A. Silver Creek Advisory Partners LLC (previously defined as “Silver Creek”) was formed on March 19, 2010 as a Delaware limited liability company, and has been registered as an investment adviser with the SEC since January 4, 2012. Silver Creek’s affiliated management company is Silver Creek Capital Management LLC (“Silver Creek Capital”), whose founders have managed private investment funds since 1994. Silver Creek Capital was organized in 1999 as a successor entity to manage other private investment funds in addition to the original fund established by Silver Creek Capital’s founders in 1994. Silver Creek was organized to manage private investment funds launched after March 19, 2010 as well as one private investment fund that was managed by Silver Creek Capital prior to January 1, 2014 (as further described below).

Silver Creek provides discretionary investment supervisory services to private investment funds (the “Funds,” which definition includes any Fund that may be launched in the future) that invest in other affiliated or unaffiliated private investment funds, accounts and/or securities (the majority of the Funds are commonly known as “funds of hedge funds”). Subject to any applicable investment restrictions specific to a Fund, Silver Creek may pursue a Fund’s investment objectives by: (a) investing assets of the Fund in pooled vehicles (“Pooled Vehicles”) managed by third-party managers (“Advisors”); (b) engaging Advisors to manage accounts or assets on behalf of the Fund or affiliated holding companies (“Managed Accounts” and, together with Pooled Vehicles, “Sub-Funds”), which Managed Accounts may invest in private investment funds, securities and/or real assets; (c) taking direct securities positions for hedging purposes and for investment purposes; and/or (d) investing in real assets, including, without limitation, timberland, and aggregate reserves. Silver Creek also provides non-discretionary investment management services to a third-party unaffiliated client pursuant to an investment advisory agreement (the “Advisory Client”).

This brochure provides clients with information about the qualifications and business practices of Silver Creek and its advisory services. The information in this brochure has not been approved or verified by the SEC or by any state securities authority. Any representation to the contrary is illegal. Additional information about Silver Creek is available on the Internet at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for Silver Creek is 156667. Clients should be aware that the term “Registered Investment Adviser” does not imply any particular level of skill or training.

The direct principal owner of Silver Creek is Dillon/Flaherty Investments, Inc. (“DFI”).

B. Types of Advisory Services Offered

Discretionary Services

Silver Creek provides discretionary investment supervisory services, defined as giving continuous advice to a client or making investments for a client based on the individual needs of the client. Silver Creek provides these services to certain Delaware limited partnerships, Delaware limited liability companies, Cayman Islands exempted companies, and Cayman Islands exempted limited partnerships of which Silver Creek is the investment manager. Silver Creek expects to launch, operate and manage additional U.S. onshore and non-U.S. offshore Funds in the future. The Funds are not required to register as investment companies under the Investment Company Act of 1940, as amended (the “Investment Company Act”) in reliance upon an exemption available to funds whose securities are not publicly offered. Silver Creek manages the Funds on a discretionary basis in accordance with the investment objectives, terms and conditions of each Fund's offering and organizational documents. Silver Creek employs investment
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strategies through the Funds that are suitable for sophisticated investors with substantial net worth and who are able to bear the risks of the strategies employed. Investors should be aware of the substantial risks associated with investing in the Funds, many of which are described in the offering documents of the respective Funds. Investors should refer to each Fund's confidential offering memorandum for
eligibility requirements, risks, redemption terms, fees, other terms and conditions, conflicts of
interest and other important information.
Silver Creek has created a number of holding entities (the “Master Funds”) that invest in Pooled Vehicles or Managed Accounts not under common control with Silver Creek, as well as taking trading positions directly from time to time at the discretion of Silver Creek. The owners of the Master Funds are the Funds (the “Feeder Funds”) or, in certain cases, other Master Funds. The Master Funds serve to invest the Funds’ assets on a pooled basis, thus benefitting the investors in the Funds through economies of scale and trading efficiencies as well as greater diversification. Feeder Funds may invest in one or more Master Funds, although each has the ability to invest directly in other hedge funds and/or individual securities. To the extent that Silver Creek receives any management or performance fees, performance allocations or other compensation from the Master Funds, Silver Creek does not receive such compensation items from such Master Funds’ corresponding Feeder Funds. The Funds and the Master Funds utilize the services of an administrator, the fees of which the Funds bear their respective pro-rata share.

The Funds and Master Funds are authorized to implement their investment strategies by causing their assets to be invested in one or more investment vehicles (each, an “Investment Vehicle”) that are organized by Silver Creek to address tax, administrative or other issues. Each Investment Vehicle utilizes the services of Silver Creek or an affiliate thereof to invest and reinvest assets of such Fund. Silver Creek does not receive any fees or other compensation from such entities.

Funds Primary Investors

1. Silver Creek Core Strategies, Ltd………………………………...Non-U.S. and tax exempt investors 2. Silver Creek Credit Opportunities I Fund A, L.P………………...Non-U.S. and tax exempt investors 3. Silver Creek Credit Opportunities II Fund A, L.P………………..Non-U.S. and tax exempt investors 4. Silver Creek Credit Opportunities III Fund B, L.P……………... .Non-U.S. and tax exempt investors 5. Silver Creek Credit Opportunities IV Fund A, L.P……………... .Non-U.S. and tax exempt investors 6. Silver Creek Credit Opportunities IV Fund B, L.P……………….Non-U.S. and tax exempt investors 7. Silver Creek Credit Opportunities V Fund B, L.P……………… . Non-U.S. and tax exempt investors 8. Silver Creek Custom Opportunistic Debt Fund, L.P.……………. Non-U.S. and tax exempt investors 9. Silver Creek Custom Platform Opportunities, L.P. ……………....Non-U.S. and tax exempt investors 10. Silver Creek Custom Platform Opportunities 2, L.P. …………….Non-U.S. and tax exempt investors 11. Silver Creek FCOIII Cayman, L.P………………………………. Non-U.S. and tax exempt investors 12. Silver Creek FCOIV Cayman, L.P………………………………. Non-U.S. and tax exempt investors 13. Silver Creek GL-MSC Fund, L.P…………………………………Non-U.S. and tax exempt investors 14. European NPL Partners Fund, L.P.……………………………… Non-U.S. and tax exempt investors 15. DFP Fund, L.P…………………..………………………………………………U.S. taxable investors 16. Silver Creek Prime, L.P. ………….…..…………………………………….......U.S. taxable investors 17. Silver Creek Prime Cayman, L.P. ………………………………. Non-U.S. and tax exempt investors 18. Twin Creeks Timber, LLC .……..……………. U.S. taxable investors and U.S. tax exempt investors 19. Silver Creek Aggregate Reserves Fund I, LLC . U.S. taxable investors and U.S. tax exempt investors
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Master Funds 1. Silver Creek Credit Opportunities I A Master Fund, L.P. 2. Silver Creek Credit Opportunities II A Master Fund, L.P. 3. Silver Creek Credit Opportunities III B Master Fund, L.P. 4. Silver Creek Credit Opportunities IV A Master Fund, L.P. 5. Silver Creek Credit Opportunities IV B Master Fund, L.P. 6. Silver Creek Credit Opportunities V B Master Fund, L.P. 7. Silver Creek Custom Opportunistic Debt Master Fund, L.P. 8. Silver Creek Custom Platform Opportunities Master Fund, L.P. 9. Silver Creek Custom Platform Opportunities 2 Master Fund, L.P. 10. Silver Creek Prime Master, L.P.

Investment Vehicles

1. Silver Creek CS SAV, L.L.C. 2. Silver Creek IGC Cayman, L.P. 3. Silver Creek Custom Opportunistic Debt Fund, Ltd. 4. Silver Creek Custom Platform Opportunities, Ltd. 5. Silver Creek Custom Platform Opportunities 2, Ltd.

Other Entities

Silver Creek Credit Opportunities Cayman GP, Ltd. (“COGP”), a Cayman Islands exempted limited company, is the general partner of Silver Creek Credit Opportunities I Fund A, L.P., Silver Creek Credit Opportunities II Fund A, L.P., Silver Creek Credit Opportunities III Fund B, L.P., Silver Creek FCOIII Cayman, L.P., Silver Creek FCO IV Cayman, L.P. and Silver Creek GL-MSC Fund, L.P. COGP is a wholly owned subsidiary of Silver Creek.

Silver Creek Credit Opportunities I-III GP, L.L.C. (“CO1-3GP”), Silver Creek Credit Opportunities II GP, L.L.C. (“CO2GP”), Silver Creek Credit Opportunities IV GP, L.L.C. (“CO4GP”), Silver Creek CPO GP, L.L.C. (“CPO GP”) and Silver Creek Prime GP, L.L.C. (“Prime GP”) are all Delaware limited liability companies which are wholly owned subsidiaries of Silver Creek. CO1-3GP is the general partner of Silver Creek Credit Opportunities I A Master Fund, L.P. and Silver Creek Credit Opportunities III B Master Fund, L.P. CO2GP is the general partner of Silver Creek Credit Opportunities II A Master Fund, L.P. CO4GP is the general partner of Silver Creek Credit Opportunities IV Fund A, L.P., Silver Creek Credit Opportunities IV A Master Fund, L.P., Silver Creek Credit Opportunities IV Fund B, L.P., Silver Creek Credit Opportunities IV B Master Fund, L.P., Silver Creek Custom Opportunistic Debt Fund, L.P., Silver Creek Custom Opportunistic Debt Master Fund, L.P. and Silver Creek IGC Cayman, L.P. CPO GP is the general partner of Silver Creek Custom Platform Opportunities, L.P., Silver Creek Custom Platform Opportunities Master Fund, L.P., Silver Creek Custom Platform Opportunities 2, L.P. and Silver Creek Custom Platform Opportunities 2 Master Fund, L.P. Prime GP is the general partner of Silver Creek Prime, L.P., Silver Creek Prime Cayman, L.P. and Silver Creek Prime Master, L.P. Silver Creek is affiliated with Dillon/Flaherty Investments, Inc. (“DFI”), one of whose control persons is also a control persons of Silver Creek. DFI is the general partner of DFP Fund, L.P. (“DFP”) and has engaged Silver Creek as an investment adviser to DFP.
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Silver Creek is affiliated with Silver Creek Capital, certain of whose control persons are also control persons of Silver Creek. Silver Creek provides Silver Creek Capital with the personnel and infrastructure to enable Silver Creek Capital to perform its duties to the private investment funds it manages. Silver Creek has also agreed to provide investment research, advice and due diligence to Silver Creek Capital. Silver Creek Capital is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The CRD number for Silver Creek Capital is 122966. Non-Discretionary Services Silver Creek also provides non-discretionary investment supervisory services, defined as giving continuous advice to a client or making investments for a client based on the individual needs of the client on a non- discretionary basis. Silver Creek provides these services to a third-party, unaffiliated client pursuant to an investment advisory agreement (previously defined as the “Advisory Client”).

C. Silver Creek provides advisory services to the Funds and the Advisory Client according to the specific investment objectives, terms and conditions contained in the relevant Fund’s offering documents and organizational documents and the Advisory Client’s investment advisory agreement, as applicable. Please refer to Item 16 of this brochure entitled “Investment Discretion” for further information.

D. Not applicable.

E. As of January 31, 2019, Silver Creek manages approximately $4,063,420,192, and together with the client assets of Silver Creek Capital, Silver Creek and Silver Creek Capital manage client assets of approximately $4,687,296,848. As of the same date, Silver Creek manages approximately $15,284,994 on a non-discretionary basis. The foregoing data is calculated on a different basis than the regulatory assets under management reported in Silver Creek’s Form ADV Part 1 and is presented on the following basis: 1) net of investments made in certain Funds by other affiliated Funds; 2) net of fees (both Management Fees and Performance Fees as defined below) and expenses; and 3) includes only contributed capital, not the amount of any uncalled commitments. For information on Silver Creek’s regulatory assets under management as well as the gross asset value of each Fund, please refer to Silver Creek’s Form ADV Part 1A. please register to get more info

A. Silver Creek is paid fees for the portfolio management of the Funds (the "Management Fees"), which are calculated and paid as a percentage of the net asset value of the investors' interest in the Funds. The Management Fees range from 0% to 1.00% and vary by Fund and by class of interest within each Fund. Management Fees are subject to waiver, refund and/or modification by separate agreement with Silver Creek. In addition, the Funds may pay Silver Creek performance-based compensation ("Performance Fees") either in the form of incentive allocations, carried interest or performance fees. The Performance Fees range from 0% to 10% and vary by Fund and by class of interest within each Fund. Performance Fees are subject to waiver, refund and/or modification by separate agreement with Silver Creek. For certain Funds and classes of interests, the Performance Fees are calculated based on a percentage of the net profits of the Funds at the end of each fiscal year or when Fund distributions are made. In measuring an investor's net profits for the calculation of such Performance Fees, Silver Creek may include both realized and unrealized gains and losses during the relevant period, unless the relevant offering documents provide otherwise. For certain Funds and classes of interests, the Performance Fees are calculated based on a percentage of amounts
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distributed in excess of hurdle. The calculation and payment of the Performance Fees applicable to a particular interest in a Fund is described in detail in the relevant offering documents for such interest. As compensation for services provided by Silver Creek, Silver Creek receives from an Advisor a portion of the management and incentive fees payable by certain Funds with respect to such Funds’ investment in a Sub Fund managed by such Advisor. This arrangement is disclosed in the Fund’s offering documents and is in lieu of fees that would otherwise be payable by the Fund to Silver Creek.

Certain of the Funds have entered into arrangements with certain of their investors, including Silver Creek affiliates, to waive, refund and/or modify the Management Fee and /or Performance Fee otherwise due with respect to investment in such Fund.

The Advisers Act and certain state laws restrict the payment of performance-based fees, such as the Performance Fees, to investment advisers registered under such act. However, SEC Rule 205-3 permits the payment of performance-based compensation to registered investment advisers provided that the clients (including investors in investment vehicles such as the Funds) meet certain financial qualifications. The offerings of interests in the Funds are structured to comply with this rule and accordingly the Funds will only accept subscriptions from investors who meet the qualifications set forth in Rule 205-3.

Since the Funds typically invest in other, unaffiliated, pooled investment vehicles or managed accounts that themselves pay advisory fees to their respective Advisors (including, without limitation, fees based on a percentage of assets under management and performance-based compensation), investors in the Funds will bear a proportionate share of these fees in addition to those paid to Silver Creek by the Funds.

Silver Creek is also paid fees for the investment management of the Advisory Client (the “Advisory Fees”), which are calculated and paid as a percentage of the fair value of the investments in the Advisory Client account plus a variable amount that is dependent on the fee being charged by the underlying investment. The Advisory Fees are generally 0.50% plus such variable amount up to a maximum fee of 0.65%.

B. For all Funds, Silver Creek is authorized to deduct fees from the Fund’s assets. Where applicable, Management Fees are taken on a quarterly basis and Performance Fees are taken on an annual basis or allocated in accordance with the terms of each respective Fund. Silver Creek bills the Advisory Client for its Advisory Fees on a quarterly basis.

C. Each Fund generally pays for the organizational expenses of the Fund and expenses of the initial offering of interests, including, without limitation, legal, accounting and compliance consulting fees and expenses. In addition, each Fund generally pays for all other ordinary and extraordinary expenses incurred on the Fund’s behalf including, without limitation, all legal, compliance, audit, accounting and reporting expenses; Management Fees and Performance Fees payable to Silver Creek; management fees, performance fees and performance allocations payable to Advisors and other investment expenses; fees, costs and indemnification of any administrator, valuation agent, consultant or other service provider appointed by the Fund; expenses related to the acquisition, holding and disposition of investments including, without limitation, fees of custodians; research expenses; trading fees and commissions; liability insurance costs; costs of indemnifying the Fund’s control persons such as board members, Silver Creek Capital and Silver Creek (including, without limitation, litigation costs and expenses and the costs and expenses associated with responding to regulatory exams related to the Fund); taxes; other expenses incidental to the Fund’s operations; and other charges and costs of the Fund’s operations. Funds may also pay for expenses related to compliance consulting. Expenses may be advanced by Silver Creek and reimbursed by the Fund. All investors in the Fund will bear their pro rata share of the Fund’s expenses; provided that any expense that is directly attributable to a particular Fund investor may be allocated solely to such Fund investor in Silver
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Creek’s discretion. In the event an Investment Vehicle is established with respect to a Fund, such Fund will bear its pro rata share of expenses of such Investment Vehicle. Pursuant to an agreement with investors in a certain Fund, Silver Creek has agreed to reimburse the Fund for any shortfall as a result of the application of an expense limit. To the extent that expenses are allocable amongst and/or between Funds, Silver Creek and any Silver Creek affiliate, such expenses are calculated by Silver Creek and generally allocated pro rata to the entities involved based on net asset value or otherwise as determined to be equitable by Silver Creek in its discretion.

For further information regarding the expenses involved in an investment in the Funds, please refer to the section of the offering documents of the relevant Fund entitled “Expenses.”

D. Management Fees and Advisory Fees are typically charged quarterly in advance. An investor who makes a redemption from a Fund before the end of the billing period will receive a refund calculated based on the value of the amount redeemed from the Fund and the number of days remaining prior to the end of the billing period. To the extent the investment advisory agreement with the Advisory Client is terminated before the end of a quarter, the Advisory Fees shall be payable on a pro rata basis for the period of the quarter for which Silver Creek served as the investment adviser for the Advisory Client.

E. Not applicable.

1. Not applicable.

2. Not applicable.

3. Not applicable.

4. Not applicable. please register to get more info

Please refer to Item 5 and the risks disclosed in Item 8 of this brochure for information regarding performance-based fees charged by Silver Creek. Silver Creek only provides investment supervisory services to the Funds. Most of the Funds which charge fees include both Management Fees and performance-based fees. One Fund charges only a Management Fee. please register to get more info

Please refer to Item 4 for a description of the Funds for which Silver Creek provides services. The Funds are only offered to prospective investors that qualify as accredited investors (as that term is defined for purposes of Rule 501 of Regulation D under the Securities Act of 1933, as amended (the “Securities Act”) and qualified purchasers (as that term is defined for purposes of Section 2(A)(51) of the Investment Company Act) (or knowledgeable employees, as permitted under Rule 3c-5 of the Investment Company Act), for purposes of the application of Section 3(C)(7) of the Investment Company Act. Investors in the Funds generally include high net worth individuals, trusts, endowments, foundations, pension plans, retirement plans, corporations, individual retirement accounts, government plans and other institutional investors. The Advisory Client is a pension plan.
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Current and prospective investors in the Funds listed under Item 4 of this Part 2A Brochure should refer to the offering documents of the relevant Fund for information on minimum investment and minimum account size requirements. The current range of minimum investment requirements for the Funds is from $100,000.00 to $100,000,000.00 which may be reduced, waived or increased in Silver Creek’s discretion. please register to get more info

A. Methods of Analysis For purposes of this Item 8, the meaning of “Fund” does not include the Advisory Client. From time to time Silver Creek may present investment opportunities that it has identified to the Advisory Client. The Advisory Client is not required to make any particular investment.

Subject to any applicable investment restrictions specific to a Fund, Silver Creek may pursue a Fund’s investment objectives by (a) placing assets of the Fund in pooled vehicles (previously defined as “Pooled Vehicles”) managed by third-party managers (previously defined as “Advisors”), (b) engaging Advisors to manage separately managed accounts on behalf of the Fund or affiliated holding companies (previously defined as “Managed Accounts” and, together with Pooled Vehicles, previously defined as “Sub-Funds”), (c) taking direct securities positions for hedging purposes and for investment purposes and/or (d) investing in real assets, including, without limitation, timberland, and aggregate reserves. Sub-Funds will be managed by Advisors that meet the relevant Fund’s and Silver Creek’s selection criteria and whose investment strategies and performance are believed to be consistent with such Fund’s stated investment objective. Each Fund may invest in Sub-Funds which have limited exposure to other Sub-Funds. A Fund may hold interests in one or more Advisors of Sub-Funds in which the Fund also holds an interest.

Silver Creek may also directly or indirectly allocate the assets of a Fund in investments that may include, without limitation, the purchase and sale of derivative instruments such as futures, exchange-listed and over-the-counter put and call options on securities, financial futures, equity indices and other financial instruments, the purchase and sale of financial futures contracts and options thereon, credit default swaps, the taking of short positions in securities and other instruments, and derivative instruments that combine features of the foregoing instruments. Such investments may be made for purposes of hedging risk or speculation.

Silver Creek has adopted a Portfolio Management and Due Diligence Policy to help ensure that investments are adequately evaluated and reviewed and that each Fund’s portfolio is being managed according to its investment objectives. Silver Creek’s policies require periodic pre- and post-investment evaluations, portfolio risk management, liquidity management, and certain procedures for transactions with Silver Creek affiliates that may pose specific conflicts of interest. A copy of Silver Creek’s Portfolio Management and Due Diligence Policy will be provided to any investor or prospective investor upon request.

It is the responsibility of Silver Creek to identify and research potential Advisors, to evaluate the terms and conditions of the Sub-Funds they manage or, where relevant, to negotiate advisory agreements, and to allocate and reallocate a Fund’s assets among Advisors. Advisors are chosen on the basis of selection criteria established by Silver Creek, including an analysis of the Advisors’ performance during various time periods and market cycles and the Advisors’ reputation, experience, training and investment philosophy and policies. In addition, Silver Creek considers the Advisors’ internal controls and ability to provide timely and accurate reporting. In an effort to optimize its investment program, the Fund may allocate a portion of its capital to Advisors who lack historical track records but who, in Silver Creek’s judgment, offer exceptional potential.
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Silver Creek monitors Advisors on an ongoing basis and reviews the Advisors’ investment policies and philosophy regularly. The identity and number of Advisors is likely to change over time. Generally, Silver Creek will remove Advisors and appoint new Advisors without prior notice to or the consent of a Fund’s investors. Certain single-investor Funds have entered into arrangements with their investor to allow such investor the ability to review and veto Silver Creek’s recommendation to allocate Fund capital to a particular Advisor’s Sub-Fund.

Silver Creek uses a variety of proprietary and non-proprietary research models and methods and employs both qualitative and quantitative analysis. Silver Creek derives information from a wide variety of sources, including securities information services, reporting by fund managers, manager interviews and due diligence, periodicals, trade journals, research reports, industry contacts and professional advisers.

Silver Creek employs a top-down thesis on investment opportunities and strategies, as well as a bottom-up approach to Advisor research, due diligence, and monitoring. Silver Creek’s investment professionals begin by developing, researching, and vetting views on investment approaches, environments, and styles. Silver Creek’s investment professionals develop and articulate convictions that guide manager research and allocation processes, rather than focusing on macroeconomic events and trends. When evaluating a strategy, Silver Creek develops and tests theses to try to determine: (i) why a strategy has return potential, (ii) whether the return potential of the strategy is likely to become readily available to most market participants (also known as "beta"), and (iii) whether the return potential of the strategy is most likely attributable to the Advisor’s particular expertise in the strategy ("alpha"). Silver Creek’s goal is to seek out Advisors who demonstrate alpha and avoid or severely limit exposures to market beta and other unwanted risk exposures (or to seek Advisors whose beta Silver Creek considers to be uncorrelated with other exposures).

Once Silver Creek’s investment professionals have a top-down view of an opportunity set, they seek to identify and invest with the individual Advisors within the set whom they believe to have the greatest ability to deliver alpha. Silver Creek believes its process provides a competitive advantage due to the following factors: (i) Silver Creek’s investment professionals’ skill at assessing investment opportunities, (ii) Silver Creek’s extensive, longstanding and deep network in the alternative investment industry, and (iii) Silver Creek’s access to Advisors whom Silver Creek believes to be the most skilled and most innovative. Silver Creek utilizes its extensive investment experience, reputation and industry network to source investments. Silver Creek’s analytical framework narrows the scope of analysis to those Advisors, Sub-Funds and other investment opportunities that Silver Creek believes to be the most likely to have the ability to add value to Silver Creek portfolios, thus allowing Silver Creek to deeply understand such Advisors and their Sub-Funds or other investment opportunities.

In a typical year, Silver Creek’s Investment Committee members speak to Advisors who have been sourced through various channels, including publicly available databases, Silver Creek’s own proprietary databases, capital introduction teams, and third-party marketers. However, Silver Creek has found that the relationships and networks that have been developed by its investment professionals have been the most valuable asset for identifying attractive Advisors. Silver Creek tracks existing and prospective Advisors and Sub-Funds in an internal database that categorizes them based on strategy. A new investment involves an allocation to an investment style or opportunity, as well as to an Advisor’s specific approach. Silver Creek evaluates an investment decision from two perspectives: strategic and tactical. The strategic perspective seeks to identify whether and why a specific strategy has attractive, long- term return characteristics. From a tactical perspective, Silver Creek develops a view on an individual Advisor’s unique approach to risk premium extraction. This assessment then drives whether Silver Creek will seek to add the exposure via an investment in a hedge fund structure, via a negotiated separate account
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or via a co-investment. Although a particular strategy may be relatively unattractive when viewed in isolation, a particular Advisor may have a unique perspective or approach that appears to add value in the particular area. Silver Creek performs due diligence that is designed to evaluate the robustness of an Advisor’s internal processes, controls, and risk management. The elements of the due diligence process will vary depending on the Advisor’s strategy, structure, operations and processes. Silver Creek’s analysis may include, without limitation, an examination of portfolio management and operational controls, pricing policies, third-party relationships, terms and conditions of the investment, moral hazard, and background checks. Advisors are generally expected to provide Silver Creek and its Funds with annual, independently audited financial statements prepared generally in accordance with U.S. Generally Accepted Accounting Principles (GAAP), International Financial Reporting Standards or a comparable accounting standard.

In addition to the evaluation procedures and other review procedures described above and to the extent timberland real assets are under consideration, Silver Creek’s investment team, in conjunction with input from individuals from other applicable Silver Creek business groups, also examine the attributes of the timberland property and its geographical location and take such other steps as may be required by the relevant Fund’s constituent documents. Advisors for timberland real assets are generally requested to maintain and provide timberland property level information, including, without limitation, inventory information, geographical information system data and land records.

Investment decisions regarding new Advisors and/or Sub-Funds are generally made by the Investment Committee on a consensus basis. The Chief Investment Officer, as chair of the Investment Committee, may, however, make the final investment decision, with the exception of the operational due diligence team, which holds veto power with respect to any new, existing, or follow-on investments. After a new Sub-Fund is approved by the Investment Committee, each Portfolio Manager has the authority to, with respect to the portfolio(s) over which s/he has responsibility, determine whether to make an allocation to the approved Sub-Fund and if so, how much capital to allocate. An Investment Committee formed to oversee a specific Fund or Funds may consist of different members in addition to the Chief Investment Officer and such Investment Committee may adopt different rules to the extent that Silver Creek determines they are warranted based on the specific requirements of such Fund or Funds.

Once a decision has been made regarding a specific investment opportunity, various risk characteristics of the investment are factored into deciding how much capital will be committed to the position. Silver Creek attempts to gauge how the addition of the new position and its size may affect the overall risk profile of a Fund’s portfolio, including through the use of pre-established scenario analyses. Silver Creek also observes and monitors the macro exposures that have been shown to aggregate across various position allocations. As Silver Creek determines necessary, it will take corrective steps such as position rebalancing, hedging, and ongoing manager selection in order to help mitigate identified risks.

B. Investment Strategies and Risks of Loss Investment Strategies Silver Creek allocates the Funds’ assets according to the stated investment objective as described in the offering documents of each Fund. The Funds will employ Advisors who use a broad variety of investment styles and strategies. The following is a non-exclusive list of many of the types of strategies in which the Funds may invest from time to time. Each Fund may add, delete or modify such categories of investment strategies at the sole discretion of Silver Creek in order to pursue the investment objectives of the Funds.
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• Event Driven/Activist: An event-driven strategy involves long and short positions in securities of business entities when a specific event (merger, takeover, recapitalization, etc.) is anticipated to produce a change within a defined time period. Advisors employing an activist investment strategy use a stake in a company to redefine and redirect the management of that company. In order to implement any actions deemed necessary to maximize value, the Advisors may work with the management team of the target company or may initiate shareholder actions (including those that may be opposed by company management).


• Distressed Securities: This strategy involves investments in public and non-public debt and equity securities of companies in financial difficulty, reorganization or bankruptcy, or in non- performing or sub-performing bank loans. Portfolios of such securities are usually concentrated in debt instruments. Advisors of such portfolios may differ in their preference for actively participating in the workout and restructuring process and the extent to which they use leverage.


• Long/Short Equity and Quantitative Long/Short Equity: This strategy involves long and short investing in equity securities that are believed to be either undervalued or overvalued. Advisors employing this strategy may or may not attempt to neutralize the amount of long and short positions (i.e., may seek to be “market neutral” or may be net long or net short). Certain investment managers may specialize in a particular industry while others may diversify holdings across industries. Advisors using this strategy generally employ varying degrees of leverage. Some Advisors may rely primarily or exclusively on quantitative models rather than human insight to generate and/or implement trading ideas.


• Quantitative Equity Market Neutral: This strategy involves a quantitative and systematic approach to long and short investing in equity securities that are believed to be either undervalued or overvalued. Advisors using this strategy typically develop proprietary models and forecasts that incorporate inputs from extensive public and/or proprietary data libraries. These models and forecasts are then run through a proprietary optimizer to create a portfolio based on the mandate of the Fund. Advisors employing this strategy typically attempt to neutralize the amount of long and short positions in an effort to maintain beta neutrality to a selected targeted index (e.g., S&P 500 or MSCI World Index). Advisors employing these strategies often differentiate their approach based on the time horizon or predictive period (e.g., seconds, hours, days, weeks, or months) related to their forecast model. Strategies with shorter time horizons generally have higher turnover than strategies with longer time horizons. Advisors using this strategy generally employ varying degrees of leverage.
• Private Equity and Hybrid Funds: These strategies involve private equity-type investments but apply hedge fund skills in structuring and financing transactions and in governance and operations to their investments. Opportunities are sometimes available where it is possible to buy into high cash flow businesses that are backed by tangible assets but which are priced attractively relative to their book and/or believed fundamental value. Examples of sectors where these opportunities may be found include, without limitation, real estate, infrastructure, banking and finance, senior living, and energy production and distribution. Targeted opportunities will present the possibility of very attractive private equity-like exit events, but are believed to reduce downside risk because of the sound fundamentals and/or cash flows of the underlying businesses. These opportunities may exist because of a variety of factors with the issuer, such as mismanagement, poor capital structure, capital markets dislocation, privatizations, legal situations and rapid change in the industry. Successful investing in these
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opportunities requires a unique skill set, including expertise in mergers and acquisitions, structured finance, capital markets and operational excellence.
• Relative Value and Quantitative Relative Value: These strategies involve the simultaneous purchase and sale of similar securities to exploit pricing differentials. Relative value managers generally attempt to neutralize long and short positions to minimize the impact of general market movements. Different relative value strategies include convertible arbitrage, statistical arbitrage, credit arbitrage, pairs trading, yield curve arbitrage and basis trading. The types of instruments traded vary considerably depending on the Advisor’s arbitrage strategy. Since these strategies attempt to capture relatively small mispricings between two related securities, relative value Advisors often employ moderate to substantial leverage to increase rates of return. Some Advisors may rely primarily or exclusively on quantitative models rather than human insight to generate and/or implement trading ideas.


• “CTA”: Commodity trading advisors typically use quantitative and/or systematic trend- following algorithms to identify long-term and short-term trading opportunities in currency, commodity and financial markets. Typically, these investments are uncorrelated to those with a focus on more traditional investment vehicles (equities and fixed income instruments) and serve to diversify the Fund’s investments. CTA investments are typically directional in nature but extremely liquid and closely monitored within very tight trading bands. These strategies can run with moderate to substantial leverage.
• Quantitative Risk Premia Strategies: This strategy involves a quantitative and systematic approach to constructing a portfolio to target exposures to well-established and academic- researched risk premia factors (value, size, momentum, low volatility, dividend yield, and quality). This strategy can employ single asset classes (e.g., equities) or can involve multiple asset classes (fixed income, currency, futures, swaps, options, etc.). Strategies are generally run to maintain market neutrality, however at times an Advisor can choose to maintain a long or short-bias. Limits are generally in place around net exposure to positions, sectors and countries. These strategies can run with moderate to substantial leverage.


• Global Macro and Systematic Global Macro: This strategy involves using opportunistic approaches to take advantage of shifts in macro-economic trends. Advisors using this strategy will typically base their decisions on the expected rate of change of interest rates, inflation, economic cycles, etc. This strategy may involve trading in all markets, all asset classes (stocks, bonds, currencies, commodities, etc.) and all instruments (cash, futures, derivatives, etc.). These strategies can run with moderate to substantial leverage. Some Advisors may rely primarily or exclusively on quantitative models rather than human insight to generate and/or implement trading ideas.
• High Frequency Trading (“HFT”): This strategy involves the use of high frequency data, complex algorithms, systematic electronic trading tools to transact high volumes of trade orders in relatively short periods of time (i.e., seconds or fractions of a second). These trading strategies are often differentiated by close connectivity with public exchanges either through co-locating a data center or having a data center as close as physically and economically possible to an exchange’s data center.
• Quantitative and Systematic-Focused Multi-Strategy: This strategy represents Funds that principally use quantitative and systematic approaches as part of the Funds’ mandate. These entities will typically incorporate some or all of the aforementioned strategies and may or may
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not employ additional alternative investments strategies, including even non-quantitative or non-systematic strategies as part of its overall investment mandate.
• Sector Investing/Special Situations: These strategies involve investing in debt or equity of particular companies or specific sectors of the economy, such as technology, insurance, financial institutions and real estate. These strategies may combine elements of long/short, event driven and distressed strategies, though investments tend to be more opportunistic and concentrated and less dependent on a particular event or catalyst to realize value. These strategies may involve an active role for the Advisor, including possibly a management role with the underlying issuers, and typically require unusual expertise and expert judgment to be successful.


• Fixed Income: Fixed income trading involves the use of sophisticated and often multi- dimensional financial instruments with debt characteristics. Such financial products include but are not limited to straight debt instruments, futures, options, swap contracts and collateralized debt obligations. Traditional trades in this arena attempt to take advantage of mispriced instruments that provide similar risk exposures, changes in the slope of a given country’s yield curve, or mispricing due to inefficiently processed information.


• Natural Resources: In this strategy, Advisors apply financial trading techniques and fundamental analysis to markets for energy, natural resources, non-financial commodities and weather and other natural events. For example, Advisors may utilize trading techniques typically associated with relative value or global macro strategies in non-financial over the counter markets. This strategy is distinguished from CTA because trading signals are driven by fundamentals and not trend-following analytics.
• Unique Insurance Opportunities: This strategy involves supplying capital to well defined and potentially profitable segments of the insurance industry. These investments may offer attractive return series with loss events that are uncorrelated with events that commonly result in losses in other financial investments (for example, an insurance investment may be sensitive to generally uncorrelated weather events, whereas typical financial instruments are sensitive to financial market events which tend to be highly correlated). These investments may take the form of buying into pools of “catastrophe insurance” bonds which pay attractive premiums but which are not required to be repaid if certain loss events occur (such as weather events resulting in losses in excess of a specified amount). These investments may also involve investing in operating insurance and reinsurance businesses, in restructurings of existing insurance businesses, and in hybrid vehicles that combine the characteristics of a reinsurance business with more conventional hedge fund strategies. These investments may also include “life settlements”, which involves owning a portfolio of life insurance policies, and in “nonrecourse premium financing”, which involves providing short term premium financing for insureds in exchange for the right to receive the death benefit payment in certain circumstances.
• Asset Backed Loans: This strategy involves purchasing in secondary sales loans and debt securities of both public and private companies that are thought to be financially sound. These loans are typically secured, often by liens on physical assets of the borrowers. Loans are typically short term (less than eighteen months) and relatively senior in the borrowers’ capital structure (senior to equity and unsecured loans, but subordinate to senior secured debt).
• Asset Backed Loan Origination: This strategy involves originating asset backed loans directly to the borrower as opposed to buying such loans on secondary markets. Advisors and Sub-
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Funds using these strategies will generally complete the credit analysis, originate loans, and service the loan. Opportunities exist in this space because banks and other traditional lenders have greatly reduced their commercial finance operations after the credit crisis, consolidation and other institutional factors. Because of this, alternative sources of financing such as hedge funds have been able to step in and source transactions on attractive terms.
• Corporate Debt: This strategy involves the acquisition of interest bearing securities that obligate the issuing corporation to pay specified amounts on specified dates, with repayment of the principal at maturity. Investments in corporate debt typically offer higher interest rates to investors than government issued fixed income investments, and such interest rates can be significantly higher when issued by corporations with below average credit ratings and/or which are in distressed situations. Advisors will typically attempt to identify situations where the liquidation value of a corporation and/or its perceived creditworthiness is being undervalued by the marketplace, which will provide attractive returns in light of the Advisor’s opinion of the value of the corporation. Corporate debt securities may be publicly traded or be acquired through private offerings and secondary sales. Debt securities being acquired may include senior loans and/or senior corporate bonds as well as mezzanine or otherwise subordinated loans and/or securities.
• Accounts Receivable Financing: In this strategy, the Advisor provides short-term financing to a business using the business’s accounts receivable as security. The business is responsible for repaying the loan at maturity and collecting on its accounts receivable. The Advisor would only take possession of the accounts receivable if the borrower defaults on its obligation. In a variation of this strategy, called “factoring”, the Advisor would purchase accounts receivable from a business at a discount to face value and be responsible for collecting on such amounts. In another variation on this strategy, an Advisor will purchase trade claims at a substantial discount to face value from insolvent or otherwise distressed companies.
• Consumer Loans: This strategy typically involves participating in pools of loans made to consumers to finance the acquisition of personal property such as cars, appliances or other consumer goods. Such participation may occur through a variety of transactions and/or structures, including acquisitions in the secondary markets or securitizations of such loans (such as asset-backed securities), as described above.
• Corporate Debt: This strategy involves the acquisition of interest bearing securities that obligate the issuing corporation to pay specified amounts on specified dates, with repayment of the principal at maturity. Investments in corporate debt typically offer higher interest rates to investors than government issued fixed income investments, and such interest rates can be significantly higher when issued by corporations with below average credit ratings and/or are in distressed situations. Advisors will typically attempt to identify situations where the liquidation value of a corporation and/or its perceived creditworthiness is being undervalued by the marketplace, which will provide attractive returns in light of the Advisor’s opinion of the value of the corporation. Corporate debt securities may be publicly traded or be acquired through private offerings and secondary sales. Debt securities being acquired may include senior loans and/or senior corporate bonds as well as mezzanine or otherwise subordinated loans and/or securities.
• Real Estate Investing: This strategy involves participating in the financing of real estate acquisitions. Such participation may occur through a variety of transactions and/or structures, including the origination of such loans, acquisitions in the secondary markets or securitizations
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of such loans (such as mortgage-backed securities), as described above. Such investments may be made through secondary purchases of securities of distressed issuers as well as originations of new loans, both as described above. The Partnership may also indirectly (or in certain instances directly) participate in the equity of real estate assets, either as a result of foreclosures on real estate loans or through a strategy of directly acquiring, holding and selling real assets.
• Loan Origination/Trade Claims: This strategy targets investments in privately placed debt securities and/or trade claims with public and/or private companies. Advisors that originate loans complete the credit analysis, originate, and service the loan. Loans are typically short term (less than 18 months) and are typically collateralized with physical or other assets. Advisors investing in trade claims typically purchase securities out of bankruptcy courts at substantial discounts to eventual recoveries. Advisors in this strategy may employ leverage. The Fund is expected to participate in this strategy only to the extent the Investment Manager determines it can do so in what the Investment Manager believes is a relatively tax efficient manner.
• Private Distressed Debt Securities: This strategy involves investing in the debt or debt-linked securities of companies that are insolvent or otherwise in financial distress. Companies that do not have access to public capital markets and that are not healthy enough to obtain financing from a conventional lender will turn to alternative sources of capital. Advisors attempt to identify situations where assets are undervalued by the marketplace, resulting in a significant spread between fundamental and market value. Such undervaluation may be the result of many factors, including: (i) difficulties in conducting financial analysis on a troubled company; (ii) the presence of complex business situations, such as litigation; and (iii) the lack of reliable sources of third-party information, such as research reports. A distressed strategy may be deployed in a wide variety of structures, but typically an investor will take a substantial (often controlling) position in an issuer who is in financial distress. Investments typically are made in relatively senior instruments, but it is also common to take positions in equity or equity- linked securities in the hope of enhancing returns after the markets recognize the issuer has recovered. Advisors in this area will often take a substantial role in the management of the issuer in the hope of positively influencing a successful turnaround.
• Non-performing Loan Portfolios: This strategy involves buying portfolios of non-performing loans and other income streams from banks, insurance companies, leasing companies and other financial institutions. Financial institutions may hold substantial portfolios of loans and other obligations that are in default. These institutions are in many circumstances willing to sell these income streams at discounts to fundamental value because of regulatory requirements, institutional requirements or an unwillingness to invest the resources required to extract value. Silver Creek believes these opportunities exist worldwide, so these investments may be made outside the U.S. Successful execution of these strategies requires a unique combination of deal flow, in house expertise to properly price and structure transactions and the infrastructure to extract value from the portfolios that are acquired.
• Mortgage-backed Securities and Structured Finance: This strategy involves an investment in a pool of mortgages or other loans packaged by the issuer. Such instruments may include mortgage-backed securities (MBS), asset-backed securities (ABS), collateralized debt obligations (CDOs), and collateralized leveraged loan obligations (CLOs). The underlying loans may be residential loans, commercial loans, asset-backed loans, or a combination of the foregoing. MBS are collateralized by residential or commercial mortgages or pools of residential or commercial mortgages. Pools of mortgage loans are assembled as securities for
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sale to investors by various governmental, government-related and private organizations. The issuers of the securities will generally collect principal and interest payments from the underlying owners of the mortgaged or hypothecated property and pass the payments through to its investors. These securities may include complex instruments such as collateralized mortgage obligations, stripped mortgage-backed securities, mortgage pass-through securities, interests in real estate mortgage investment conduits, as well as other real estate-related securities. They may also include those with fixed, adjustable, floating or variable interest rates, interest rates that change based on multiples of changes in a specified index of interest rates and interest rates that change inversely to changes in interest rates, as well as those that do not bear interest. An Advisor investing in this strategy must be able to successfully weigh the purchase price of the securities against numerous risk factors (including, but not limited to, the credit risks associated with the performance of the underlying mortgage or other assets, the credit risk of the issuer, prepayment risk, extension risk and interest rate fluctuations) to ensure positive returns.
• Construction Loans: This strategy involves participating in loans made to finance new construction of either commercial or residential real estate improvements. Such participation may occur through a variety of transactions and/or structures, including the origination of such loans, acquisitions in the secondary markets or securitizations of such loans (such as mortgage- backed securities), as described above.
• Tax Lien Financing: This strategy involves purchasing tax liens on real property from governmental authorities. Investors will acquire a “tax certificate” from the applicable governmental authority by paying off the taxes owed on such property. As a holder of a tax certificate, an investor is entitled to repayment of the cost of the tax certificate plus interest (in an amount determined by applicable law). Holders of tax certificates step into the shoes of the governmental authority and will generally have priority over all other lien holders on the real property. In the event the owner of the real property is unable to repay the amounts owed to the holder of the tax certificate, the real property may be sold at auction or otherwise, and the new owner will assume the repayment obligations under the tax certificate. In some cases where the owner of the real property cannot meet its payment obligations, the holder of a tax certificate may be entitled to foreclose and take title to the real property.
• Litigation Financing: These strategies involve providing financing for plaintiffs pursuing legal actions for damages. The lender receives a priority claim against the ultimate recoveries obtained by the claimant in the disposition of the proceeding. Successful underwriting of such loans requires a sophisticated analysis of the merits of the underlying action and the ability to determine an interest rate that will adequately compensate the lender for the risk of an unfavorable outcome. The Funds may also invest by buying legal claims directly. In a variation of this strategy, the Funds may invest in debtor in possession financing. In this strategy the issuer provides financing to bankruptcy estates of debtors undergoing Chapter 11 reorganizations. The lender obtains a super-priority claim against the bankruptcy estate to support the ultimate repayment of the loan prior to or in connection with the plan of reorganization.
• Convertible Securities Arbitrage: This strategy primarily involves buying “long” a convertible security and selling “short” the underlying stock into which the convertible security may be converted (and vice versa) and/or another of the issuer’s debt instruments (or a credit default swap on the issuer) in anticipation of profiting from a relative mispricing among them.
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• Real Assets - Timberland: As employed by Silver Creek Funds, this strategy involves the purchase of high quality timberland portfolios and other timberland properties. An Advisor is appointed to manage and operate the timberland properties. The Advisor provides property acquisition, management, administrative and property disposition services.
• Real Assets – Aggregate Reserves: As employed by Silver Creek Funds, this strategy involves the purchase of diversified portfolios of Aggregate Reserves that spans various markets throughout the United States. “Aggregate Reserves” means (i) sand, gravel, crushed stone, and any similar products used in the construction industry and (ii) limestone used in the production of cement or other products. The Silver Creek Fund employing this strategy targets existing aggregate quarry landowners and/or companies that extract, process and market Aggregate Reserves (“Operators”) who are seeking to monetize some or all of their existing reserves or to acquire reserves alongside Operators purchasing Aggregate Reserve companies. The foregoing is not a comprehensive list of strategies that may be employed by the Funds, nor are the descriptions necessarily the only ways in which such strategies may be employed. Silver Creek has a flexible investment policy that will allow the Funds to participate in any market, strategy or investment, but subject in any event to any applicable investment restrictions and objectives specific to a Fund. In order to implement the various strategies, many Advisors are permitted to utilize leverage and to invest in a wide range of instruments, markets, and assets including, but not limited to, U.S. and non-U.S. equities, both public (listed on securities markets and exchanges around the world) and private; interests in other pooled investment vehicles (including funds-of-funds and/or affiliated funds); equity-related instruments such as preferred stocks, warrants and convertible securities; fixed income and other debt-related instruments whether or not investment grade, including debt securities and bonds of governments, their agents and instrumentalities, commercial paper and trade debt issued by U.S. and non-U.S. operating companies, bankers’ acceptances and certificates of deposit issued by banks and credit institutions; currencies; financial commodities such as futures and options relating to financial and physical assets; repurchase agreements and reverse repurchase agreements; derivative instruments, including both over-the- counter and exchange-traded instruments such as swaps, futures, options and forward agreements; and real assets. The Funds may invest directly in such instruments as well. In addition, the Funds and/or the Advisors may trade on margin and engage in short sales. Risks of Loss Investment in the Funds is speculative, illiquid and involves a high degree of risk. Interests in the Funds are available only to persons willing and able to bear the economic risks involved in the investment strategies employed by the Funds and to accept limited liquidity of their investment and who can bear the risk of loss of their entire investment. An investment in the Funds is suitable only for a limited portion of the risk segment of an investor’s portfolio. There is no assurance that the Funds will be profitable or that investors will not lose their investment in their specific Fund. The Performance Fees may create an incentive for Silver Creek to cause the Funds and Investment Vehicles to make investments which may be riskier or more speculative than those which would be made under a different fee arrangement. Prospective investors should give careful consideration to the following risk factors detailed below in evaluating the merits and suitability of an investment in a Fund. The following does not purport to be a comprehensive summary of all the risks associated with an investment in a Fund. Rather, the following are only certain risks to which the Funds are subject that Silver Creek wishes to encourage prospective investors to consider and discuss in detail with their professional advisors. To the extent that a Fund invests through
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an Investment Vehicle, the risk factors described below should be read to apply to such investments in the Investment Vehicle as well. For further information regarding the risks as well as potential conflicts of interest involved in an investment in the Funds, please refer to the sections of the offering documents of the respective Fund entitled “Risk Factors” and “Potential Conflicts of Interest.”
• Investment in General: Any prospective investor who subscribes, or proposes to subscribe, for an investment in a Fund must be able to bear the risks involved and must meet the Fund’s suitability requirements. Some or all of the alternative investment strategies employed by the Funds may not be suitable for certain investors. No assurance can be given that the Funds’ investment objectives will be achieved. Hedge fund investments are speculative and involve a substantial degree of risk. Past results of other funds managed by Silver Creek or any of its affiliates are not necessarily indicative of future performance of a Fund, and a Fund’s performance may be volatile. Moreover, Silver Creek will place Fund assets with Advisors based upon Silver Creek’s evaluation of, among other factors, the past performance of such Advisors. Such past performance may not be an accurate indicator of future returns delivered by such Advisors. Investment results may vary substantially on a monthly, quarterly or annual basis. An investment in a Fund does not constitute a complete investment program. An investor must realize that it could lose all or a substantial amount of its investment in a Fund.

Silver Creek expects that certain Sub-Funds may under-perform or experience financial difficulties, which difficulties may never be overcome. Certain Sub-Funds may be highly illiquid and/or permit redemptions or withdrawals infrequently and under very restrictive terms. Advisors may utilize highly speculative investment techniques, including extremely high leverage, highly concentrated portfolios, workouts and startups, control positions and illiquid investments. None of the Funds, their investors or Silver Creek will have the ability to direct or influence the management of an underlying Advisor’s investments. As a result, the returns of the Funds will depend primarily on the performance of such Advisors and could suffer substantial adverse effects by the unfavorable performance of such Advisors. There are no assurances that the Funds will be able to identify suitable investment opportunities. No assurance can be given that the Funds will achieve their goals or investment objectives. If a Fund receives distributions in kind from an investment, it may incur additional costs and risks to dispose of such assets, which costs will be passed along to its investors.


• Achievement of a Fund’s Investment Objectives: All securities, commodities, currency and real asset investments risk the loss of capital. While Silver Creek believes that the Funds’ investment programs will moderate this risk to some degree through a diversification of investment styles, the use of multiple Advisors, the investment strategies employed, the management of real properties and/or assets, and possibly, hedging, no guarantee or representation is made that the Funds’ programs will be successful. Such an approach is not risk-neutral and the pursuit of absolute returns may result in losses to investors. There is no ability to predict the investments the Advisors may select, or whether they will act in accordance with disclosure documents or descriptive materials furnished by them to a Fund. There is no guarantee that Advisors will be able to successfully identify and select successful investment opportunities. No assurance can be given that a Fund will achieve its goals or investment objective.
• Market Disruption and Political Risk: The success of any investment activity is influenced by general economic and financial conditions that may affect the level and volatility of asset
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prices, liquidity, interest rates and the extent and timing of investor participation in the markets for both equity and interest-rate-sensitive securities. Volatility, illiquidity, governmental action, currency devaluation, or other events in global markets in which a Fund directly or indirectly holds positions could impair the Fund’s ability to achieve its investment objective and could cause the Fund to incur substantial losses. The success of a significant portion of a Fund’s investment program will depend, to a great extent, upon correctly assessing the future course of price movements of stocks, bonds and other securities and financial instruments. There can be no assurance that Silver Creek and/or the Advisors will be able to predict accurately these price movements or that trading strategies that have been successful in the past will be successful in the future.

Various social and political tensions in the U.S. and around the world may contribute to increased market volatility, may have long-term effects on the U.S. and worldwide financial markets and may cause further economic uncertainties in the United States and worldwide. Silver Creek does not know how long the financial markets will continue to be affected by these events and cannot predict the effects of these or similar events in the future on the U.S. economy and securities markets. Given the risks described above, an investment in the interests of a Fund may not be appropriate for all prospective investors. A prospective investor should carefully consider its ability to assume these risks before making any such investment decision.

Market disruptions have led to increased governmental as well as self-regulatory scrutiny of the private investment fund industry in general. Legislation proposing greater regulation of the industry, the markets in which the Funds trade and invest and the counterparties with which the Funds do business has been proposed by the U.S. Congress, as well as the governing bodies of non-U.S. jurisdictions and further regulations continue to be proposed and promulgated. Any such regulation could have a material adverse impact on the profit potential of the Funds.


• Illiquidity of Investments of the Funds: The Sub-Funds in which the Funds invest typically impose substantial restrictions on transfers of interests in such Sub-Funds and generally require the consent of the Sub-Fund to be obtained before the transfer of any interests. The Sub-Fund may withhold such consent for any reason or no reason. Interests in the Sub-Funds are typically offered without registration under the Securities Act. There is generally no public market for interests in the Sub-Funds and, for a variety of regulatory reasons no such market will be permitted to exist. The only source of liquidity for interests in the Sub-Funds are as described in each particular Sub-Fund’s offering documents. Certain Sub-Funds in which the Funds invest may be illiquid and may not permit redemptions or withdrawals, or may permit redemptions or withdrawals in limited circumstances and on highly restrictive terms.


• Use of Advisors: The Advisors may manage other accounts (including collective investment vehicles and accounts in which the Advisors may have an interest) that, together with accounts already being managed, could increase the level of competition for the same trades the Advisors might otherwise make, including the priorities of order entry. This could make it difficult to take or liquidate a position at a price indicated by the Advisor’s strategy. In investing in a Fund, an investor will incur the costs of multiple levels of investment advisory services: the management fee and performance fee paid to Silver Creek for managing the Fund, as well as the management and incentive and other fees paid or allocations made to Advisors themselves. The asset-based fees of the Advisors generally are expected to range from 1% to 3%, and the performance-based allocations or fees of the Advisors generally are expected to range from 20% to 30% of net capital appreciation. Some Advisors may manage or invest in
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other funds or funds-of-funds, which would add additional layers of fees. In addition to advisory fees and its own investment and operational expenses, a Fund will incur its proportionate share of all of the expenses of the Sub-Funds and any Investment Vehicles, including, but not limited to, brokerage commissions and legal and accounting fees. A Fund may invest, either directly or indirectly, in Sub-Funds managed by Silver Creek or by Advisors that are affiliates of Silver Creek or the Fund (including Sub-Funds managed by Advisors in which the Fund holds an interest).

The Advisors of many, and possibly all, of the Sub-Funds through which the Funds invest will be compensated through incentive fee arrangements. Under these incentive fee arrangements, the Advisor may benefit from appreciation, including unrealized appreciation, in the value of the account, but may not be similarly penalized for realized losses or decreases in the value of the account. Such fee arrangements may create an incentive for the Advisors to make investments that are more risky or speculative than would be the case under a different fee arrangement. Because Advisors are compensated based on their performance and not the performance of a Fund’s investment as a whole, some Advisors may receive fees, including incentive fees, even though a Fund as a whole is not profitable.

While Silver Creek has policies and procedures in place to evaluate and monitor the operations of Advisors with whom a Fund invests, there can be no assurance that a Fund will not be exposed to losses due to operational failure, business interruptions, or improper or illegal activities by such Advisors. In addition, Silver Creek’s access to information about the Sub- Funds’ investments and operations on a daily or regular basis will be limited. Investors in the various Sub-Funds typically have no right to demand such information.

While the use of multiple Advisors may provide some diversification of investment risk, no assurance can be given that such diversification will occur, or that if it does, that it will increase, rather than reduce, potential net profits. The use of multiple Advisors may cause a Fund indirectly to hold opposite positions in an investment, thereby decreasing or eliminating the possibility of positive returns from such investment. To the extent that a Fund does, in fact, hold such positions, the Fund, considered as a whole, may not achieve any gain or loss despite incurring expenses.

Generally, Silver Creek will not have any control over the investments made by Sub-Funds. Silver Creek may reallocate a Fund’s investments among the Sub-Funds, but Silver Creek’s ability to do so is constrained by the withdrawal limitations imposed by the Sub-Funds. These withdrawal limitations could prevent Silver Creek from reacting rapidly to market changes should a Sub-Fund fail to effect portfolio changes consistent with market changes and the demands of Silver Creek.

There is generally no limitation on the size or operating experience of the Sub-Funds in which a Fund may invest. Some smaller Sub-Funds may lack management depth or the ability to generate internally or obtain externally the capital necessary for growth.
• Lack of Regulation of Advisors and the Funds: The Funds and the Sub-Funds in which the Funds invest are generally not subject to many provisions of the federal securities and commodities laws that are designed to protect investors in pooled investment vehicles offered to the public in the United States. The interests in Sub-Funds that are or may be purchased by the Funds generally are not offered pursuant to registration statements effective under the Securities Act. In addition, the Sub-Funds in which the Fund invests generally are not subject
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to the periodic information and reporting provisions of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), nor in most cases will those Sub-Funds be registered as investment companies under the Investment Company Act. The Advisors of Sub-Funds that trade in commodity interests may be exempt from the disclosure, reporting and record-keeping requirements of the U.S. Commodity Exchange Act. Advisors may not currently be registered under the Advisers Act. Accordingly, only a relatively small amount of publicly available information about Sub-Funds or Advisors will be available to Silver Creek in managing and assessing the Funds’ investments. In addition, it is likely that Silver Creek will not be able to ascertain investment positions taken by many of the Sub-Funds in which the a Fund invests and it is unlikely that Silver Creek will be able to independently verify many of the valuations provided by Advisors.


• Leverage: Subject to any applicable restrictions on borrowings described in a specific Fund’s offering documents, the Funds and Sub-Funds in which they invests are authorized to borrow funds in order to employ leverage, to manage liquidity and for any other purpose. Such borrowings may be secured by a pledge of assets to the lender. Borrowing money to purchase securities may provide an opportunity for greater capital appreciation by permitting greater economic exposure to profitable positions. At the same time, leverage increases the Funds’ exposure to capital risk and higher current expenses through greater exposure to losses, interest charges, fees imposed by lenders and transaction costs. Moreover, if the assets allocated to an Advisor are not sufficient to pay the principal of, and interest on, the debt when due, a Fund could sustain losses exceeding the amount of assets allocated to that particular Advisor. Any leverage at the Fund level will be in addition to the often substantial leverage employed by the Advisors and would serve to further increase the risk associated with these positions. A Fund and Advisors to whom such Fund allocates assets may borrow funds, or engage in repurchase agreements, for the purpose of purchasing or carrying securities. Such borrowings may not be subject to any limitations on the amount or terms of borrowings other than those imposed by the lender and any applicable credit regulations and any applicable limitations imposed on a Fund’s borrowings as described in its offering documents, and the amount of borrowings outstanding at any time may be large in comparison to the borrower’s capital. Borrowing money to purchase securities may provide an opportunity for greater capital appreciation, but also increases a Fund’s exposure to capital risk and higher current expenses.


• Investment Selection: Silver Creek and the Advisors will select investments on the basis of information and data prepared by the issuers of such securities or their Advisors or made directly available to Silver Creek and/or the Advisors by the issuers of the securities and other instruments or through sources other than the issuers. Although Silver Creek and the Advisors evaluate available information and data and seek independent corroboration when they consider it appropriate and when it is reasonably available, Silver Creek and the Advisors are not in a position to confirm the completeness, genuineness or accuracy of such information and data.
• Managed Account Allocations: Silver Creek may place assets of a Fund with a number of Advisors through opening discretionary Managed Accounts rather than investing in Pooled Vehicles. Managed Accounts may expose the Fund to theoretically unlimited liability, and it is possible, given the leverage at which certain of the Advisors of the Managed Accounts will trade, that the Fund could lose more in a Managed Account directed by a particular Advisor than the Fund had allocated to such Advisor to invest.
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• Timing of Subscriptions and Redemptions: Open-end Funds may permit additional subscriptions by existing investors and ordinary elective redemptions at certain intervals, subject to certain restrictions as described in such Funds’ offering documents. Some Sub- Funds in which such Funds may invest, however, may not permit additional investments or the admission of new limited partners, shareholders or participants, or withdrawals or redemptions by partners, shareholders or participants, as applicable, on the same basis or may be closed to further investment. As a result, the open-end Fund may be delayed in investing investors’ subscriptions to the Fund and in redeeming or withdrawing Fund assets from some Sub-Funds. This delay may in turn dilute the interests of investors in the Fund’s holdings of certain Sub- Funds. Certain of the Sub-Funds in which any of the Funds invest may be illiquid and not permit redemptions or withdrawals, or may permit redemptions or withdrawals in limited circumstances and on highly restrictive and/or punitive terms. These factors may require an open-end Fund to defer the payment of amounts redeemed from such Fund. These factors may also tend, from time to time, to affect the proportion of Fund investments in particular Sub- Funds.


• Investment in Foreign Securities: The Funds may, either directly or indirectly through Advisors and Sub-Funds, take positions in non-U.S. securities. Investment in non-U.S. securities may be subject to greater risks than purely domestic investments because of a variety of factors, including currency controls and the fluctuation of currency exchange rates, changes in governmental administration or economic or monetary policy (in the U.S. and abroad) or changed circumstances in dealings between nations. Dividends paid by foreign issuers may be subject to withholding and other foreign taxes that may decrease the net return on these investments as compared to dividends paid to a Fund by domestic issuers. There may be less publicly available information about non-U.S. issuers than about U.S. issuers, and non-U.S. issuers may not be subject to uniform accounting, auditing and financial reporting standards and requirements comparable to those of U.S. issuers. Securities of some foreign issuers are less liquid and more volatile than securities of comparable U.S. issuers and commissions on non-U.S. transactions are generally higher than commissions in the United States. Non-U.S. securities markets may also be less liquid, more volatile and subject to less governmental supervision than those in the U.S. Investment in foreign countries could be affected by other factors not present in the U.S., including expropriation without just compensation, exchange control, withholding taxes, confiscatory taxation and potential difficulties in enforcing contractual obligations. Finally, the value of investments denominated in non-U.S. currencies is subject to fluctuations in the exchange rate between the U.S. dollar, in which investments in the Funds are denominated, and the non-U.S. currency. Advisors or Sub-Funds may incur significant transaction costs in converting assets between different currencies. Risks of Special Techniques and Investment Strategies Used by Advisors and the Funds: Many of the Advisors through which the Funds invest use special investment techniques and investment strategies that may subject the Funds’ investments to certain risks. These techniques and strategies may also be employed by a Fund directly from time to time. Certain, but not all, of these techniques and strategies and the risks that they entail are summarized below.
• Illiquid Fund Securities: A Fund may have material exposure to private, unregistered securities. Positions in these securities may be difficult to liquidate or otherwise may be subject to very limited or no redemption rights. Positions may be valued based on economic models even though intrinsic value or realizable value may be different. Valuations of such illiquid positions may involve uncertainties and judgments, and if such valuations should prove to be incorrect, the net asset value of the Fund could be adversely affected.
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• Short Selling: Strategies employed by certain Advisors may entail selling securities of an issuer short in the expectation of “covering” the short sale with securities purchased in the open market at a price lower than that received in the short sale. The profit realized on a short sale will be the difference between the price received in the sale and the sum of the costs associated with posting margin and the cost of the securities purchased to cover the sale. The possible losses from selling a security short are unlimited, whereas losses from a long cash investment in a security can only equal the total amount of the cash investment. Short-selling activities are also subject to restrictions imposed by the federal securities laws, the several national securities exchanges and the Financial Industry Regulatory Authority, which restrictions could limit the investment activities of Sub-Funds. Where a Fund invests through a Sub-Fund, however, its exposure is generally limited to its investment in that Sub-Fund.
• Trading in Derivatives, Futures, Currencies and Other Instruments: Advisors and a Fund may directly trade in commodity futures, currency and interest rate forwards and a wide variety of other derivative instruments, including options, swaps, caps, warrants and rights (collectively, “Derivative Instruments”) whose values are based on the price of related securities, commodities, currencies or other interests. A position in a Derivative Instrument please register to get more info

There are currently no legal or disciplinary events that are material to a client’s or prospective client’s (including investors and prospective investors in the Funds) evaluation of Silver Creek’s advisory business or the integrity of its management. please register to get more info

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A. Not applicable. B. Silver Creek and the Funds have claimed fund-of-fund commodity pool operator registration relief pursuant to the November 29, 2012 CFTC No-Action letter No. 12-38 and therefore the Funds are operated as if Silver Creek were exempt from registration as a commodity pool operator. Silver Creek is not required by CFTC regulation to deliver a disclosure document or a certified annual report to participants in the Funds. The CFTC does not pass upon the merits of participating in a pool or upon the adequacy or accuracy of such pool’s offering documents. It is expected that Silver Creek would remain exempt from certain compliance requirements with respect to offerings to qualified eligible persons under CFTC Regulation 4.7.

C.(1). Not applicable.

C.(2). Silver Creek acts as the investment adviser to the various pooled investment vehicles listed under Item 4 of this brochure on a discretionary basis, as well as to the Advisory Client on a non-discretionary basis. Silver Creek Capital also provides additional investment research, advice and due diligence to Silver Creek (Silver Creek and Silver Creek Capital collectively defined as the “Management Group”).

Each Fund depends on the Management Group to conduct the business of the Fund. The managers and other personnel of the Management Group will devote as much attention to the business of each Fund as in their judgment is reasonably required, but they will also act in other capacities with other entities, funds and businesses with which they are involved. Accordingly, the Management Group will have conflicts of interest in allocating management time, services and functions among a Fund and other business activities in which it is engaged, and conflicts that may arise from having possession of material confidential information regarding potential investment opportunities. The Management Group and their managers, personnel and affiliates are not precluded from purchasing interests of a Fund or interests of parallel funds that invest alongside a particular Fund.

Additional conflicts of interest of the Management Group may arise due to the trading strategies or fee arrangements of a Fund. Silver Creek is compensated by certain Funds in part through a performance fee. This fee compensates Silver Creek for appreciation of the net asset value of a Fund, including in certain instances unrealized appreciation. Silver Creek is not similarly penalized for realized losses or decreases in the value of a Fund’s assets. By allowing Silver Creek to share in appreciation without bearing a proportionate share of any decreases in net asset value, this arrangement may create an incentive for Silver Creek to make investments that are more risky or speculative than it would otherwise. Furthermore, because the compensation of Silver Creek (and the Advisors) is tied to the net asset value of a Fund (and its investments) and such valuation includes gains that may never be realized, situations involving uncertainties as to the valuation of Fund assets could have an adverse effect on the net asset value of the Fund or result in Silver Creek (and/or the Advisors) receiving compensation for gains that are never realized by the Fund if judgments regarding appropriate valuations prove incorrect. For a description of how the foregoing conflicts of interest are addressed, please refer to sub-section A under Item11 of this brochure regarding Silver Creek’s Code of Ethics. C.(3). The following is also disclosed under Item 4. Silver Creek is also affiliated through both ownership and control with Silver Creek Capital. Silver Creek Credit Opportunities Cayman GP, Ltd. (“COGP”) is the General Partner of Silver Creek Credit Opportunities I Fund A, L.P., Silver Creek Credit Opportunities II Fund A, L.P. and Silver Creek Credit Opportunities III Fund B, L.P., Silver Creek FCOIII Cayman, L.P., Silver Creek FCO IV Cayman, L.P. and Silver Creek GL-MSC Fund, L.P. Silver Creek Credit Opportunities I-III GP, L.L.C. (“CO1-3GP”) is the General Partner of Silver Creek Credit Opportunities I A Master Fund, L.P., Silver Creek Credit Opportunities III B Master Fund, L.P. and Silver Creek Credit Opportunities V Fund B Master Fund, L.P. Silver Creek Credit Opportunities II GP, L.L.C. (“CO2GP”) is
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the General Partner of Silver Creek Credit Opportunities II A Master Fund, L.P. Silver Creek Credit Opportunities IV GP, L.L.C. (“CO4GP”) is the General Partner of Silver Creek Credit Opportunities IV Fund A, L.P., Silver Creek Credit Opportunities IV A Master Fund, L.P., Silver Creek Credit Opportunities IV Fund B, L.P., Silver Creek Credit Opportunities IV B Master Fund, L.P., Silver Creek Custom Opportunistic Debt Fund, L.P., Silver Creek Custom Opportunistic Debt Master Fund, L.P. and Silver Creek IGC Cayman, L.P. Silver Creek CPO GP, L.L.C. (“CPO GP”) is the General Partner of Silver Creek Custom Platform Opportunities, L.P., Silver Creek Custom Platform Opportunities Master Fund, L.P., Silver Creek Custom Platform Opportunities 2, L.P. and Silver Creek Custom Platform Opportunities 2 Master Fund, L.P. Silver Creek Prime GP, L.L.C. (“Prime GP”) is the general partner of certain of the Funds, Silver Creek Prime, L.P., Silver Creek Prime Cayman, L.P. and Silver Creek Prime Master, L.P. COGP, CO1-3GP, CO2GP, CO4GP, CPO GP and Prime GP are all wholly owned subsidiaries of Silver Creek. Silver Creek is affiliated with Dillon/Flaherty Investments, Inc. (“DFI”), one of whose control persons is also a control persons of Silver Creek. DFI is the general partner of DFP Fund, L.P. (“DFP”) and has engaged Silver Creek as an investment adviser to DFP.

C.(4) – C.(11). Not applicable

D. From time to time the Management Group and/or its employees may have the opportunity to earn fees or other compensation for services they provide to third parties in connection with the investment activities of a Fund. For example, certain Fund investments may give the Fund the right to appoint a representative to a board of directors or advisory board, and an employee of Silver Creek could be appointed to such position. In other situations the Management Group or an employee could obtain the right to receive compensation for services, such as management services or finders' or referral fees, provided in connection with a Fund's investment activities. In all such circumstances, any compensation that would otherwise be so payable to the Management Group or an employee shall instead be paid to the Fund whose investment activities gave rise to such compensation. Where more than one Fund is involved, the compensation will be allocated equitably as determined by Silver Creek in good faith. In such situation, the payor is directed to pay such compensation directly to the relevant Fund(s) to avoid creating taxable income for the Management Group or its employees. please register to get more info

AND PERSONAL TRADING

A. To limit potential conflicts of interest involving personal trades and to promote compliance with law and fiduciary requirements, Silver Creek has adopted a Code of Ethics and Personal Securities Transactions Policy, which include a formal code of ethics and insider trading policies and procedures. Silver Creek's Code requires, among other things, that employees:


• Act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients, prospective clients, fellow employees, colleagues in the investment profession, and other participants in the investment management industry;
• Place the integrity of the investment profession, the interests of Funds, and the interests of the investors in the Funds above their own personal interests;
• Not take inappropriate advantage of their position;
• Conduct all personal securities transactions in a manner consistent with the policy;
• Use due care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities;
• Practice and encourage others to practice in a professional and ethical manner that will reflect credit on Silver Creek and the investment management industry;
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• Promote the integrity of, and uphold the rules governing, capital markets;
• Maintain and improve their professional competence; and
• Comply with applicable provisions of the federal and state securities laws. Silver Creek's policies also require its employees to: 1) pre-clear certain personal securities transactions; 2) report personal securities transactions at least quarterly; and 3) provide Silver Creek with a detailed summary of certain holdings (both initially upon commencement of employment and annually thereafter) over which such employees have a direct or indirect beneficial interest.

A copy of Silver Creek's Code of Ethics and Personal Securities Transactions Policy will be provided to any investor or prospective investor upon request.

B & C. Silver Creek acts as investment adviser for the Funds, certain of which have similar or identical investment objectives to other funds managed by the Management Group. Silver Creek may cause persons and entities other than a particular Fund to acquire and hold securities of the same issuer as those acquired and held by such Fund. Silver Creek has the right to cause a Fund or entities that such Fund controls or in which it invests to do business with any other investment vehicles controlled by the Management Group or entities that such other investment vehicle controls or in which it invests.

The Funds may invest, either directly or indirectly, in Sub-Funds or Managed Accounts managed by the Management Group or Advisors that are affiliates of the Management Group. The Funds also may invest directly in one or more Advisors of Sub-Funds or Managed Accounts to which a Fund has allocated assets. It is possible that affiliates of the Management Group and/or a Fund will receive fees or other compensation as a result of a Fund’s investments. In no event will the Management Group participate in fees paid or allocations made to Advisors through rebates or reallowances of any sort. This restriction does not prohibit a Fund from negotiating fee reductions or rebates or participating in the economics of an underlying manager in connection with the investment activities of that Fund so long as any benefits from such inure to the benefit of the applicable Fund and not to any member of the Management Group.

Silver Creek may cause a Fund to transfer investments to or from other investment vehicles controlled by the Management Group or its related persons. Such a situation would arise, for example, where Silver Creek determines that it is in the best interest of one Fund to sell or effect a redemption of a position and in the best interest of another investment vehicle controlled by the Management Group to purchase or contribute capital to the same position. Such transactions may be executed as an assignment for reasons of administrative convenience or the subscribing Fund may be required to execute a new subscription agreement in order to take the position. In all cases, the transaction must be on terms that are as favorable to each party as would be entered into on an arms'-length basis as determined in good faith by Silver Creek on the best information available to it and consistent with Silver Creek's and the respective Funds’ valuation policies as well as Silver Creek's Portfolio Management and Due Diligence Policy. In the case of a position in a Sub-Fund, such value will typically be the net asset value calculated and reported by the Sub-Fund’s Advisor or fund administrator, but there may be circumstances in which such value is at a price that is different from the reported net asset value. Silver Creek will not accept any commission or similar transaction-based compensation as a result of providing such investment recommendations to its Funds. Subject to any applicable restrictions on borrowing set forth in a Fund’s offering documents, a Fund may lend money or securities to or borrow money from entities which are investment vehicles or managed accounts for which the Management Group serves as an investment advisor, manager, sponsor, administrator or otherwise has an interest. Funds may borrow funds from the Management Group from time to time. Such arrangements may involve the pledge of all or part of a Fund’s assets to secure such financing and may entail certain conflicts of interest. These arrangements may result in loans that are not
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as secure as loans to or from wholly-independent entities and may be subject to agreements that are not reached as a result of arms-length negotiation. In each such case, the Management Group shall endeavor to undertake such transactions on terms that are determined in good faith to be as favorable to each party as would be entered into an arms'-length basis as determined by the Management Group on the best information available to it and consistent with Silver Creek's and the respective Fund's valuation policies as well as Silver Creek's Portfolio Management and Due Diligence Policy. However, there can be no assurance that such transactions will be on terms that are equivalent to those which would be available in an actual arm’s-length transaction

Funds may, and certain Funds have, entered into negotiated arrangements with investors on terms that are different and/or more favorable than those offered in the standard offering documents of the relevant Fund. Affiliates of Silver Creek have been and in the future may be beneficiaries of such preferential terms. These arrangements have in the past included, without limitation: 1) lower or no Management Fees and/or Performance Fees; 2) different redemption rights; 3) increased portfolio transparency and other reporting; 4) certain notice requirements at the occurrence of specified events; 5) certain representations and warranties; and/or 6) terms commonly referred to as “Most Favored Nation” clauses.

The Funds have no right to participate in or benefit from the activities of the Management Group, its managers, members, personnel and its respective affiliates and related parties (collectively, "Related Parties") and the Related Parties do not account to the Funds for any profits or benefits made or derived therefrom, nor do Related Parties have any obligation to disclose specific opportunities to investors in the Funds. However, under Silver Creek's Code of Ethics and Personal Securities Transactions Policy, investment or service opportunities between Related Parties and Silver Creek's business contacts and outside employment opportunities (as well as service as a director, trustee or officer of an outside organization, as discussed below) must be disclosed to Silver Creek and are prohibited unless approved by Silver Creek. Silver Creek and its Related Parties are permitted to own interests in the Funds and in certain cases have invested in the Funds on a no-fee basis. Silver Creek and its Related Parties are allowed to trade in securities for their own account, and may hold securities that are the same as those in which the Funds advised by Silver Creek are invested or which could be suitable for the Funds but in which the Funds do not hold an interest. Also, Silver Creek and its Related Parties may from time to time have an interest, direct or indirect, in a security whose purchase or sale is recommended or which is purchased, sold or otherwise traded for a Fund. However, under Silver Creek's Personal Securities Transactions Policy, all employees must disclose their personal trading activities to Silver Creek in order to ensure that such employees do not inappropriately trade in securities prior to the Fund's purchase of the same securities. All of Silver Creek's personnel are required to abide by Silver Creek's Code of Ethics and Personal Securities Transactions Policy. Silver Creek, its Related Parties and/or its employees at certain times come into possession of material non-public information which may preclude the Funds from entering into transactions that would otherwise be profitable.

Related Parties also may, subject to compliance with the Advisers Act, deal as principals with a Fund in the sale or purchase of investments of the Fund or act as brokers, whether to the Fund or to third parties, in the purchase or sale of the Fund’s investments and shall be entitled to retain any profits or customary commissions resulting from such dealings. Related Parties may, under certain circumstances, be granted permission to serve as directors, trustees or officers of outside organizations. Certain Related Parties currently serve in such a capacity. These organizations can include public or private corporations, partnerships, charitable foundations and other not- for-profit institutions. At certain times, Silver Creek may determine that it is in its clients' best interests for a Related Party to serve as an officer, director or advisory board member of an outside organization. Service with organizations outside of Silver Creek can, however, raise serious regulatory issues and concerns,
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including conflicts of interests and access to material non-public information. Compensation for such activities is subject to Silver Creek's Directors' and Other Fees and Compensation Policy. Related Parties are prohibited from engaging in such outside activities without the prior approval of Silver Creek. Approval will be granted on a case by case basis, subject to proper resolution of potential conflicts of interest. Outside activities will be approved only if any conflict of interest issues can be satisfactorily resolved and any necessary disclosures are made to clients.

An investor must prospectively consent to certain transactions described above in order to subscribe for an interest in a Fund. Prospective investors in a Fund should refer to the offering documents and audited financial statements of the respective Fund for specific disclosure with regards to that Fund's transactions with Silver Creek or one or more of its affiliates or other controlled investment vehicles.

D. Situations may arise where it is deemed advisable for a fund or account (such as a Fund) to take trading positions or make investments that are opposite the trading positions or investments taken by another fund or account controlled by the Management Group or its affiliates. As a result, the Management Group may sell or recommend the sale of a particular security for certain accounts, including accounts in which it has an interest, and it or others may buy or recommend the purchase of such security for other accounts, including accounts in which it has an interest and, accordingly, transactions in particular Funds or accounts may not be consistent with transactions in other Funds or accounts or with the Management Group’s investment recommendations.

In situations where a limited investment opportunity is suitable for one or more Funds managed by the Management Group, such opportunities will be allocated on a fair and equitable basis, as determined in good faith, balancing the best interests of the respective Funds and consistent with Silver Creek’s Portfolio Management and Due Diligence Policy. Factors to be considered may include, without limitation, the investment objectives of the Funds in question, anticipated liquidity needs, expected inflows and outflows of capital, anticipated future investment opportunities, whether the investment opportunity is of sufficient size to impact returns, contractual obligations to third parties, and other equitable factors. Each Fund bears its pro rata share of any costs associated with such trade on an equitable basis. please register to get more info

A. Brokerage Practices - General

As the investment adviser to the Funds, Silver Creek is granted the discretionary authority in the relevant organizational documents and/or investment management agreements to determine which securities and the amounts of securities that are bought or sold, as well as the broker dealer to be used and the commission rates to be paid, if any. Where a Fund invests in a Pooled Vehicle or Managed Account managed by an unaffiliated Advisor selected by Silver Creek, Silver Creek generally will not have the ability to determine which securities and the amounts of securities that are bought or sold, nor will Silver Creek necessarily be able to determine the broker dealer to be used and the commission rates to be paid. As disclosed in each Fund's offering documents, the Funds invest primarily in Pooled Vehicles, the interests of which are typically sold directly by the issuers and without payment of brokerage commissions, or through Managed Accounts for which the executing brokers are chosen by the investment manager for the respective account. However, for any security trades effected through brokers selected by Silver Creek, Silver Creek will endeavor to select those brokers or dealers which will provide the best execution at competitive commission rates.
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1. Research and Other Soft Dollar Benefits Subject to the requirement to seek to obtain best execution of brokerage transactions, transactions for the Funds are sometimes allocated to brokers on the basis of and in consideration of such broker's provision or payment of the costs of investment research and analysis, administrative and operational services and support, bookkeeping and recordkeeping services, trading terminals or other office equipment and other trading services and products (sometimes referred to as "soft dollar" services and products) that are of benefit to such adviser or other advisory clients of the adviser. In instances where a Fund makes direct investments, Silver Creek engages a full service brokerage firm to serve as prime broker and/or executing broker for such transactions. As a result, the Fund bears commission rates and other charges that are higher than those that may be available from a discount brokerage. A full service brokerage would be used where Silver Creek determines in good faith that the cost of using a brokerage is reasonable in relation to the value of the brokerage services and additional services provided by such full service brokerage. Such additional services may generally include pricing services, administrative and operational support, accounting services and software, and/or research and may be used to service Funds not exclusively in connection with the management of the specific Fund that engaged such full service brokerage. Where Silver Creek is responsible for selecting brokers for the Funds, it does not receive a "soft dollars" account that it uses to pay for separate research or other services. However, certain Advisors may employ such soft dollar accounts. Many Advisors employed by the Funds use soft dollars extensively.

The commission rates and other amounts charged by brokers in the foregoing circumstances may be higher than those charged by other brokers who may not offer such services. Advisors may therefore recommend the use of (or use) a broker who provides soft dollar services and products even though a lower commission may be charged by a broker who does not offer the same level of products and services. Research or other soft dollar services may be useful in servicing all of the Advisors' clients, and not all of such research may be useful for the account for which the particular transaction was effected. Such services may benefit other advisory clients and it is possible that the benefits of such services to a particular Fund will not be proportionate to the commissions borne by such Fund. The use of soft dollars described herein may not qualify for the "safe harbor" set forth in Section 28(e) of the Exchange Act.

2. Brokerage for Client Referrals

Brokers or dealers selected by Silver Creek or Advisors to execute transactions may from time to time refer clients to Silver Creek or such Advisors. Silver Creek will not make commitments to any broker or dealer to compensate that broker or dealer through brokerage or dealer transactions for client referrals; however, a potential conflict of interest may arise between the client's interest in obtaining best price and execution and Silver Creek's interest in receiving future referrals.

Silver Creek may from time to time engage placement agents, solicitation agents or finders for the interests of the Funds ("Solicitation Agents"). Silver Creek may pay Solicitation Agents a portion of the fees paid to Silver Creek or other compensation. Such Solicitation Agents shall generally be registered as broker- dealers and members of FINRA or other self-regulatory organization in good standing. To the extent applicable, such compensation will be paid in a manner intended to comply with SEC Rule 206(4)-3 and applicable regulations under the Securities Exchange Act of 1934, as amended. 3. Directed Brokerage Not applicable
Silver Creek Advisory Partners LLC Form ADV: Part 2A Page 38 please register to get more info

A. Fund portfolios are reviewed on a continuous basis, and their performance, exposures and risk characteristics are monitored by the Management Group’s Investment Committee, including, Eric E. Dillon (Chief Investment Officer), Peter Duncan (Portfolio Manager), Art Zaske (Portfolio Manager), Robert Ratliffe (Portfolio Manager), William Turner (Portfolio Manager), Theodore Liu (Portfolio Manager) and LeAnne Kolb (Chief Financial Officer and Head of Operational Due Diligence). The Investment Committee is also supported by one Managing Director of Risk Management, one Managing Director, one Director of Credit Strategies, one Director of Timberland, two Directors of Investment Research, two Senior Investment Analysts, one Investment Analyst, one Managing Director of Due Diligence, a Due Diligence Senior Analyst, a General Counsel, and the Chief Compliance Officer who is also Senior Counsel. An Investment Committee formed to oversee a specific Fund or Funds may consist of different members in addition to the Chief Investment Officer and such Investment Committee may adopt different rules to the extent Silver Creek determines they are warranted based on the specific requirements of such Fund or Funds.

The Investment Committee meets regularly to review and address ongoing tasks and issues and formally meets on a regular basis to review each Sub-Fund position in each Fund’s portfolio as well as to review each Fund’s overall hedging program and investment outlook with respect to specific underlying strategies. The Investment Committee also meets on an interim basis to the extent specific items need to be addressed. The Investment Committee evaluates the Funds’ portfolios consistent with any applicable guidelines or restrictions in a specific Fund’s offering documents and consistent with Silver Creek’s Portfolio Management and Due Diligence Policy. For further information on the Investment Committee’s review process, please refer to the section A of tem 8 of this brochure entitled “Methods of Analysis.”

Fund portfolios are also reviewed by members of the operations team and the Chief Financial Officer in consultation with the Chief Compliance Officer to monitor compliance with any applicable operating guidelines of the specific Funds.

B. Not applicable.

C. Each Fund’s fiscal year ends on the 31st day of December of each calendar year. Each Fund will furnish annual reports to its investors containing financial statements examined by such Fund’s independent auditors. Such audited financial statements for any fiscal year will be delivered as soon as reasonably practicable following the end of such fiscal year and receipt of necessary information from Sub-Funds and Advisors. Because each Fund’s audit is dependent upon the receipt of audited financial statements from Sub-Funds and Advisors, such Fund’s audit may not be completed until late in the second quarter of the following fiscal year. Each Fund will communicate to each investor the net asset value of such Fund and of such investor’s interest in the Fund on a regular basis as disclosed in each Fund’s offering documents.

Additional written financial reporting may be provided via on-line access and/or direct delivery in Silver Creek’s sole discretion and may include: monthly fund fact sheets; quarterly newsletters; and quarterly portfolio summaries. Certain Fund investors receive additional and/or different reports by agreement among Silver Creek, the respective Fund and such investor. In Silver Creek’s discretion, such reports and other communications may be disseminated exclusively via e-mail or a password protected website. Silver Creek provides the Advisory Client with quarterly written reports. please register to get more info

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A. Not applicable. B. Silver Creek may from time to time engage placement agents, solicitation agents or finders for the interests of the Funds ("Solicitation Agents"). Silver Creek may pay Solicitation Agents a portion of the fees paid to Silver Creek or other compensation. Such Solicitation Agents shall generally be registered as broker-dealers and members of FINRA or other self-regulatory organization in good standing. To the extent applicable, such compensation will be paid in a manner intended to comply with SEC Rule 206(4)-3 and applicable regulations under the Securities Exchange Act of 1934, as amended. please register to get more info

Because Silver Creek has sole authority over the disposition of assets held by the Funds, Silver Creek is deemed to have custody of client assets under Rule 206(4)-2 of the Advisers Act. Silver Creek maintains all assets that are not exempt under Rule 206(4)-2 at a qualified custodian who provides account statements to the Funds and Silver Creek on a regular basis. The Funds are audited by an independent public accountant on an annual basis in accordance with U.S. Generally Accepted Accounting Principles and Silver Creek expects to distribute the resulting audited financial statements to Fund investors within 180 days of the applicable Fund’s fiscal year end.

Please refer to Item 13.C for information regarding reports provided for investors in Silver Creek Funds. please register to get more info

Silver Creek has discretionary authority to manage securities on behalf of its clients, the Funds, which authority is contained in the investment management agreement or other constituent document amongst the specific Fund and Silver Creek which include a power of attorney.

The investors in the Funds managed by Silver Creek generally may not place any limits on Silver Creek’s authority beyond the limitations set forth in the offering and governing documents of their respective Fund. Silver Creek also provides non-discretionary investment management services to the Advisory Client pursuant to an investment advisory agreement. please register to get more info

A. As a "fund-of-hedge-funds" adviser, Silver Creek is infrequently requested to vote the proxies of traditional operating companies. Silver Creek may however, from time to time, receive a request to vote on behalf of its Funds in their capacities as investors in underlying Sub-Funds. Silver Creek votes the Funds' proxies in the interest of maximizing value for the Funds and the investors in the Funds. To that end, Silver Creek endeavors to vote proxies in the manner that it determines in good faith will be the most likely to cause the Funds' investments to increase the most or decline the least in value. Consideration is given to both the short and long term implications of the proposal requiring a vote. The Investment Committee, in consultation with the Chief Compliance Officer and/or Silver Creek’s legal personnel, is responsible for voting the proxies in the best interest of the Funds and their investors, and submitting the proxies promptly and properly. Silver Creek’s complete proxy voting policy and procedures have been memorialized in writing and are available for investors to review. In addition, Silver Creek maintains a record of all of the proxy votes cast on behalf of the Funds; such records may be reviewed at Silver Creek's offices.
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B. Not applicable. please register to get more info

A. Not applicable B. Not applicable.

C. Not applicable.
ITEM 19 REQUIREMENTS FOR STATE-REGIESTERED ADVISERS

A. Not applicable. B. Not applicable. C. Not applicable. D. Not applicable. please register to get more info