC 820 - LEVEL l - Level 1 instruments are liquid and traded in active markets with sufficient frequency and volume to provide pricing information on an ongoing basis. Level 1 instruments include exchange-traded securities, listed derivatives, futures contracts and over- the-counter securities traded in an active market. Such instruments have observable market inputs to arrive at fair value and such inputs are reliable and verifiable. FASB ASC TOPIC 820 – LEVEL 2 and LEVEL 3 - Level 2 includes assets and liabilities valued using observable inputs other than quoted prices used to value Level 1 securities, while Level 3 consists of the most “unobservable” inputs (e.g., highly illiquid securities). In accordance with FASB ASC 820, Rimrock seeks to maximize the use of observable inputs and minimize the use of unobservable inputs to extent possible when determining the fair value of a security or other financial instrument. –9– Rimrock seeks to ensure that appropriate valuation procedures are followed to price securities in client accounts managed by Rimrock. Rimrock strives for consistent pricing sources that accurately reflect current market activity prices. The Chief Financial Officer has overall responsibility for implementing Rimrock’s valuation policies and procedures. If it is determined that a price obtained from a custodian, pricing service or other source is not reflective of current market conditions, each of the Chief Financial Officer and Chief Risk Officer have the authority to change the pricing source. In addition, Rimrock’s Evaluation and Pricing Committee is charged with ensuring the integrity of the securities pricing process for the Private Funds and Managed Accounts and for periodic reviews of Rimrock’s valuation policies and procedures. The Evaluation and Pricing Committee is comprised of a number of senior employees, including but not limited to the Chief Executive Officer, Chief Risk Officer, Chief Financial Officer, and two senior Portfolio Managers. A majority of Committee members are not engaged in portfolio management. Rimrock’s Chief Compliance Officer is a non-voting member of the Committee. The Committee meets monthly to review any pricing source changes, changes or additions to ASC 820 (FAS 157) Level 3 positions and fair values, as well as other valuation related matters. Rimrock Funds Trust Trustees are responsible for overseeing the pricing of securities in the Rimrock Core Bond Fund. The Trustees have established a Fair Value Pricing Committee (the “FMV Committee”) whose function is to approve in advance, where necessary, or ratify promptly otherwise, any fair valuation decision of or relating to a security held by the Funds, and that would result in a change in the net asset value of the Funds of more than $0.01 per share. Rimrock will comply with the Trust’s Valuation and Pricing Policies and will provide reports to the FMV Committee and the Trustees as required in those Policies and as otherwise reasonably requested by the FMV Committee. The Trustees will approve any material changes to the policies and procedures used in connection with the pricing and the valuation of the securities held by the Core Bond Fund. The FMV Committee is composed of two Trustees (at least one independent), and the Fund’s Treasurer, Chief Compliance Officer and other Rimrock representatives as necessary for market color and input. Rimrock uses independent pricing sources to value client investments whenever these prices are deemed accurate. If market quotations are not available from independent third parties (including broker-dealers), then securities and other financial assets are valued at “fair value,” in accordance with FASB guidance. Fair value is determined using Rimrock’s best efforts to estimate the value based on comparable securities or valuation models using sources and inputs Rimrock deems reliable such as Bloomberg, broker-dealer quotes, third party pricing services, and others depending on the particular security. This is determined in good faith by Rimrock. Third party pricing services generally provide values to Rimrock following review and analysis of available documentation and information, including but not limited to information provided by Rimrock. Depending on the extent of reliance by third party services on that information, those valuations may not be considered “independent.” Fair valuation is the last option. Rimrock has adopted the following set of valuation procedures to determine the prices to be used for securities held in client accounts. Client account custodians serve as the primary provider of security prices. For Rimrock sponsored funds, Northern Trust serves as custodian. For all other Rimrock client accounts, the client selects the custodian. In addition to custodian-provided pricing, Rimrock attempts to obtain prices from alternative sources. These include third party pricing sources and broker-dealers known to be active in certain segments of the fixed income markets. All prices are determined daily for the Rimrock Core Bond Fund; for other Funds prices are determined at least monthly, custodian and select broker prices are reviewed daily. If Rimrock determines that a value obtained from a custodian, pricing service or other service is not reflective of current market values, it may change the value, using its best efforts to estimate the value. In some instances, a portfolio security will be valued higher than the price at which it was recently purchased if higher value is supported by the Fund’s valuation procedures and where the Adviser –10– reasonably believes that the security could be sold for a higher price. For example, when the Rimrock Core Bond Fund purchases securities in an order size smaller than a normal trading unit it may receive a discounted price, but if the Adviser would be able to aggregate those securities from the Fund’s portfolio with those or similar securities held in other client accounts, the security could be sold at its market price. Clients, prospective clients, investors, and prospective investors in any of the Funds may review a copy of our current and complete valuation procedures at our offices by contacting us at the telephone number on the cover page of this brochure. Termination A Fund investor may withdraw all or any part of its investment from a Fund as set forth in the applicable Fund’s prospectus or offering documents. For the Private Funds, Rimrock may, in its sole discretion, waive or modify any of the terms of withdrawal. Rimrock seeks to treat all clients and investors in a fair and equitable manner. The decision to waive or modify any terms, permitted by offering documents, will be based on the facts and circumstances of the request and with consideration of the impact on other clients and investors. Investors in each Fund should refer to the appropriate Fund’s organizational and prospectus or offering documents for complete information regarding withdrawals of investments. Rimrock Core Bond Fund provides for daily redemptions. Rimrock’s Funds’ other than the Rimrock Core Bond Fund have different share classes offering distinct termination provisions. Generally, Private Fund investors provide forty-five (45) days notification for a quarterly redemption after a one (1) year soft lock-up period or one hundred twenty (120) days notification for annual quarterly redemption after a two (2) year soft lock-up period. However, Rimrock Structured Product Fund requires only ninety (90) days notification for annual quarterly redemption after the two (2) year soft lock-up period. In addition, Rimrock Total Return Strategies Fund II permits redemptions with fifteen (15) days’ prior written notice. For most Rimrock Funds, early redemptions, prior to the expiration of the lock-up, may be permitted by Rimrock subject to a 3% redemption fee (an “Early Redemption Fee”). The Board of Directors of a Private Fund and Rimrock may, in their discretion, permit redemptions at other times and upon other payment terms as they decide, and may waive any applicable lock-up and notice periods. As an example, Rimrock may require or permit a partial or full redemption of an investor’s shares, without an early redemption fee, to comply with, or avoid violations of applicable law, rules or regulations; after the death of an individual investor; and where Rimrock has determined in good faith that a redemption will not be detrimental to a Fund or the interests of redeeming or remaining investors. For any partial period, investors will be charged prorated fees in arrears. For most Private Funds, Rimrock may limit the amount of Fund redemptions on a quarterly basis to 25% of the related Master Fund’s net asset amount. If the 25% quarterly limit is reached, the redeeming investors will receive a pro rata portion of their requested amount. Managed Account clients may terminate the relationship with us with prior written notice (generally 30 days) in accordance with the terms of their investment management agreement. Side Arrangements Rimrock has and may in the future, as appropriate, waive or modify certain terms of investment for certain investors, in side letters or otherwise, in its sole discretion. Rimrock Private Funds have no side pocketed assets. –11– General Investors in the Funds and prospective investors in any new fund launched by Rimrock or its affiliates should refer to the appropriate prospectus or offering and organizational documents for additional important information, terms, conditions and risks involved with investing in the Fund(s). Personal Investments in Funds Certain executive officers and/or other employees of Rimrock, and their family members, have invested or may invest a portion of their personal net worth in one or more of the Funds. Rimrock, as a firm, arose from the personal investment of its founding principal. Rimrock principals, officers and employees are encouraged to invest in Rimrock Funds and, except in the Rimrock Core Bond Fund, currently are not charged any Fund management or performance fees. In so doing, Rimrock believes that an alignment of interest exists between Rimrock and Fund investors. This situation may give rise to circumstances where principals redeem, partially, or in full from a given fund, in order to pay taxes or rebalance their personal investments. As discussed above, the discretion to waive or modify any of the terms of withdrawal granted by a Fund’s offering documents will be based on the facts and circumstances of the request and with consideration of the impact on other clients and investors. Rimrock officers and employees, and their family members, may concentrate their investment in one or more of the Funds, creating an incentive to favor those Funds over other Funds in the allocation of investment opportunities. Rimrock seeks to address this potential conflict of interest by implementing policies and procedures for fair and consistent allocation of investment opportunities among all client accounts over time. please register to get more info

It is important for investors to note that performance fees in the Private Funds and Managed Accounts create potential conflicts of interest, which Rimrock has identified and described in the following paragraphs. Performance fees create an incentive for Rimrock to make investments that are riskier or more speculative than would be the case absent a performance fee arrangement. In order to address this potential conflict of interest, Rimrock periodically reviews client accounts to ensure that investments are suitable and that the account is being managed according to the client’s investment objectives and risk tolerance. Performance fees also create an incentive for our Firm to overvalue investments which lack a market quotation. In order to address such conflict, we have adopted policies and procedures that require our Firm to “fairly value” any investments which do not have a readily ascertainable value. Furthermore, since we also have clients that pay different management and/or performance fees, we have an inherent incentive to favor the Funds or other accounts that pay higher management and performance fees. We will receive more compensation from clients with higher management fees, and compensation we receive from clients with greater performance fees is more meaningfully tied to the performance of their accounts. For example, investors in the Rimrock Core Bond Fund will pay less in management fees than those in Rimrock Private Funds and will not pay incentive fees, creating an incentive for Rimrock to favor the Private Funds in allocating investment opportunities. However, as a fiduciary, we endeavor at all times to put the interests of our clients first. To this end, we take the following steps to address these conflicts of interest: –12–
• We disclose to clients the existence of material conflicts of interest, including the potential for our Firm to earn more compensation from advisory clients who pay higher management and performance fees;
• We have implemented policies and procedures for fair and consistent allocation of investment opportunities among all client accounts over time;
• We allow clients to establish specific investment guidelines and restrictions that decrease the potential overlap of investment opportunities among clients;
• We periodically compare holdings and performance of accounts with similar strategies to identify significant performance disparities indicative of possible favorable treatment;
• We periodically review trading frequency and portfolio turnover rates to identify possible patterns of “window dressing,” “portfolio churning,” or any purposeful or unconscious attempts to manipulate trading to boost performance near the reporting period; and
• We educate our employees regarding the responsibilities of a fiduciary, including the need for equitable treatment of all clients, regardless of the fee arrangement. Performance fees will only be charged in accordance with the provisions of Rule 205-3 of the Investment Advisers Act of 1940.
Private Fund investors must understand the performance fee method of compensation and its risks
prior to subscribing to interests in any of the Funds. please register to get more info

Rimrock serves as the General Partner and investment adviser to various private investment funds and Managed Accounts that are available to pension and profit sharing plans, endowments, foundations, trusts, estates, charitable organizations, corporations, certain individuals, and other business entities. Rimrock also acts as investment adviser to the Rimrock Funds Trust, which consists of one series, the Rimrock Core Bond Fund. The Rimrock Core Bond Fund is open to all types of investors. Generally, each investor in one or more of our Private Funds, and each Managed Account client must be an “accredited investor,” as defined in the Securities Act of 1933, as amended, and be eligible to enter into a performance fee arrangement. In addition, each investor is required to make representations concerning its sophistication as an investor and its ability to bear the risk of loss for its entire investment. To invest in the Funds, an investor must also be a “qualified purchaser” or “qualified client” as defined in the Investment Advisers Act of 1940, as amended. Finally, a Fund investor must be a “qualified eligible person” as defined in the Commodity Exchange Act, as amended. Rimrock may, in its discretion, waive all or part of any admission standard or requirement. Our minimum subscription for Private Fund investors is $1,000,000. However, Rimrock may waive the minimum subscription requirement at our discretion on a case-by-case basis. Conditions for Investment Rimrock generally requires a minimum investment of $1,000,000 for our private investment funds. Investors may be subject to disqualification provisions for investment in the Private Funds under Rule 506(d)(1) of the Securities Act of 1933. You must also be an accredited investor (under Regulation D) and qualified to participate in a performance fee arrangement (under the California Corporate Securities Law of 1968 and/or the Investment Advisers Act or 1940, as amended) by having a net worth of more than $2,100,000 or invest at least $1,000,000 in the private investment fund. For Private Funds open only to “qualified purchasers,” you must have investments of at least $5,000,000 ($25,000,000 for most entities) at the time of investment. –13– please register to get more info

For each Fund, Rimrock pursues an investment strategy described in the applicable Fund’s prospectus or private placement memoranda, as summarized for each respective strategy below. Managed Accounts may have a substantially similar mandate as the strategies described below or alternatively a sub-sector of one of the strategies; for example, a strategy limited to investments in the mortgage sector. In each case, the following summaries are not intended to be complete statements of the investment strategies and related risks of the applicable Rimrock Funds or Managed Accounts. Investors should review the full prospectus or private placement memorandum and other governing documents for a given Fund for a complete statement of the strategy and risks relating to such Fund. The terms of a Rimrock Fund’s prospectus or private placement memorandum and other governing documents supersede the disclosures contained in this Brochure. A. Method of Analysis Rimrock’s investment process is built around an extensive fundamental, bottom-up analytical process. However, we do incorporate our view of the business cycle and credit cycle. Top-Down Rimrock performs an annual review where we attempt to identify the trends that may impact the global economy over a longer-term horizon. On a quarterly basis, we review and generate an outlook for the global economic cycle over the next 12 months, seeking to identify relative strengths and weaknesses within the major global economies. The quarterly review also involves relative value analysis across all asset classes, in an effort to identify anomalous pricing, both quantitatively and qualitatively. Rimrock also performs a fixed income sector analysis in order to identify sub-sector pricing and performance trends that may impact our security selection process. Bottom-Up Rimrock seeks to purchase securities with an eye towards holding until maturity, pay down, or call. Rimrock does so by employing multiple models and stress tests to model risk, as well as gain a thorough understanding of any structural components. We look to identify undervalued securities that hold up to a wide range of economic outcomes, using conservative default and recovery assumptions. Our efforts combine technology and experience to identify bonds with preferred attributes from various bid lists and dealer inventories. Risks Rimrock’s investment approach has risks. Each investment portfolio will be subject to market volatility. Each portfolio will follow an investment strategy that, if unsuccessful, could involve significant losses for investors. In addition, Rimrock’s investment approach is generally based on information and data derived from firsthand research and, for public companies, filed by the issuers of such securities with the SEC. Rimrock is not in many cases in a position to confirm the completeness or accuracy of such information and data, and such information and data may not, in fact, be complete or accurate. See Item 8.C. below for more information on risks. B. Investment Strategies Investment Strategy: Rimrock High Income PLUS (Master) Fund, Ltd. Rimrock High Income PLUS Fund, L.P. Rimrock High Income PLUS (QP) Fund, L.P. Rimrock High Income PLUS (Cayman) Fund, Ltd. –14– Rimrock High Income PLUS (JPY) Trust The Rimrock High Income PLUS Fund (the “HIP Fund”) is a multi-sector fixed-income relative value fund. The HIP Fund’s strategy is to exploit structural and technical inefficiencies in the market, especially in the short end of the yield curve, and to enhance returns through the use of hedging, modest leverage and select longer-term total return investments. The HIP Fund’s focus on the short-end of the yield curve is the result of the portfolio management team’s extensive experience and research surrounding the efficacy of that part of the market. Empirical data going back to the 1950s demonstrates the superior risk-adjusted return characteristics found in the short end of the curve, where an investor buying securities with an average life between one (1) and three (3) years has been able to capture a higher rate of return for a less than commensurate increase in risk. Interestingly, the data includes extended periods of rising rates and even some inverted yield curves. While the historical data is compelling, it is important to understand the forces responsible for this relationship and to determine its sustainability in the future. First, the demand for money market instruments (those having a maturity of 13 months or less) continues to grow, as there are certain investors who are willing to pay a premium for the surety of price stability. The combination of the strong demand for money market instruments and the cost associated with not “breaking the buck” serve to reduce the offered return to investors. For those securities just beyond the 13- month mark, there is an exceptional increase in the potential risk-adjusted return for investors who are willing to move just beyond the “safety” of money markets. After the money markets sector, another relatively efficient part of the fixed-income market includes those bonds that comprise the Barclays Capital Aggregate Bond Index or other similar intermediate duration benchmarks that are popular with large pension funds, endowments and foundations for their long-only fixed-income allocations. The number of sophisticated investment managers investing in this part of the yield curve serves to increase the efficiency of the market, and as a result, reduces the opportunity to purchase instruments with outstanding risk-adjusted return characteristics. Bonds that start their life in the Barclays Capital Aggregate Bond Index will ultimately exit the index as they “roll down” the yield curve on their march towards maturity and will have to pass through the less trafficked short end of the yield curve. While the shape of the yield curve will likely change, and the advantage found in the short end may wax and wane over time, the expectation is that the general relationship will hold going forward. In addition to being able to take advantage of structural and technical inefficiencies in the market, the HIP Fund’s focus on the short end of the yield curve has the benefit of limiting the HIP Fund’s interest rate risk. As part of the investment process, the HIP Fund does not try to predict the direction or rate of change in interest rates, but concentrates its efforts on identifying undervalued bonds. Therefore, the overall duration of the portfolio is limited to between (-1) and +3 years, with the mid-point at +1 year, which ensures a muted impact on performance regardless of a change in rates. Lastly, as an investor in short average life bonds, the HIP Fund can be more reliant on maturity and return of principal as an exit strategy rather than having to sell a bond in order to capture a profit. Overall, the HIP Fund seeks to maintain a low risk profile by adhering to a disciplined relative value approach and achieving a diversified portfolio. The HIP Fund has three (3) strategic components: an Income Portfolio, which seeks to generate an attractive yield; select Total Return Strategies that serve to complement the Income Portfolio; and Hedging, which attempts to moderate specific risks in the HIP Fund. –15– Income Portfolio The Income Portfolio is a diversified portfolio that utilizes a broad investment charter and modest leverage to generate an attractive yield, which is designed to represent the majority of the HIP Fund’s returns over time. Unlike some sector-specific fixed-income funds, the HIP Fund has the ability to seek value in all sectors of the fixed-income universe, including mortgages, asset-backed securities (“ABS”), corporates (both investment grade and below investment grade), and emerging markets. The HIP Fund is also able to employ all security types and structures in the construction of the Income Portfolio. The notional leverage in the Income Portfolio is limited to a maximum of three times (3x) equity (i.e., two dollars ($2) of borrow against one dollar ($1) of equity), while the HIP Fund’s normal range has been approximately 1.2 to 1.4 times equity (i.e., 20 to 40 cents of borrow for every dollar of equity). Total Return Strategies In addition to the yield generated by the Income Portfolio, the portfolio management team is confident in their ability to identify a select number of opportunities that serve to enhance performance. Typically, these Total Return Strategies will complement, or hedge, the Income Portfolio and may include strategies ranging from relative value to fixed income arbitrage to more macro-oriented positions. Importantly, the exposure of each individual Total Return position is typically limited to an amount representing 2-3% loss for the HIP Fund, with a maximum of 5%. Therefore, if the HIP Fund is wrong on each of the Total Return positions, it should not completely offset the potential returns generated in the Income Portfolio. Hedging The HIP Fund uses a variety of hedging techniques to reduce certain risks inherent in a fixed income portfolio, such as duration (a measure of a bond’s interest rate sensitivity), convexity (a measure of sensitivity of a bond’s duration to a change in interest rates), volatility (a measure of variation in price), and spread widening (a measure of price impact due to changes in credit spreads). The HIP Fund’s approach to hedging emphasizes identifying cost effective strategies. More importantly, however, the HIP Fund attempts to utilize liquid instruments to give it the option to monetize the hedging strategies should the environment warrant it. Investment Strategy: Rimrock Low Volatility (Master) Fund, Ltd. Rimrock Low Volatility Fund, L.P. Rimrock Low Volatility (QP) Fund, L.P. Rimrock Low Volatility (Cayman) Fund, Ltd. Rimrock Low Volatility (QP) (Cayman) Fund, Ltd. Rimrock Low Volatility (QP) (JPY) Trust The Rimrock Low Volatility Funds (the “Low Vol. Fund”) is a multi-strategy fixed income fund. The Low Vol. Fund seeks to generate returns through the exploitation of structural and technical inefficiencies in the market, especially in the short-end of the yield curve, and through careful security selection, modest leverage, and active hedging. Please refer to the paragraphs above describing our investment approach for the HIP Fund. The Low Vol. Fund employs the same investment approach, except for the Total Return Strategies, which are excluded. Overall, the Low Vol. Fund seeks to maintain a low risk profile by adhering to a disciplined relative value approach and achieving a diversified portfolio. The Low Vol. Fund has two (2) strategic components: an Income Portfolio, which seeks to generate an attractive yield, and Hedging, which attempts to moderate specific risks in the Low Vol. Fund. –16– Income Portfolio The Income Portfolio is a diversified portfolio that utilizes a broad investment charter and modest leverage to generate an attractive yield, which is designed to represent the majority of the Low Vol. Fund’s returns over time. Unlike some sector-specific fixed-income funds, the Low Vol. Fund has the ability to seek value in all sectors of the fixed-income universe, including mortgages, ABS, corporates (both investment grade and below investment grade), and emerging markets. The Low Vol. Fund is also able to employ all security types and structures in the construction of the Income Portfolio. The notional leverage in the Income Portfolio is limited to a maximum of three times (3x) equity (i.e., two dollars ($2) of borrow against one dollar ($1) of equity), while the Low Vol. Fund’s normal range has been approximately 1.2 to 1.4 times equity (i.e., 20 to 40 cents of borrow for every dollar of equity). Hedging The Low Vol. Fund uses a variety of hedging techniques to reduce certain risks inherent in a fixed-income portfolio, such as duration (a measure of a bond’s interest rate sensitivity), convexity (a measure of sensitivity of a bond’s duration to a change in interest rates), volatility (a measure of variation in price), and spread widening (a measure of price impact due to changes in credit spreads). The Low Vol. Fund’s approach to hedging emphasizes identifying cost effective strategies. More importantly, however, the Low Vol. Fund attempts to utilize liquid instruments to give it the option to monetize the hedging strategies should the environment warrant it. Investment Strategy: Rimrock Structured Product (Master) Fund, Ltd. Rimrock Structured Product Fund, L.P. Rimrock Structured Product (Cayman) Fund, Ltd. Rimrock Structured Product (JPY) Trust The Rimrock Structured Product Fund (the “SPF Fund”) is a fixed income relative value fund. The SPF Fund’s strategy is to exploit structural and technical inefficiencies in the market, especially in the mortgage- backed securities (“MBS”), ABS, commercial mortgage-backed securities (“CMBS”) and other structured product sectors of the fixed income market. Rimrock will focus the exposure of the SPF Fund in structured product securities that have a relatively short average life, between one (1) and three (3) years, and which also demonstrate attractive risk and reward characteristics. In addition, Rimrock will have the ability to use modest leverage and hedging strategies in an effort to generate attractive rates of return with commensurate performance volatility. Rimrock believes that the structured product sector of the fixed-income market, including MBS, ABS and CMBS, is relatively inefficient and that it can apply its long experience in the structured product sector in order to identify securities that offer attractive risk-adjusted returns. Rimrock believes the SPF Fund can also benefit from the its ability to transact in securities that have a below investment-grade rating, or in some cases no rating, from one or more of the nationally recognized statistical rating organizations (“NRSRO”), as most investors in this sector of the market are benchmarked to indices that do not include un-rated or below investment-grade rated securities, such as the Barclays Capital Aggregate Bond Index, and would be less willing to utilize such securities in an effort to limit their deviation, or tracking error, relative to the benchmark. In addition, many institutional investors incorporate a limit on the amount of un-rated or below investment-grade securities in their fixed-income portfolio, which limits the number of participants in this space and can create an advantageous supply and demand dynamic for the SPF Fund. Next, due to the large number of complex variables that are incorporated into Rimrock’s evaluation of structured product securities, including a detailed analysis of both the underlying collateral and the legal –17– structure of the security, Rimrock believes its long experience will be beneficial to the SPF Fund in its ability to identify undervalued or mispriced securities. The SPF Fund will also have the ability to utilize modest financial leverage, primarily through the use of term and rolling repurchase financing agreements, but will mitigate the funding risk through the use of multiple counterparties, the maintenance of a cash reserve, a reserve of alternative securities that can be financed, and the maintenance of a minimum level of liquidity in the underlying portfolio. The SPF Fund uses a variety of hedging techniques to reduce certain risks inherent in a fixed-income portfolio, such as duration (a measure of a bond’s interest rate sensitivity), convexity (a measure of sensitivity of a bond’s duration to a change in interest rates), volatility (a measure of variation in price), and spread widening (a measure of price impact due to changes in credit spreads). The SPF Fund’s approach to hedging emphasizes identifying cost effective strategies. More importantly, however, the SPF Fund attempts to utilize liquid instruments to give it the option to monetize the hedging strategies should the environment warrant it. Finally, the SPF Fund has the ability to enter into select Total Return Strategies that are designed to exploit specific mispricing or relative value relationships in the structured product sector of the market, or the basis between certain securities within the sector. While Rimrock expects these Total Return Strategies to be more capital appreciation-oriented focused, Rimrock also believes these strategies can be additive to the overall performance of the SPF Fund and may serve to reduce its performance volatility over time. Investment Strategy: Rimrock Strategic Income Fund, Ltd. The Rimrock Strategic Income Fund (the “SIF Fund”) is a fund structure that was created for a single client (aka a “fund of one”) with specific legal needs requiring a Cayman-based vehicle. The underlying portfolio for Class A Shares (the “Fixed Income Relative Value Strategy”) is benchmarked to a longer-duration index, and the client is utilizing the SIF Fund as a limited duration source of enhancing performance relative to the benchmark. The SIF Fund is not open to any other investors outside of the one client. Shares of the SIF Fund invest in a multi-sector fixed-income relative value portfolio. Its strategy is to exploit structural and technical inefficiencies in the market, especially in the short end of the yield curve, and to enhance returns through the use of hedging, modest leverage and select longer-term total return investments. In addition, this portfolio seeks to maintain sufficient liquidity to satisfy monthly redemption requests, including through the use of more liquid securities. In addition to being able to take advantage of structural and technical inefficiencies in the market, the Fixed Income Relative Value Strategy’s focus on the short end of the yield curve has the benefit of limiting the portfolio’s interest rate risk. As part of the investment process, the Fixed Income Relative Value Strategy does not try to predict the direction or rate of change in interest rates, but concentrates its efforts on identifying undervalued bonds. Therefore, the overall duration of the portfolio is limited between (-1) and +3 years, with the mid-point at +1 year, which ensures a muted impact on performance regardless of a change in rates. Lastly, as an investor in short-average life bonds, the Fixed Income Relative Value Strategy can be more reliant on maturity and return of principal as an exit strategy rather than having to sell a bond in order to capture a profit. Overall, the Fixed Income Relative Value Strategy seeks to maintain a low-risk profile by adhering to a disciplined relative value approach and achieving a diversified portfolio. The Fixed Income Relative Value Strategy has two (2) strategic components: an Income Portfolio, which seeks to generate an attractive yield, and Hedging, which attempts to moderate specific risks in the Fund. –18– Income Portfolio The Income Portfolio is a diversified portfolio that utilizes a broad investment charter and modest leverage to generate an attractive yield which is designed to represent the majority of the Fund’s returns over time. Unlike some sector-specific fixed-income funds, the Fund has the ability to seek value in all sectors of the fixed-income universe, including mortgages, ABS, corporates (both investment grade and below investment grade), and emerging markets. The Fixed Income Relative Value Strategy is also able to employ all security types and structures in the construction of the Income Portfolio. The notional leverage in the Income Portfolio is limited to a maximum of two times (2x) equity (i.e., one dollar ($1) of borrow against one dollar ($1) of equity), while the Fixed Income Relative Value Strategy’s normal range has been approximately 1.2 to 1.4 times equity (i.e., 20 to 40 cents of borrow for every dollar of equity). Hedging The Fixed Income Relative Value Strategy uses a variety of hedging techniques to reduce certain risks inherent in a fixed income portfolio, such as duration (a measure of a bond’s interest rate sensitivity), convexity (a measure of sensitivity of a bond’s duration to a change in interest rates), volatility (a measure of variation in price), and spread widening (a measure of price impact due to changes in credit spreads). The Fixed Income Relative Value Strategy’s approach to hedging emphasizes identifying cost effective strategies. More importantly, however, the SIF Fund attempts to utilize liquid instruments to give it the option to monetize the hedging strategies should the environment warrant it. Investment Strategy: Rimrock Total Return Strategies Fund II, Ltd. Rimrock Total Return Strategies Fund II, Ltd. invests in a trade that is designed to benefit if interest rate volatility increases. Specifically, the investment strategy combines the purchase of options on the USD Swap Rate with the purchase or sale of United States Treasury securities, futures, or swaps. The Fund will seek to enhance investment returns from that strategy through the use of financing and leverage. It may also use alternative securities and commodities to provide more cost effective exposure, including but not limited to futures, options on futures, swaps and options on swaps (aka “swaptions”). This strategy requires the maintenance of a highly concentrated portfolio, not one that is diversified. The Fund may, however, use a variety of hedging techniques to reduce certain risks inherent in a fixed income portfolio, such as duration (a measure of a bond’s interest rate sensitivity), convexity (a measure of sensitivity of a bond’s duration to a change in interest rates), volatility (a measure of variation in price), and spread widening (a measure of price impact due to changes in credit spreads). The Fund’s approach emphasizes identifying cost effective strategies, and attempts to utilize liquid instruments, such that they may have the opportunity to monetize the hedging strategies, should the environment warrant such a transaction. Investment Strategy: Rimrock Core Bond Fund Rimrock Core Bond Fund, under normal circumstances, will invest at least 80% of its net assets (plus borrowings for investment purposes) in a diversified portfolio of fixed income securities with varying maturities, issued by domestic and foreign entities. The Fund will use the Bloomberg Barclays U.S. Aggregate Bond Index (the “U.S. Aggregate Index”) as its benchmark and will seek to outperform the performance of that index. Under normal conditions, the Fund’s target portfolio duration will be plus or minus two years from that of the U.S. Aggregate Index. Duration is a measure of the expected life of a fixed income security that is used to determine the sensitivity of a security’s price to changes in interest rates. The longer a security’s duration, the more sensitive it will be to changes in interest rates. For example, the price of a bond fund with an average duration of three years generally would be expected to fall approximately 3% if interest rates rose –19– by one percentage point. As a result of this target, the portfolio duration of the Fund will normally be significantly longer than the duration of Rimrock’s other investment strategies. The Fund invests in the U.S. and abroad, including in emerging market countries. The Fund may invest up to 30% of its assets in securities denominated in foreign currencies, and may invest beyond this limit in U.S. dollar-denominated securities of foreign issuers. The Fund will seek to maintain a market value weighted average credit rating of “A-”. Up to 25% of the Fund’s net assets may be invested in securities rated below investment grade (such securities are considered speculative and are often called “junk bonds”) by Moody’s Investors Service, Inc. (“Moody’s”), Standard & Poor’s Ratings Services (“S&P”) or Fitch, Inc. (“Fitch”), or, if unrated, as determined to be of comparable quality by Rimrock.. There is no bottom limit on the ratings of securities that may be purchased or held by the Fund, and the Fund may also invest in loans and debt securities of distressed issuers or issuers in default at the time of purchase. The Fund will not invest more than 15% of its net assets in illiquid securities. Rimrock will focus the Fund’s portfolio holdings in areas of the bond market that it believes are relatively undervalued and offer attractive prospective risk-adjusted returns compared to other segments of the bond market. The Fund’s portfolio may include various types of bonds and debt securities, including corporate bonds, notes, mortgage-related and asset-backed securities (including collateralized debt obligations, which in turn include collateralized bond obligations and collateralized loan obligations), bank loans, U.S. and non-U.S. money-market securities, municipal securities, derivatives (including options, futures, and swaps), private placements and restricted securities. These investments may have interest rates that are fixed, variable or floating. The Fund may use derivatives, including futures, options and swaps, to hedge investments, for risk management, or to increase income or gains for the Fund. The Fund may also seek to obtain market exposure to the securities in which it invests by entering into repurchase agreements and reverse repurchase agreements, or by using other investment techniques. The Fund may regularly short sell up to 25% of the value of its total assets. C. Risk of Loss The Rimrock Funds and Managed Accounts are subject to swings in value. All Funds and Managed Accounts follow an investment strategy that, if unsuccessful, could involve significant losses for Investors. Although Rimrock has the flexibility to react to changing market conditions, or changes in an investment, either could result in significant losses. The Rimrock Core Bond Fund has restrictive investment guidelines which may limit some risks but will also prevent Fund from enjoying from certain investment opportunities available to the Private Funds. An investment in the Private Funds or in Managed Accounts will not be liquid and is suitable only for persons who have no need for a return of any part of their investment for an extended period of time. There can be no guarantee that any account’s or Fund’s investment objectives will be achieved. Any such investment is subject to significant risk. There is risk associated with reliance on Rimrock. The following is a partial list of the types of risks an investor assumes:
• Investment selection where one depends on Rimrock’s skill;
• Possible changes in investment strategies and policies;
• Payment of a portion of the net profits to Rimrock creates an incentive to take riskier positions;
• Investors will not have direct input into the management of any Fund or Managed Account; –20–
• Lack of regulatory oversight where the Funds or Managed Accounts are not covered by the Investment Company Act;
• Limited access to Fund information except periodic reports;
• Valuation of Fund and Managed Account investments; and
• Conflicts of interest, such as competing time pressure, challenges of allocating investment opportunities, and potential exposure to non-public information. 1. Certain Risks of Debt Securities Generally In addition to the material but generic examples listed above, Rimrock may expose investors in Funds and Managed Accounts to the non-exhaustive list below of specific security-related risks. Rimrock will not attempt to hedge all market and other risks inherent in the Funds’ or Managed Accounts’ positions. Rimrock may partially hedge certain risks. This will result in various directional market risks remaining unhedged. Rimrock may rely on diversification to control such risks to the extent that Rimrock believes it is desirable to do so. (a) Interest Rates Interest rate risk refers to the risks associated with market changes in interest rates. Interest rate changes may affect the value of a debt instrument indirectly (especially in the case of fixed rate securities) and directly (especially in the case of instruments whose rates are adjustable). The market value of debt securities that are interest rate sensitive is inversely related to changes in interest rates. That is, an interest rate decline produces an increase in a security’s market value and an interest rate increase produces a decrease in value. The longer the remaining maturity of a security, the greater the effect of interest rate changes. Changes in the ability of an issuer to make payments of interest and principal and in the market’s perception of its creditworthiness also affect the market value of that issuer’s debt securities. Adjustable rate instruments also react to interest rate changes in a similar manner although generally to a lesser degree (depending, however, on the characteristics of the reset terms, including the index chosen, frequency of reset and reset caps or floors, among other factors). Interest rate sensitivity is generally more pronounced and less predictable in instruments with uncertain payment or prepayment schedules. Although governmental financial regulators, including the U.S. Federal Reserve, have taken steps to maintain historically low interest rates, the U.S. Federal Reserve has begun to raise interest rates slightly. It is possible there will be less governmental action in the future to maintain low interest rates or that action will be taken to raise interest rates further. Changes in market conditions and governmental action may have adverse effects on instruments, volatility, and liquidity in debt markets and any negative impact on fixed income securities could be swift and significant and may negatively impact performance. (b) Maturity Risk Interest-rate risk will generally affect the price of a debt security more if the security has a longer maturity. Debt securities with longer maturities will therefore be more volatile than other fixed-income securities with shorter maturities. Conversely, debt securities with shorter maturities will be less volatile but generally provide lower returns than municipal securities with longer maturities. The average maturity of a portfolio’s debt security investments will affect the volatility of that portfolio’s value. (c) Credit Risk Credit risk is the risk that the issuer of a debt security will not be able to pay principal and interest when due. Financial strength and solvency of an issuer are the primary factors influencing credit risk. In addition, –21– lack or inadequacy of collateral or credit enhancement for a debt instrument may affect its credit risk. Rating agencies assign credit ratings to certain debt securities to indicate their credit risk. The price of a debt security will generally fall if the issuer defaults on its obligation to pay principal or interest, the rating agencies downgrade the issuer’s credit rating or other news affects the market’s perception of the issuer’s credit risk. A portion of a portfolio’s holdings may be invested in below investment grade issues which may be subject to greater credit risk. Because not all dealers maintain markets in all lower quality and comparable unrated securities, there is no established retail secondary market for many of these securities. The lack of a liquid secondary market for certain securities may make it more difficult for a portfolio to obtain accurate market quotations for purposes of valuing portfolios. In addition, adverse publicity and Investor perceptions, whether or not based on Fundamental analysis, may decrease the values and liquidity of lower-quality and comparable unrated securities, especially in a thinly traded market. (d) Investment-Grade Securities Although bonds and notes rated in the BBB or equivalent category are commonly referred to as investment grade, they may have speculative characteristics. Such investments may, under certain circumstances, lead to a greater degree of fluctuation in a portfolio’s asset value than if a portfolio only invested in higher-rated investment-grade securities with similar maturities. In addition, changes in economic conditions or other circumstances are more likely to lead to a weakened capacity to make principal and interest payments than is the case with higher grade bonds. (e) Non-Investment-Grade Securities A portfolio may invest in debt securities that are generally rated below investment grade (such as BB or lower by Standard & Poor’s Corporation and/or BA or lower by Moody’s Investors Service, Inc.) or deemed to be below investment grade by Rimrock in its sole discretion. These securities, often referred to as high- yield debt securities, are considered speculative and, while generally offering greater income than investments in higher quality securities, involve greater risk of loss of principal and income, including the possibility of default or bankruptcy of the issuers of such securities, especially during periods of economic uncertainty or change. These lower quality bonds tend to be affected by economic changes and short-term corporate and industry developments, as well as public perception of those changes and developments, to a greater extent than higher quality securities, which react primarily to fluctuations in the general level of interest rates. In addition, the market for lower-rated debt securities may be thinner and less active than that for higher- rated debt securities, which can adversely affect the prices at which the lower-rated debt securities are sold. If market quotations are not available, lower-rated debt securities will be valued by Rimrock in its sole discretion. Judgment plays a greater role in valuing high-yield corporate-debt securities than is the case for securities for which more external sources for quotations and last sale information is available. Adverse publicity and changing Investor perception may also affect the availability of outside pricing services to value lower-rated debt securities and a portfolio’s ability to dispose of these securities. In addition, such securities generally present a higher degree of credit risk. Issuers of lower-rated debt securities are often highly leveraged and may not have more traditional methods of financing available to them so that their ability to service their obligations during an economic downturn or during sustained periods of rising interest rates may be impaired. The risk of loss due to default by such issuers is significantly greater because below investment-grade securities generally are unsecured and frequently are subordinated to the prior payment of senior indebtedness. –22– Additionally, while the market for high yield municipal debt securities has been in existence for many years and has weathered previous economic downturns, past experience may not provide an accurate indication of future performance of the high yield bond market, especially during periods of economic recession. (f) Restructurings, Divestitures and Spin-Offs Special situations that include the reorganization of corporate assets can create inefficiencies in the pricing of underlying securities. In many such situations, stock in a business within a reorganizing company will trade on a “when issued” basis prior to that business becoming a stand-alone public company. Rimrock may invest in this type of situation to take advantage of the relationship between the “when issued” security and the underlying security. Additionally, Rimrock may invest in any type of restructuring, divestiture or spin-off that exhibits a discrepancy in value between a business in its current form and the business or combination of businesses that will be the result of an extraordinary event. (g) Stub Securities Stub securities typically refer to a small equity component remaining after one company becomes the owner of a significant portion, but not all, of another. For example, this occurs when a buyout group leaves a small percentage of a company’s equity in the public market after the completion of a tender offer or merger to avoid having to file an initial public offering in the future. Another example is when a large public company in one business owns a significant position in the stock of another large public company in another business. The stock price of the owner of the equity position can be broken down into two (2) parts, one part that represents the ongoing business of that company, and one part that represents the value of the equity position in the other company. Buying the stock of the owner and selling short the stock of the other company creates a synthetic stub security representing the value of the owner’s core business. Rimrock may purchase stub securities that it believes are inefficiently priced versus other related securities. (h) Bankruptcy Reorganizations and Distress Situations Rimrock invests in securities of companies that are stressed or distressed due to operating difficulties or an untenable capital structure. Rimrock believes that these special situations can present a unique opportunity to invest in a company below its intrinsic value. Investments will be made in securities with the potential for superior returns based on evaluation and research concentrating on: (i) industry (including barriers to entry, competition, pricing power and regulatory issues); (ii) company (including ownership, quality of management, profitability, credit statistics and event risk); (iii) security (including seniority in capital structure, covenant protection and asset protection); and (iv) valuation (including cash flows and company assets). Once Rimrock identifies companies using one or more of the above research criteria, its strategy includes one or more of the following: (i) infusing capital into those companies that temporarily lack access to traditional sources of capital; (ii) financial restructuring of those companies that are distressed, in default or in bankruptcy; (iii) recapitalizing small to mid-sized private and public companies where the demands of the business and the demands of the marketplace create a capital market dichotomy; and (iv) reorganizing or globalizing those companies whose divisions, sections or departments are being transitioned or sold for political, strategic or organizational reasons. Rimrock’s strategy also includes the establishment of significant creditor positions respecting an identified company by purchasing that company’s debt securities at a fraction of their face values. This can provide Rimrock with the necessary leverage to influence the company in its reorganization, restructuring or recapitalization efforts. –23– (i) Bank Loans and Participations A portfolio may include significant amounts of bank loans and participations. These obligations are subject to unique risks, including (i) the possible invalidation of an investment transaction as a “fraudulent conveyance” under relevant creditors’ rights laws, (ii) so-called “lender liability” claims by the issuer of the obligations, (iii) environmental liabilities that may arise with respect to collateral securing the obligations, and (iv) limitations on the ability of a portfolio to directly enforce its rights with respect to participations. In analyzing each bank loan or participation, Rimrock compares the relative significance of the risks against the expected benefits. Successful claims by third parties arising from these and other risks, absent fraud, willful misconduct or gross negligence by Rimrock, will be borne by a portfolio. (j) Bankruptcy Issues Some of the companies in which a portfolio invests may be involved in bankruptcy. There are a number of significant risks inherent in the bankruptcy process. These include the risks described below. (i) Loss of Creditor Control. Many events in a bankruptcy are the product of contested matters and adversarial proceedings and are beyond the control of the creditors. While creditors are generally given an opportunity to object to significant actions, there can be no assurance that a bankruptcy court in the exercise of its broad powers would not approve actions that would be contrary to the interests of a portfolio. (ii) Permanent Adverse Effects. The effect of a bankruptcy filing on a company may adversely and permanently affect the company. The company may lose its market position and key employees and otherwise become incapable of restoring itself as a viable entity. If, for this or any other reason, the proceeding is converted to liquidation, the liquidation value of the company may not equal the liquidation value that was believed to exist at the time of the investment. (iii) Delays. The duration of a bankruptcy proceeding is difficult to predict. A creditor’s return on investment can be adversely impacted by delays while the plan of reorganization is being negotiated, approved by the creditors and confirmed by the bankruptcy court and until the plan ultimately becomes effective. Reorganizations outside of bankruptcy are also subject to unpredictable and potentially lengthy delays. (iv) High Administrative Costs. The administrative costs in connection with a bankruptcy proceeding are frequently high and will be paid out of the debtor’s estate prior to any return to creditors. For example, if a proceeding involves protracted or difficult litigation, or turns into a liquidation, substantial assets may be devoted to administrative costs. (v) Class Claims. Bankruptcy law permits the classification of “substantially similar” claims in determining the classification of claims in a reorganization. Because the standard for classification is vague, there exists the risk that an investor’s influence with respect to the class of securities it owns can be lost by increases in the number and amount of claims in that class or by different classification and treatment. (vi) Contingent Claims. In the early stages of the bankruptcy process, it is often difficult to estimate the extent of, or even to identify, any contingent claims that might be made. –24– (vii) Dominion and Control. Especially in the case of investments made prior to the commencement of bankruptcy proceedings, creditors can lose their ranking and priority if they exercise “domination and control” of a debtor and other creditors can demonstrate that they have been harmed by such actions. (viii) Priority Claims. Certain claims that have priority by law (for example, claims for taxes, employee salaries, pension claims and environmental claims) may be quite substantial. In addition, under certain circumstances, payments to a portfolio and distributions by a portfolio to its respective investors may be reclaimed if any such payment is later determined to have been a fraudulent conveyance or a preferential payment. (k) Participation on Creditors’ Committees A portfolio may participate on committees formed by creditors to negotiate with the management of financially troubled companies that may or may not be in bankruptcy. A portfolio may also seek to negotiate directly with debtors with respect to restructuring issues. In the situation where a portfolio does choose to join a creditors’ committee, the portfolio would likely be only one of many participants, each of whom would be interested in obtaining an outcome that is in its individual best interests. There can be no assurance that a portfolio would be successful in obtaining results favorable to it in such proceedings, although the portfolio may incur significant legal fees and other expenses in attempting to do so. As a result of participation by a portfolio on such committees, the portfolio may be deemed to have duties to other creditors represented by the committees, which might thereby expose the portfolio to liability to such other creditors who disagree with the portfolio’s actions. (l) Litigation Rimrock may invest in companies involved in litigation where the outcome of a lawsuit may have a significant impact on a company in the very short term. Typically, these situations create significant uncertainty about the future of an enterprise and, consequently, allow for mispricing of the underlying securities. From time-to-time, a Fund or Managed Account may be long, short or hedged in securities of companies involved in these situations. This will be the case in so far as Rimrock can create positions that have attractive risk reward parameters based on the expected outcome of the legal event. In addition, clients may have direct claims arising out of their investments. Rimrock will assist with proofs of claim and engage outside counsel to provide advice or litigate client claims but cannot guarantee that such counsel will ultimately be successful in obtaining meaningful recoveries for clients. (m) Cybersecurity With the increased use of technologies such as the Internet to conduct business, Rimrock and its vendors and other service providers are susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events and may arise from external or internal sources. Cyber-attacks include, but are not limited to, gaining unauthorized access to digital systems, corrupting data, equipment or systems, or causing network services to be unavailable to intended users (i.e., “denial of service”) or other operational disruption. Cyber incidents affecting Rimrock, its vendors, and other service providers have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, the release of investor information or confidential business information, interference with the ability to calculate net asset values, impediments to trading, destruction of equipment and systems, violation of applicable privacy and other laws, regulatory fines or penalties, reputational damage, or additional compliance costs. Similar adverse consequences could result from cyber –25– incidents affecting issuers of financial instruments in which Rimrock clients invest, counterparties with which clients engage in transactions, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions or parties. (n) Unusual Securities Creations Rimrock may invest in unusual securities created for particular purposes that are not of a type typically traded in the securities markets. Examples of such securities include, but are not limited to, publicly traded limited liability companies, contingent payment rights, and securities whose value is contingent upon the occurrence of a series of events. There may be no liquid market for such securities. The market prices, if any, of such investments tend to be more volatile and it may be impossible to sell such investments when desired or to realize their fair value in the event of a sale. Moreover, securities in which a portfolio may invest include those that are not listed on a stock exchange or traded in an over-the- counter market. As a result of the absence of a public trading market for these securities, they may be less liquid than publicly traded securities. There may be substantial delays in attempting to sell non-publicly traded securities. Although these securities may be resold in privately negotiated transactions, the prices realized from these sales could be less than those originally paid. Further, companies whose securities are not publicly traded are not subject to the disclosure and other investor protection requirements which would be applicable if their securities were publicly traded. (o) Equity Securities The purchaser of an equity security typically receives an ownership interest in the company with certain voting rights. The owner of an equity security may participate in a company’s success through the receipt of dividends, which are distributions of earnings by the company to its owners. Equity security owners may also participate in a company’s success or lack of success through increases or decreases in the value of the company’s shares as traded in the public trading market for such shares. Equity securities generally take the form of common stock or preferred stock. Preferred stockholders typically receive greater dividends but may receive less appreciation than common stockholders and may have lesser or greater voting rights as well. Equity securities may also include convertible securities, warrants or rights. Convertible securities typically are debt securities or preferred stocks which are convertible into common stock after certain time periods or under certain circumstances. Warrants or rights give the holder the right to purchase a common stock at a given time for a specified price. A portfolio may invest in equity securities of mid or small capitalization companies and recently organized or reorganized companies. Such securities have been more volatile in price than those of larger capitalized, more established companies. Securities of such companies pose greater investment risks because such companies may have limited product lines, distribution channels and financial and managerial resources. Further, there is often less publicly available information concerning such companies. The equity securities of such companies are often traded over the counter and not in the volumes typical on a national securities exchange. Consequently, a portfolio may be required to dispose of such securities over a longer, and potentially less favorable, period of time than is required to dispose of securities of larger, more established companies. (p) Initial Public Offerings A portfolio may invest in initial public offerings, either directly or indirectly through investment in convertible securities, warrants, and other securities. An initial public offering (“IPO”) is a –26– company’s first offering of stock to the public. The market value of IPO shares may fluctuate wildly due to factors such as the absence of a prior public market, unreasoned trading, excitement or concern around a company’s novel business, the small number of shares available for trading, and limited information about the issuer. The purchase of IPO shares may involve high transaction costs. A significant portion of a portfolio’s performance could be attributable to investments in IPOs, because such investments in a fixed income portfolio could have a magnified impact. Because of the price volatility of IPO shares, IPO shares may be held for a short period of time. This may increase the turnover of the portfolio and may lead to increased expenses. The market for IPO shares can be speculative and/or inactive for extended periods of time. The limited number of shares available for trading in some IPOs may make it more difficult to buy or sell significant amounts of IPO shares without an unfavorable impact on prevailing prices. Investors in IPO shares can be affected by substantial dilution in the value of their shares, by sales of additional shares and by concentration of control in existing management and principal shareholders. (q) Preferred Stock A portfolio may invest in preferred stock which may have characteristics of both debt and equity securities. Dividend payments to preferred stockholders may be suspended or cancelled if the issuer experiences liquidity difficulties and the principal paid for preferred stock is generally subordinate to the debt obligations of the issuer. Consequently, investments in preferred stock carry significant risk of loss of principal. (r) Private Equity Risks Private equity investments involve an extraordinarily high degree of business and financial risk and can result in substantial or complete losses. Some private companies in which a portfolio invests, either directly or as a result of a reorganization, may be operating at a loss or with substantial variations in operating results from period to period and may need substantial additional capital to support expansion or to achieve or maintain competitive positions. Such companies may face intense competition, including competition from companies with much greater financial resources, much more extensive development, production, marketing and service capabilities and a much larger number of qualified managerial and technical personnel. Rimrock may or may not have control positions in private companies. When Rimrock takes minority positions and lacks control, clients run the risk that management or other shareholders will refuse to adopt Rimrock’s recommendations, resulting in investment losses from such refusal or disagreement. When Rimrock has a controlling interest, its actions may be limited by its fiduciary obligations to minority equity holders. If Rimrock selects or influences the selection of company management, or independent consultants to management, the managers or consultants selected may not be successful. Rimrock can offer no assurance that the efforts of any particular private portfolio company will be successful or that its business will succeed. (s) Developments in Global Markets Global markets have experienced significant market events, including decreasing liquidity and declining market values. Increasing credit and valuation problems in the corporate, governmental and sovereign debt markets and the mass liquidation of investment portfolios across all markets, among other factors, have generated extreme volatility and illiquidity in worldwide capital markets. This volatility and illiquidity has extended to the global markets generally and has been exacerbated by, among other things, growing uncertainty regarding the extent of the problems in the mortgage industry and financial institutions and the –27– financial and economic condition of certain governments and countries, including decreased risk tolerance by investors, significantly tightened availability of credit and global deleveraging. The continuation of these market conditions and uncertainty and further deteriorations could result in further declines in the market values of the investment assets anticipated to be held by a portfolio. The duration and ultimate effect of these market conditions cannot be predicted, nor is it known whether or the degree to which such conditions may worsen. Such declines could prevent a portfolio from successfully executing the portfolio’s investment strategy, and may require the portfolio to dispose of investments at a loss while such adverse market conditions prevail. European economies in particular have been experiencing a prolonged economic downturn, resulting in heightened credit risk, reduced valuation of investments, and decreased economic activity. Although European governments have taken various actions to try to stabilize the financial markets, it is unclear whether those actions will be effective, and it is possible that those actions could lead to an inflationary environment. If these risks materialize, a portfolio’s financial results could be negatively impacted even after the end of an economic downturn. An inflationary environment (which could follow government efforts to stabilize the economy) could also adversely impact a portfolio’s reserves and could adversely impact the valuation of the portfolio’s investments. Such economic uncertainty has been exacerbated by the increased potential for default by one or more European sovereign debt issuers and the negative impact of such an event on global financial institutions and capital markets generally. Actions or inactions of European governments may impact these actual or perceived risks. If one or more European sovereign debt issuers defaults, then a portfolio’s investments, financial position, and liquidity could be materially and adversely affected. On June 23, 2016, the United Kingdom (the “U.K.”) held a referendum in which a majority of voters approved an exit from the European Union (the “E.U.”), commonly referred to as “Brexit.” Brexit has caused significant volatility in global stock markets and currency exchange fluctuations, including a sharp decline in the value of the British pound sterling as compared to the U.S. dollar and other currencies. Consequently, investments denominated in British pounds sterling are subject to increased risks related to these currency rate fluctuations and our net assets in U.S. dollar terms may decline. The long-term effects of Brexit are expected to depend on, among other things, the agreements the U.K. makes to retain access to E.U. markets either during a transitional period or more permanently. Brexit could adversely affect European or worldwide economic or market conditions and could contribute to instability in global financial markets. In addition, Brexit could lead to legal uncertainty and potentially divergent national laws and regulations as the U.K. determines which E.U. laws to replace or replicate. Until the terms of the U.K’s exit from the E.U. become more clear, it is not possible to determine the impact that the U.K.’s departure from the E.U. and/or any related matters may have on a portfolio; however, any of these effects of Brexit, and others that cannot be anticipated, could adversely affect the business of a portfolio. (t) Non-U.S. Investments Involve More Risks A portfolio may invest in securities of non-U.S. companies (including Depository Receipts), which involve risk not typically associated with investing in U.S. companies. A portfolio may be affected unfavorably by exchange control regulations or changes in the exchange rate between non-U.S. currencies and the U.S. dollar. Non-U.S. economies may differ unfavorably from the U.S. economy in growth of gross national product, rate of inflation, rate of savings and capital reinvestment, resource self-sufficiency and balance of payment positions, and in other respects. The value and marketability of a portfolio’s investments in some non-U.S. countries could be materially reduced by expropriation or confiscatory taxation, limitations on the –28– removal of funds or other assets, political or social instability, or diplomatic developments. In addition, securities of some non-U.S. companies are less liquid and their prices are more volatile than securities of comparable U.S. companies. Investing in non-U.S. securities creates a greater risk of clearance and settlement problems than does investing in U.S. securities. (u) Recent and Anticipated Regulatory Activity The U.S. Congress, the SEC and other regulators have taken, or represented that they may take, action to increase or otherwise modify the laws, rules and regulations applicable to short sales, derivatives and other techniques and instruments in which a portfolio may invest. New (or modified) laws, rules and regulations may prevent, or significantly limit the ability of, Rimrock from using certain such instruments or from engaging in such transactions. This may impair the ability of Rimrock to carry out a portfolio’s investment strategy and may otherwise have an adverse impact on a portfolio’s returns. Compliance with such new or modified laws, rules and regulations may also increase the portfolio’s expenses and therefore, may adversely affect the portfolio’s performance. For example, the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) imposes a number of new regulations governing certain over-the-counter derivative instruments and transactions. The SEC, the CFTC and various other regulatory agencies, including the federal banking agencies, have adopted numerous final rules implementing the Dodd-Frank Act, and continue with the process of developing regulations implementing the provisions of the Dodd-Frank Act. The final rules, exemptive orders and guidance actions promulgated by such agencies may impact the investment activities of Rimrock on behalf of a portfolio. Furthermore, since the finalization process is ongoing, it is not possible at this time to predict with certainty the total impact the Dodd-Frank Act and such implementing regulations will have on Rimrock or a portfolio. It is possible that such impact could be adverse and material. In addition, the legal and regulatory environment for private investment funds (such as the Private Funds) and their managers is evolving worldwide. Increased regulation and regulatory oversight may impose administrative burdens on Rimrock, including, without limitation, responding to examinations and other regulatory inquiries and implementing new regulations, policies and procedures. Changes in the regulation of private investment funds, their managers and their investment activities may have a material adverse effect on the ability of clients to pursue their investment program and the value of investments held by Private Funds. (v) Non-U.S. Investments Have Less Regulatory Oversight and Protection The securities of non-U.S. issuers held by a portfolio are generally not registered under, nor are those issuers subject to the reporting requirements of, the U.S. securities laws and regulations. Accordingly, there may be less publicly available information about the securities, the non-U.S. company or government issuing them, or the non-U.S. board of trade clearing them than is available about a U.S. company, government entity or board of trade. Non-U.S. companies and non-U.S. boards of trade are not generally subject to accounting, auditing, and financial reporting standards, practices and requirements comparable to those that apply to U.S. companies. Non-U.S. government supervision of stock exchanges, boards of trade, securities brokers and issuers of securities is generally less stringent than supervision in the U.S. The investments may also be subject to withholding taxes imposed by the applicable country’s taxing authority. (w) Emerging Markets Emerging market countries include: (i) countries that are generally considered low or middle income countries by the International Bank for Reconstruction and Development (commonly known as the World –29– Bank) and the International Finance Corporation; (ii) countries that are classified by the United Nations or otherwise regarded by their authorities as emerging; or (iii) countries with a market capitalization of less than 3% of the Morgan Stanley Capital World Index. A portfolio may invest without percentage limitation in U.S. or non-U.S. securities. A portfolio may invest up to 100% of their total assets in emerging markets. Investments in companies domiciled in developing countries may be subject to potentially higher risks than investments in companies in developed countries. These risks include (i) less social, political and economic stability; (ii) the small current size of the markets for such securities and the currently low or nonexistent volume of trading, that result in a lack of liquidity and in greater price volatility; (iii) certain national policies may restrict a portfolio’s investment opportunities, including restrictions on investment in issuers or industries deemed sensitive to national interests; (iv) foreign taxation; (v) the absence of developed legal structures governing private or foreign investment or allowing for judicial redress please register to get more info

Investment advisers registered with the SEC are required to disclose all material facts regarding any legal or disciplinary events that could be important to a client’s evaluation of Rimrock or the integrity of Rimrock’s management. Rimrock has been registered and in the business of providing investment advisory services since 2006. Neither our Firm nor any of our associated persons has any reportable disciplinary information. please register to get more info

A. Broker-Dealer Affiliations Rimrock is not registered as a broker-dealer nor does Rimrock currently have a pending application to register as a broker-dealer. Rimrock has entered into a services agreement with Foreside Financial Services, LLC (“Foreside”) for the Private Funds and Rimrock Funds Trust. Foreside is a registered broker-dealer and member of the Financial Industry Regulatory Authority (“FINRA”), established for the purpose of providing marketing and distribution of both private and public funds. Foreside does not trade securities nor provide pricing services to Rimrock. Foreside is not owned by Rimrock. Several Rimrock employees are registered representatives of Foreside, given their focus on marketing Rimrock’s Funds. Foreside is compensated by Rimrock for distribution of Rimrock Private Funds through a flat fee arrangement, consisting of a base fee plus fees per registered representative and per fund. Foreside is also the primary underwriter and distributor of the shares of the Rimrock Core Bond Fund. Pursuant to a distribution agreement, Foreside acts as the agent of the Trust in connection with the continuous offering of shares of that Fund. Foreside distributes shares of the Rimrock Core Bond Fund on a best efforts basis and has no obligation to sell any specific quantity of shares. The Rimrock Core Bond Fund has adopted a distribution plan with respect to the Investor Class pursuant to Rule 12b-1 of the Investment Company Act of 1940. The plan authorizes that Fund to pay Foreside annual fees of up to 0.25% of the Fund’s average daily net assets attributable to its Investor Class shares in consideration for distribution and shareholder services and the assumption of related expenses. –41– Rimrock has entered into a services agreement with Ueda Yagi Securities Co., Ltd, (“Ueda Yagi”) a Japanese registered financial services firm located in Tokyo, Japan. Ueda Yagi and Rimrock entered into the agreement in order for Ueda Yagi to perform services such as consulting about business development, translating documents and presentations, as well as arranging meetings with potential Japanese investors for Rimrock Funds. The compensation for Ueda Yagi’s services is paid through a fee sharing arrangement from assets raised in Japan. Rimrock has created additional feeder funds, Rimrock Low Volatility (QP) (JPY) Trust, Rimrock Structured Product (JPY) Trust, and Rimrock High Income PLUS (JPY) Trust, all Yen-denominated feeder funds, for Japanese investors. B. CPO and CTA Registrations Rimrock is a NFA (formerly the National Futures Association) approved member. Rimrock has obtained exemptions from certain regulatory requirements applicable to commodity pools for its master and feeder Private Funds under Regulation 4.7 of the Commodity Exchange Act, as amended (“CEA”). This exemption limits eligible Private Fund investors to Qualified Eligible Persons. The Rimrock Core Bond Fund is also exempt from certain commodity pool regulatory requirements under Regulation 4.12(c) of the CEA. Rimrock is registered as a Commodity Trading Advisor (“CTA”) and as a Commodity Pool Operator (“CPO”). C. Other Financial Industry Affiliations Rimrock is organized and serves as the general partner and/or investment adviser of private investment funds, as described under the “Advisory Business” section of this brochure. For Funds where we, or our associated persons, serve as manager, general partner, and/or investment adviser, our Firm makes the Funds available to qualified investors whose investment strategies are consistent with the objectives of the Fund(s). Our Firm does not advise you as to the appropriateness of investing in our Funds and will not receive any compensation for doing so except to the extent that we receive advisory and other fees from the Funds or for selling interests in the Funds. However, because of the relationship between our Firm and the Funds, a conflict of interest may exist because we have a financial incentive to recommend our Funds. While we believe that compensation charged by the Private Funds is competitive, such compensation may be higher than fees charged by other investment vehicles providing the same or similar services. You are under no obligation to invest in any of the Rimrock Funds and may obtain comparable services and/or lower fees through other firms. Rimrock’s Principals formed RCM Holdings for the purpose of making collective personal investments, both in Rimrock Funds, as well as select external investments. In 2019, Rimrock created a new affiliate, RCM Services, LLC, to provide administrative and other support to various legal entities, including Rimrock, and moved a number of Rimrock employees to RCM Services. RCM Services employees continue to provide a variety of support to Rimrock, including human resources management, accounting, technology support, financial statement preparation and legal and compliance support. RCM Services has, as external investments, minority interests in Rimrock Real Estate Ventures, L.P. (“RREV”) and Vimvi Corporation (“Vimvi”) and their affiliated firms. RREV is a commercial real estate finance company that originates, invests in, services, and sells commercial real estate equity and debt. Vimvi is a real estate brokerage firm headquartered in Pasadena, California. Rimrock reviews these investments for potential conflicts of interest on at least an annual basis.

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Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for our associated persons. Our goal is to protect client and investor interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing. All of our associated persons are expected to adhere strictly to these guidelines. Our Code of Ethics requires that associated persons submit reports of their personal securities account holdings and transactions to Rimrock’s Compliance Department, who reviews these reports on a periodic basis. Associated persons are further required to obtain preapproval for any outside business activities and certain personal securities trades to avoid potential conflicts of interest. Persons associated with our Firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information and confidential information about clients or client account holdings by persons associated with our Firm. Rimrock personnel are permitted to serve as directors of private or public companies whose securities are held by clients. Rimrock also enters into non- disclosure agreements with issuers of securities and receives potential material non-public information from those issuers. If material non-public information is obtained, clients may be prohibited from purchasing or selling securities for a period of time. Rimrock also places restrictions on gifts and entertainment to avoid potential conflicts of interest that can arise when associated persons accept or give gifts or entertainment. For example, Rimrock prohibits the giving and receipt of cash gifts and requires associated persons to report gifts received from a single source that exceeds a monetary threshold. Clients or prospective clients, and investors or prospective investors in any of the Funds, may review a complete copy of our Code of Ethics by contacting us at the telephone number on the cover page of this brochure. Participation or Interest in Client Transactions We serve as the investment adviser/general partner to the Funds named in the “Advisory Business” section of this brochure in which you may be solicited to invest. Persons associated with our Firm have significant investments in the Funds. If you are an investor in one or more of the Funds, please refer to the Funds’ offering documents for detailed disclosures regarding the Funds. Additionally, individuals associated with our Firm may buy or sell - for their personal accounts - investment products identical to those purchased by the Funds. This practice may create a conflict of interest because we have the ability to trade ahead of the Funds and potentially receive more favorable prices than the Funds will receive or to benefit from the market effect of the Fund’s later trades. To eliminate this conflict of interest, it is our policy that neither our associated persons nor we shall have priority over the Funds in the purchase or sale of securities. Personal Trading Practices Rimrock recognizes that the personal investment transactions of its employees and members of their immediate families demand the application of a strict code of ethics. Consequently, Rimrock requires that all personal investment transactions be carried out in a manner that will not endanger the interest of any client or create any apparent or actual conflict of interest between Rimrock and its employees, on the one hand, and the client, on the other hand. Thus, Rimrock has adopted the procedures set forth below. All –43– trades for personal accounts must be consistent with recommendations and actions that Rimrock has taken or will take on behalf of its clients and Rimrock’s Trade Allocation Policy. Client’s interests take precedence over the personal interests of Rimrock and its associated persons. If a potential personal trading conflict arises, Rimrock and the employee must resolve the matter in the client’s favor. All trades for personal accounts in individual, publicly traded securities generally must be pre-cleared and must comply with Rimrock’s Restricted List. Employee investments in private investment offerings and initial public offerings must also be pre-cleared and are reviewed for potential conflicts. These restrictions are intended to protect both Rimrock and its employees from even the appearance of impropriety with respect to any transactions or securities in an associated person’s personal account. Outside Business Activities Rimrock personnel are permitted to engage in business activities outside Rimrock, which may create a potential conflict of interest if they cause an associated person to have divided loyalties, requiring choices between that other interest and the interests of Rimrock or Rimrock’s clients. Accordingly, all associated persons are required to report and obtain approval, in advance, of prospective outside business activities, including but not limited to serving as an officer or on the board of directors or trustees of any public or private company, other than a not-for-profit organization. Prohibition on Affiliated Loans Rimrock prohibits loans from any client to any affiliated person or entity. please register to get more info

Rimrock has been granted the authority to select the broker or dealer through which to place trades on behalf of the Funds through each Fund’s organizational documents and client agreements. When executing transactions, we endeavor to select those brokers, dealers or other counterparties which will provide the best services at the lowest prices under the circumstances. Rimrock may consider a broker-dealer’s execution capability, commission rates (if applicable) or spreads, the value of research provided (if any), the availability and completeness of information before and after the trade regarding bid/ask spreads or other indications of interest, the availability of fixed income securities with the characteristics sought, availability of repo financing, expertise in particular markets or products, responsiveness, and financial strength and responsibility, among other factors. Rimrock’s Evaluation and Pricing Committee is responsible for monitoring client execution. Research and Other Soft Dollar Benefits Rimrock currently does not have any soft dollar arrangements, nor do we plan on entering into “soft dollar” arrangements. In effecting its fixed income trading, Rimrock does not generally generate brokerage commissions from client accounts that could be used to obtain research or related brokerage services as defined in Section 28(e) of the Securities Exchange Act of 1934. From time to time, Rimrock receives unsolicited research from various broker-dealers, who may or may not be counterparties to trades placed on behalf of clients, about particular companies, industries or general economic conditions. Certain broker-dealers will also invite Rimrock employees to attend meetings with representatives of securities issuers or analysts. Although Rimrock may review and consider certain of the research received, and may attend these meetings, Rimrock generally does not take that research or those meetings into consideration in its broker-dealer selection process. Rimrock purchases research and related –44– services using its own resources. For these purposes, “research” means advice, analysis and reports used to provide lawful and appropriate assistance to Rimrock in making investment decisions for its clients. Brokerage for Client Referrals/Fund Distribution Rimrock does not consider in the selection of broker-dealers whether or not Rimrock or a related person receives client referrals from the broker–dealer or a third party. In addition, Rimrock does not consider the promotion or sale of shares issued by any Rimrock managed mutual fund in directing transactions or any transaction-related remuneration, including but not limited to any commission, mark-up, mark-down, or other fee, to a particular broker, dealer, or other counterparty. Block Trades and Investment Allocation Transactions for each client generally will be effected independently, unless we decide to purchase or sell the same security for several clients at approximately the same time. We may, but are not obligated to, aggregate multiple orders for the same security purchased or sold for advisory accounts we manage (this practice is commonly referred to as “block trading”). As a matter of general Firm policy, clients participating in any block trade will receive an average security price and transaction costs will be shared equally and on a pro rata basis. Rimrock’s obligation is to treat all clients fairly over time, but not necessarily identically. Block trades will generally be allocated on a pro-rata basis, modified to reflect a variety of factors. Factors considered in allocation decisions are: (1) client portfolio guidelines and limitations on investments; (2), investment objectives, including risk, return and volatility profiles; (3) portfolio composition and diversification principles; (4) the size, nature and type of investment opportunity; (5) available cash, including cash that becomes available through leverage, subscriptions and redemptions; (6) applicable contractual or legal obligations connected with an investment, including transfer or assignment provisions; and (7) other factors as Rimrock, in good faith, deems relevant. Rimrock’s policy prohibits consideration of fee arrangements, or relationships to an employee or principal of Rimrock, in its allocation decisions. In the event transactions for Rimrock, its employees or principals (“proprietary accounts”), are aggregated with client transactions, conflicts arise and special policies and procedures must be adopted to disclose and address these conflicts. Presently, other than to the extent that Rimrock employees and principals are investors in the Funds, employees and principals do not aggregate orders with clients. Trade Errors In the event a trading error occurs in a client account, our policy is to restore the account to the position it would have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Principal Transactions It is Rimrock’s policy not to execute principal transactions. Principal transactions are defined as transactions where an adviser, acting as principal for its own account or the account of an affiliate, buys from or sells any security to any advisory client. Rimrock deems any account in which it or its principals own 25% or more of the assets to be a principal account for these purposes. –45– Agency Cross Trades It is Rimrock’s policy and practice to not engage in agency cross transactions. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. please register to get more info

Rimrock has a Chief Risk Officer seated on the trading desk, and the Firm has developed proprietary analytical tools and uses commercially-licensed computer systems in order to monitor portfolios. Measures such as duration, spread duration, credit quality, convexity, option adjusted spread, counterparty exposure, leverage, and liquidity are monitored throughout the trading day and reviewed weekly in a Risk Meeting. The weekly Risk Meeting is conducted by the Chief Risk Officer with the Chief Investment Officer and Portfolio Managers. Significant market volatility, material position level changes, or changes on top down outlook may also trigger a review. As an investor in the Rimrock Funds, the custodian provides a monthly account statement, an annual report including financial statements and a statement of your capital account as of the end of the fiscal year. In addition, investors may request to receive a monthly performance report, risk report and other detailed portfolio information. The Funds have independent administrators involved in the monitoring of portfolios and reconciliation of cash and positions. Rimrock also uses an independent public accounting firm to conduct annual audits. Rimrock Managed Accounts receive reports directly from their custodians as well as a monthly risk report from Rimrock. Rimrock monitors and reviews market risks for the Managed Accounts in the same manner as the Funds described above. The custodians for the Managed Accounts are engaged directly by the client and not by Rimrock. please register to get more info

A. Compensation to Rimrock Rimrock’s revenue from advisory clients is derived solely from management fees and performance fees generated through managing Rimrock Funds and Managed Accounts. Any fees or remuneration that a Rimrock officer or employee may receive in connection with serving as a director or trustee of an issuer held by one or more Rimrock clients must be passed along to such clients, on a pro rata basis. B. Compensation by Rimrock As part of our efforts to market the interests of the Funds, Rimrock has entered into arrangements to compensate certain third party placement agents or others for referring prospective investors to the Funds as set forth below. We reserve the right to enter into additional, similar arrangements in the future. Although common, such referral arrangements do create a potential conflict of interest because, in theory, the referrer may be motivated, at least partially, by financial gain and not because the Funds are the most suitable to the prospective investor’s needs. As discussed at Item 10 of this Brochure, Rimrock has entered into a services agreement with Foreside for the Private Funds and a primary underwriter agreement for the Rimrock Core Bond Fund. Foreside is a registered broker-dealer established for the purpose of providing marketing and distribution of both private –46– and public funds. Foreside does not trade securities nor provide pricing services to Rimrock. Foreside is not owned by Rimrock. Several Rimrock employees are registered representatives of Foreside. Foreside is compensated by Rimrock for distribution of the Private Funds through a flat fee arrangement. Rimrock has entered into a services agreement with Ueda Yagi, a Japanese registered financial services firm located in Tokyo, Japan. Ueda Yagi and Rimrock entered into the agreement in order for Ueda Yagi to perform services such as consulting about business development, translating documents and presentations, as well as arranging meetings with potential Japanese investors for Rimrock Funds. The compensation for Ueda Yagi’s services is paid through a fee sharing arrangement from assets raised in Japan. Rimrock has created additional feeder funds, Rimrock High Income PLUS (JPY) Trust, Rimrock Low Volatility (QP) (JPY) Trust, and Rimrock Structured Product (JPY) Trust, all Yen denominated feeder funds, for Japanese investors. please register to get more info

An investment adviser who is deemed to have “custody” of client funds or securities is subject to significant reporting and regulatory requirements that are not applicable to an investment adviser who does not have custody. An investment adviser has “custody” of client funds or securities, as defined in Rule 206(4)-2 of the Investment Advisers Act, when it holds “directly or indirectly, client funds or securities or has any authority to obtain possession of them.” Under Rule 206(4)-2, an investment adviser will be deemed to have custody of a client’s funds and securities if the client is a partnership for which the investment adviser serves as the client’s general partner. An investment adviser also is deemed to have custody under the Rule if the investment adviser has any arrangement under which the investment adviser is authorized or permitted to withdraw client funds or securities (including its fees) directly from the client’s account. Accordingly, Rimrock is deemed to have custody of Fund client assets by virtue of the Firm’s dual role as investment manager and general partner of the domestic Rimrock Funds, the affiliation of an associated person as a director for the offshore Rimrock Funds, and Rimrock’s ability to cause the deduction of its fees. Custody of the assets of the Funds is maintained with an independent, qualified custodian selected by Rimrock at our discretion, which selection may change from time to time. The custodian directly provides clients with monthly statements reflecting capital account balances. Additionally, an independent public accountant that is registered with, and subject to, regular inspection by the Public Company Accounting Oversight Board provides an annual audit report that is distributed to clients. We do not maintain physical possession of the funds or securities of any Fund or Managed Account. The qualified custodian is restricted from making payments to us or our affiliates from any account maintained by the custodian on behalf of a Fund unless certain requirements are met. For Managed Accounts, the client hires an independent custodian for the account. In Rimrock’s standard investment management agreement and in any third-party forms used by Rimrock, the Firm allows each client to choose whether to authorize direct billing or to pay for services separately pursuant to invoices provided by Rimrock. In each case where Rimrock bills a client’s account directly, through the client’s custodian or representative, Rimrock follows established procedures. Rimrock’s ability to make disbursements or transfers in connection with Managed Accounts is limited to instances of authorized trading and other circumstances where Rimrock has no discretion as to the timing, amount, or recipient of disbursements or transfers. In addition, Rimrock’s authority to give such instructions is limited to “delivery versus payment” conditions, where transfers out of the account occur only upon corresponding transfer of securities or funds into the account. The custodian provides the Managed Account client with monthly account statements. –47– please register to get more info

Rimrock has sole and complete discretion to manage the Private Funds’ investment portfolios. Rimrock has sole discretion as well to manage Rimrock Managed Accounts and the Rimrock Core Bond Fund, though those portfolios are subject to required regulatory or negotiated investment guidelines. Generally, Rimrock does not accept instructions from clients with respect to investments by or for their accounts. Managed Account clients can impose reasonable restrictions on investing in certain securities or types of securities. Clients with Managed Accounts can also negotiate other terms with Rimrock. Rimrock Managed Account restrictions and terms are formalized in advisory agreements with Rimrock. Clients’ investment guidelines and restrictions must be provided to and agreed with Rimrock in writing, in the form of an investment management agreement. please register to get more info

Proxy Voting Rimrock acts as discretionary investment adviser for the Rimrock Funds and Managed Accounts. Rimrock’s current investment strategies are heavily focused on fixed income securities. Rimrock occasionally purchases equity securities, and clients may receive equity securities in connection with reorganizations, which may require voting of proxies. Rimrock has adopted policies and procedures to address proxy voting. Rimrock’s authority to vote proxies or act with respect to other corporate actions is established through the delegation of discretionary authority under our investment advisory contracts. Therefore, unless a client specifically reserves the right, in writing, to vote its own proxies or to take actions with respect to other corporate actions requiring shareholder or debtholder approval, Rimrock will vote all proxies and act on all other shareholder or debtholder actions in a timely manner as part of its full discretionary authority over client assets in accordance with its policies and procedures. Corporate actions may include, for example and without limitation, tender offers or exchanges, acquisitions, spin-offs, bankruptcy proceedings, and class actions. When voting proxies or acting with respect to corporate actions for clients, Rimrock’s utmost concern, and its policy, is that all decisions be made solely in the best interests of the client. Given Rimrock’s focus on fixed income securities, Rimrock generally does not receive many proxies. When a proxy is received, normally the decision on how to vote a particular proxy is made by the portfolio managers for the relevant Fund or Managed Account. Rimrock seeks to identify and disclose any conflicts of interests identified with respect to proxy voting in general and any particular proxy vote. Rimrock seeks to act in a prudent and diligent manner intended to enhance the economic value of the assets of the client’s account. Rimrock will provide to any client or investor in a client account at no cost a copy of its proxy voting policy and information about the way in which proxies have been voted. Requests for such information should be directed to Rimrock’s Chief Compliance Officer. please register to get more info

Rimrock, as a registered investment adviser, is required to provide investors with certain financial information or disclosures about Rimrock’s financial condition. Rimrock has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding.
Additional Items: Attached below is Rimrock’s Privacy Notice.
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PRIVACY NOTICE
Maintaining the confidentiality and security of your personal financial information is very important to us at Rimrock Capital Management, LLC (“Rimrock”). INFORMATION WE COLLECT. To provide you with superior service, we may collect several types of nonpublic personal information about you, including:
• Information from forms you fill out and send to us in connection with your investment in one of our funds (such as your name, address, and social security number).
• Information you give us verbally.
• Information you submit to us in correspondence, including emails.
• Information about the amounts you have invested in our funds (such as your initial investment and any additions to and withdrawals from your capital account).
• Information about any bank account you use for transfers between your bank account and your capital account in any of our funds, including information provided when effecting wire transfers. INFORMATION WE SHARE. We do not sell your personal information and we do not disclose it to anyone except as permitted or required by law. For example, we may share information we collect about you with our independent auditors in the course of the annual audit of the fund in which you have an investment. We may share this information with our legal counsel as we deem appropriate and with regulators. Additionally, we may disclose information about you at your request (for example, by sending duplicate account statements to someone you designate), or as otherwise permitted or required by law. INFORMATION SECURITY. Within Rimrock, access to information about you is restricted to those employees who need to know the information to service your account. Rimrock employees are trained to follow our procedures to protect your privacy and are instructed to access information about you only when they have a business reason to obtain it.
PRIVACY NOTICE FOR DATA SUBJECTS WHOSE PERSONAL INFORMATION MAY BE
COLLECTED IN THE EUROPEAN UNION:
EU GENERAL DATA PROTECTION REGULATION (“GDPR”). With regard to personal information collected in the European Economic Area (EEA) Rimrock lacks an office in any EEA country and offers investment management products and services only to institutional investors in the EEA. However, through its investor subscription forms, websites, emails, and other communications with investors, Rimrock collects and stores personal information on officers, employees, and representatives of entity investors. Because Rimrock has no established office in the EEA, it must potentially deal with local supervisory authorities in all E.U. states where it has business. In addition, information that we collect may be transferred outside of the EEA, including to countries, such as the United States and the Cayman Islands, which have not been deemed as having “adequate” security measures by the European Commission. Therefore, we have executed or intend to execute Model Clauses in our contracts, pursuant to European –49– Commission Decision 2010/87/EC, to facilitate the legitimate, secure transfer of personal information outside the EEA as necessary. CAYMAN ISLANDS DATA PROTECTION LAW, 2017 (“DPL”). By virtue of making an investment in a Cayman Islands Fund and your associated interactions with us, you will provide us (including by submitting subscription documents, tax forms and associated documents and in correspondence and discussions with us) certain information that constitutes “personal data” under the DPL. PERSONAL INFORMATION. Personal information that may be collected by us from data subjects in the EEA, and information which constitutes “personal data” under the DPL, includes, without limitation:
• Name
• Address
• Phone Number
• Email Address
• Names of Beneficial Owners
• Tax ID Number
• Place of Birth or Incorporation
• Whether an Investor is an “Accredited Investor” and “Qualified Purchaser”
• Contact Information for Individuals Receiving Duplicate Reports and “Interested Parties.” LAWFUL GROUNDS TO PROCESS AND OBTAIN CONSENT. As a regulated financial services entity, Rimrock is required to collect, review and store private information about investors, clients, and their representatives. Based on our obligations and business needs, we may collect information for a variety of reasons, including, but not limited to, the following:
• Determining whether a prospective investor is eligible to invest in the Fund under applicable law;
• Determining the identity and beneficial ownership of investors and clients to comply with requirements seeking to prevent money laundering, tax evasion, terrorism and violation of foreign sanctions, and identity theft;
• Determining the persons authorized to act on behalf of an investor or client who can give instructions to Rimrock.
• Determining whether an investor or client is subject to specific investment regulations related to a specific type of person or organization (e.g., ERISA plans, governmental entities);
• Communicating with clients and investors about their existing and prospective investments or accounts. Data subjects whose data is collected in the EEA or whose data is subject to the DPL may withdraw consent at any time where consent is the lawful basis for processing his/her information. However, if a data subject withdraws consent for processing or otherwise objects to processing that impedes Rimrock’s ability to comply with applicable regulations, a data subject may be unable to avail him/herself of the services that Rimrock provides. Rimrock keeps the above-referenced client and investor information for as long as its relationship with the client or investor continues, and for a minimum of five years after termination. DATA SUBJECTS’ RIGHTS. All individuals whose personal information is held by Rimrock have the right to: –50–
• Ask what information Rimrock holds about them and why;
• Ask for a copy of such information or access to such information;
• Be informed how to correct or keep that information up to date;
• Be informed on how Rimrock is meeting its data protection obligations. Furthermore, for data collected in the EEA, or data which is subject to the DPL, data subjects have the right to:
• Ask for a copy of such information to be sent to a third party;
• Ask for data to be erased if possible and required under the GDPR or the DPL, as applicable;
• Ask for processing of personal information to be restricted if possible and required under GDPR or the DPL, as applicable;
• Object to processing of personal information if possible and required under GDPR or the DPL, as applicable;
• Object to automated decision-making where applicable;
• Contact a supervisory authority in the EEA or the Cayman Islands to lodge a complaint regarding Rimrock’s processing of your personal data. RESPONSIBILITY. Rimrock’s Chief Compliance Officer (the “CCO”) is also Rimrock’s Data Protection Officer, responsible for reviewing, maintaining and enforcing these policies and procedures to ensure meeting Rimrock’s client privacy goals and objectives while at a minimum ensuring compliance with applicable federal, state, and foreign laws and regulations. The CCO reports directly to Rimrock’s Principals and the Board of Directors of the Funds. The CCO is also responsible for distributing these policies and procedures to employees and conducting appropriate employee training to ensure employee adherence to these policies and procedures. All Supervised Persons are responsible for helping to ensure that investor and client private information is collected, used, stored, and handled in accordance with Rimrock policy. PROCEDURE. Rimrock has adopted these various procedures, applicable to its business practice and those of its affiliates, including each Fund’s general partner or directors. These procedures are designed to (1) ensure the confidentiality of customer records and information, (2) protect against any anticipated threats or hazards to the security of customer records and information, and (3) protect against unauthorized access or use of customer records or information that could result in substantial hardship or inconvenience to any consumer. NON-DISCLOSURE OF INFORMATION. Rimrock and its affiliates maintain safeguards to comply with federal and state standards to guard each client’s and investor's nonpublic personal information. The Firm does not share any nonpublic personal information with any nonaffiliated third parties, except in the following circumstances:
• As necessary to provide the service that the client or investor (by virtue of subscribing to the Fund’s interests) has requested or authorized, or to maintain and service the client’s or investor's account;
• As required by regulatory authorities or law enforcement officials who have jurisdiction over Rimrock and its affiliates or as otherwise required by any applicable law; and
• To the extent reasonably necessary to prevent fraud and unauthorized transactions. –51– Employees are prohibited, either during or after termination of their employment, from disclosing nonpublic personal information to any person or entity outside Rimrock, including family members, except under the circumstances described above. An employee is permitted to disclose nonpublic personal information only to such other employees who need to have access to such information to deliver our services to the client or investor. SECURITY AND DISPOSAL OF INFORMATION. Rimrock restricts access to nonpublic personal information to those employees who need to know such information to provide services to our clients or investors. Any employee who is authorized to have access to nonpublic personal information is required to keep such information in a secure compartment or receptacle on a daily basis as of the close of business each day. All electronic or computer files containing such information shall be secured and protected from access by unauthorized persons. Any conversations involving nonpublic personal information, if appropriate at all, must be conducted by employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations. Electronic and paper records used for business purposes must not be left in places where they are visible to unauthorized persons. Data printouts and files must be disposed of securely when no longer needed. Safeguarding standards encompass all aspects of Rimrock’s business that affect security. This includes not just computer security standards but also such areas as physical security and personnel procedures. Important safeguarding standards the Firm has adopted include:
• Access controls on information systems, including controls to authenticate and permit access only to Supervised Persons and procedural controls to prevent employees from providing client/investor information to unauthorized individuals who may seek to obtain this information through fraudulent means (e.g., requiring employee use of user ID numbers and passwords, etc.);
• Access restrictions at physical locations containing customer information, such as buildings, computer facilities, and records storage facilities to permit access only to authorized individuals (e.g., key card entry system);
• Encryption of electronic customer information, including while in transit or in storage on networks or systems to which unauthorized individuals may have access;
• Monitoring systems and procedures to detect actual and attempted attacks on or intrusions into customer information systems (e.g., data should be auditable for detection of loss and accidental and intentional manipulation);
• Policy to respond as appropriate when the Firm suspects or detects that unauthorized individuals have gained access to customer information systems, including, as appropriate, notifying applicable regulatory and law enforcement agencies;
• Measures to protect against destruction, loss, or damage of customer information due to potential environmental hazards, such as fire and water damage or technological failures (e.g., use of fire resistant storage facilities and vaults; backup and store off site key data to ensure proper recovery); and
• Information systems security should incorporate security of physical facilities and personnel, the use of commercial or in-house services (such as networking services), and contingency planning. RIMROCK CONTACT INFORMATION FOR PERSONS LOCATED WITHIN THE EEA. If you are located in the European Economic Area (“EEA”) or Switzerland and have questions or concerns regarding the processing of your personal information, you may contact our EU Representative at: Rimrockcapital@sallbergco.se –52– Or write to us at: Attn: Sällberg & Co Bankgatan 1A, 223 52 Lund, Sweden CONTACT INFORMATION FOR THE CAYMAN ISLANDS OMBUDSMAN
Under the DPL, you have the right to complain to the Cayman Islands Ombudsman, who may be
contacted by email (info@ombudsman.ky), telephone (+1 345 946 6283) or post (PO Box 2252, Grand
Cayman KY1-1107, Cayman Islands).
CHANGES TO OUR PRIVACY POLICY. We reserve the right to change our privacy policy in the future, but we will not disclose your nonpublic personal information as required or permitted by law without giving you an opportunity to instruct us not to.
QUESTIONS. For questions about our privacy policy, or for additional copies of this notice, please
call us at (949) 381-7800 or ir@rimrockcapital.com. please register to get more info