Our History GCM CFIG is the successor to the Customized Fund Investment Group, which, from late 2000 to January 2, 2014, was a business unit within the asset management division of Credit Suisse Group AG (Credit Suisse). On January 2, 2014, Grosvenor Capital Management Holdings, LLLP (GCM Holdings), an Illinois (USA) limited liability limited partnership, acquired certain assets associated with the Customized Fund Investment Group from Credit Suisse. Our Business GCM CFIG (including its predecessors) has been in business since 1999. We provide the following investment management and advisory services for private markets (i.e., private equity, real estate, and infrastructure investments) to investment vehicles, separately managed accounts, and other clients on a discretionary and non-discretionary basis (GCM CFIG Funds):
• Single-investor GCM CFIG Funds managed or advised by GCM CFIG (Customized GCM CFIG Funds)
We offer customized investment vehicles and separate accounts designed for investors seeking a customized mandate, control over structure, and/or involvement in the investment process. We collaborate with investors to review, design, implement, and monitor customized portfolios tailored to the investor’s needs.
• Multi-investor GCM CFIG Funds managed or advised by GCM CFIG (Commingled GCM CFIG Funds)
We offer multi-investor investment vehicles designed for multiple investors seeking ease of investment and diversification in select strategies. The GCM CFIG Funds pursue their investment objectives by investing in: › one or more pooled investment vehicles (either directly or indirectly through special purpose vehicles formed for the purpose of investing in such securities or other assets), including funds acquired in the secondary market (Underlying Funds), which themselves purchase securities or other assets and are managed by third-party investment managers (Investment Managers) › securities or other assets that may be sponsored or identified by Investment Managers or may be sourced independently by GCM Grosvenor (either directly or indirectly through special purpose vehicles formed for the purpose of investing in such securities or other assets). We refer to these securities, including securities issued by operating companies (Operating Companies), or other direct assets as co-investments (Co-Investments). For convenience:  we sometimes refer to the privately offered customized and commingled investment vehicles that we manage or advise—which are typically organized as limited partnerships, limited liability companies, corporations or similar entities—as the GCM CFIG Investment Vehicles  we sometimes refer to the GCM CFIG Investment Vehicles, together with accounts that we manage or advise but that are not organized as legal entities, as the GCM CFIG Funds Although investors in GCM CFIG Funds or GCM CFIG Investment Vehicles are not, in their capacity as such, our clients for regulatory purposes, we sometimes refer to those investors as our clients. Investment Monitoring Services We provide Investment Monitoring Services (Investment Monitoring Services) for certain clients seeking assistance in monitoring their private equity, real estate, or infrastructure investments, including investments held directly by the client. Investment Monitoring Services may include:  testing the schedule of unrealized investments  reviewing distribution notices  monitoring capital calls to verify reasonableness of management fee calculations  reviewing amendment and consent requests made by an Investment Manager and providing a written summary and review of the terms of the amendment or consent  attending periodic meetings held by an investor’s private fund program’s Investment Managers and preparing brief reports of any relevant updates  reviewing equity ownership of individual portfolio companies to ensure compliance with internal client policies Portfolio Administration Services We provide portfolio administration services (Portfolio Administration Services) for certain clients, designed to integrate portfolio administration for all of a client’s private equity, real estate or infrastructure investments, including those investments that are sourced and executed directly by the investor or through parties other than GCM CFIG, such as the investor’s consultants or other investment managers or advisers. Portfolio Administration Services may include:  tracking cash flow activity and developing appropriate cash flow activity categorizations  reviewing and reconciling capital calls and distributions  recording quarterly capital account adjustments  reconciling quarterly reports received by an investor in respect of its investments  providing an investor with various fund-by-fund and aggregate reporting  providing an investor with various look-through underlying asset level exposure reporting Such an investor typically has access to the reports described above through a password-protected portal into our proprietary systems. Our Assets Under Management As of December 31, 2018, our assets under management were approximately $25.5 billion. The methodology used to calculate our assets under management differs from the methodology used to calculate regulatory assets under management for purposes of responding to Item 5.f(2) of Part 1 of our SEC Form ADV. Additional detail concerning the methodology is available upon request. Our Principal Owner Our principal owner is GCM Holdings. Employees and former employees of companies associated with GCM Grosvenor, as well as certain other persons formerly associated with us, indirectly own a majority interest in GCM Holdings. Michael J. Sacks, our Chairman and Chief Executive Officer, owns a controlling interest in GCM Holdings through several intermediate entities that he controls and of which he is the principal owner. please register to get more info

Fees in General The GCM CFIG Funds generally pay us or our affiliates one, or a combination, of the following:  a percentage of up to 2.0%, of assets, investment value, all or a portion of investor or investment commitments, which may include uncalled capital  an agreed upon fixed amount  a percentage of specified realized profits of up to 25%, which is typically subject to various hurdles or preferred returns Any transaction or monitoring fees that are received by us will generally either be rebated back to the investors as an offset against our management fee or directly paid to the applicable GCM CFIG Fund and allocated among the partners of that fund, including GCM CFIG affiliates where applicable. Fees may differ based upon a number of factors, including without limitation, investment type and asset class, overall fee arrangements, account complexity, overall relationship with us and our affiliates, account size, assets or commitments under management and the terms of the various Underlying Funds in which the GCM CFIG Funds invest and vintage year of the GCM CFIG Fund. Certain investors, including seed investors, strategic partners, and persons associated or formerly associated with us, and members of their families, as well as certain friends of such persons, may invest in GCM CFIG Funds on a non-fee-paying basis or at fee rates that are lower than those charged to other investors in such GCM CFIG Funds, in our discretion. Neither we, nor any of our personnel, receive compensation directly attributable to the sale of a security (including shares or similar equity interests) in any GCM CFIG Investment Vehicle or other GCM Grosvenor investment products (e.g., brokerage commissions). Fees and Allocations for Customized GCM CFIG Funds Management fees, carried interest, or other special allocations, and other terms for Customized GCM CFIG Funds are negotiated on a case-by-case basis with the investor. Management fees are typically payable quarterly, either in advance or in arrears, may be payable on investments that are valued below cost, and in some cases, may be paid on investments valued at zero but have not been written off. Carried interest is generally based on a waterfall calculation that takes into account an investor’s realized gains and, in some cases, unrealized gains and losses on portfolio securities, either over the life of the Customized GCM CFIG Fund or on a deal-by-deal basis, and may or may not take into account a hurdle or preferred return and management fees and expenses previously paid by the investor. Fees and Allocations for Commingled GCM CFIG Investment Vehicles Typically, each Commingled GCM CFIG Investment Vehicle sets forth its specific fee structure, including how and when fees are calculated, charged and payable, and how allocations are calculated and made in a private placement memorandum, limited partnership agreement, investment management agreement, side letter, or similar offering document (together, GCM CFIG Fund Documents) provided to each prospective investor in such GCM CFIG Investment Vehicle prior to the prospective investor’s investment in the GCM CFIG Investment Vehicle. Fees applicable to Commingled GCM CFIG Investment Vehicles typically are not negotiable. Fees are typically payable quarterly, either in advance or in arrears, based on terms memorialized in the GCM CFIG Fund Documents. Carried interest calculated and made in the same manner, as described above, for our Customized GCM CFIG Investment Vehicles. Fees for Investment Monitoring and Portfolio Administration Services Fees for Investment Monitoring and Portfolio Administration Services are negotiated on a case-by-case basis and depend upon the range of services that we provide to the client. Fee Refunds In cases in which an investor in a GCM CFIG Fund pays fees in advance and the investor terminates its investment in such GCM CFIG Fund in accordance with the termination provisions governing such GCM CFIG Fund prior to the expiration of the period for which the advance fee was paid, except as otherwise agreed with the investor, we pay an appropriate pro rata refund to the investor, or make a pro rata credit to the investor, designed to ensure that the investor pays a fee only for the portion of the period preceding the effectiveness of the termination. Expenses Each GCM CFIG Fund typically pays its organizational and initial offering costs. Each GCM CFIG Fund typically pays such costs and expenses as are necessary, advisable, or convenient for the conduct of its business, including, without limitation:  brokerage commissions, due diligence costs, investment banking fees, monitoring costs, sourcing or finder’s fees, and other costs related to the identification, sourcing, evaluation, or execution of transactions—including expenses related to potential transactions that are not ultimately consummated (i.e., broken deal fees and other transaction-related expenses incurred either by GCM CFIG, the GCM CFIG Fund, and/or the Investment Manager or other party sponsoring such investment)  the interest expense, fees, and other expenses associated with any borrowing facility  fees and expenses in connection with the custody of assets of a GCM CFIG Fund  certain fees and expenses associated with reporting to clients  legal, accounting, administration, tax preparation, audit, financial statement preparation, valuation, research terminal, consulting, and other professional fees and expenses, including costs and out of pocket expenses of a third party engaged by a GCM CFIG Fund or by GCM CFIG itself for purposes of providing these services to one or more GCM CFIG Funds  other operating or administrative fees and expenses related to accounting, research, due diligence, reporting, and portfolio management services  Third-Party Costs, as defined herein  any costs and expenses arising out of a GCM CFIG Fund’s indemnification obligations  any taxes and regulatory or other governmental fees and charges (including regulatory or governmental fees and charges resulting from the offering or sale of a GCM CFIG Fund’s securities in a non-U.S. jurisdiction)  certain travel and entertainment expenses incurred in connection with a GCM CFIG Fund’s affairs, including in connection with investments, potential investments, and meetings with investors or their representatives (to the extent permissible in such Fund’s governing documents and to the extent such expenses comply with GCM CFIG’s Travel and Expense Policy)  extraordinary expenses  all other costs specifically described in the particular GCM CFIG Fund’s offering documents  all other costs related to a GCM CFIG Fund’s investment activities We are not reimbursed for our internal costs except as agreed upon in connection with a particular GCM CFIG Fund. In accordance with our policies and procedures and the documents governing certain GCM CFIG Funds, payments made to independent third-party vendors, consultants, or professional advisers (including providers of outsourced accounting, administrative, or reporting services) that directly support the ongoing management, administration, and operations of such GCM CFIG Funds (Third-Party Costs) are borne by such GCM CFIG Funds. Third-Party Costs may include, among others:  insurance expenses, which consist primarily of premium payments made to third-party insurance underwriters and brokers related primarily to fiduciary liability coverage, professional liability coverage, ERISA fidelity bond, if applicable, and directors’ and officers’ liability coverage  operational due diligence expenses, which consist primarily of legal expenses and professional fees paid to third-party investigation firms to conduct background investigations on existing and potential Investment Managers  technology expenses, which consist primarily of software and data licensing, development, programming and operating costs paid to third-party vendors to support the operating platforms of the GCM CFIG Funds, as well as costs related to the licensing, usage, and redistribution of data and performance benchmarks  industry expert expenses, which consist primarily of fees payable to firms that source through their member networks professionals with expertise relevant to the GCM CFIG Funds’ investment activities Third-Party Costs, to the extent allocable, are generally allocated to the GCM CFIG Funds or related groups of GCM CFIG Funds (e.g., all GCM CFIG Funds pursuing a particular strategy or specific transaction) on a pro rata basis in accordance with their respective commitment amounts, unless we decide, in our discretion and as permitted by the various GCM CFIG Funds’ Documents, to specially allocate such expenses to a subset of GCM CFIG Funds to which such expenses more specifically relate, even though they may not benefit from such expenses on a strictly pro rata basis. All costs and expenses directly attributable to one or more GCM CFIG Funds, and not to any other GCM CFIG Fund, including the costs of background investigations directly attributable to such GCM CFIG Funds, are charged to those GCM CFIG Funds and are not allocated pro rata among other GCM CFIG Funds in the manner discussed above. In certain limited cases, GCM Grosvenor bears all or a portion of the Third-Party Costs that otherwise would be borne by a GCM CFIG Fund pursuant to the principles discussed above. As an investor in Underlying Funds or Co-Investments, each GCM CFIG Fund typically bears its allocable share of the Underlying Funds’ or Co-Investments’ respective organizational, offering, investment, and operating expenses, including taxes, interest due on borrowings, brokerage and other transaction costs, the fees, expenses, and profit participations of the Investment Managers and any extraordinary costs incurred. The advisory fees charged by Investment Managers vary in type, amount, and structure. For example, certain performance fees or allocations are paid or made only after achieving a hurdle rate of return. Moreover, some performance fees or carried interest may be calculated after investors have received a return of capital and a preferred return, or variations of such arrangements. Most GCM CFIG Funds are thus subject to two levels of fees and a potentially higher expense-to-equity ratio than would be associated with an investment fund that invests and trades directly in financial instruments under the direction of a single investment manager. Pursuant to Accounting Standards Generally Accepted in the United States (U.S. GAAP), the management fee, partnership expenses, and carried interest of Underlying Funds or Co-Investments are typically capitalized and therefore not reflected in the reported expense ratios in the audited financial statements. please register to get more info

As discussed in Item 5 of this Brochure, many GCM CFIG Funds pay us or our affiliates performance fees or special allocations (i.e., carried interest) based on a percentage of realized profits, which may be subject to a hurdle or preferred return. These arrangements present potential conflicts when our interests may not be, or perceived not to be, aligned with the interests of one or all of the GCM CFIG Funds. In allocating investment opportunities, there could be incentives to favor GCM CFIG Funds with higher potential performance-based fees or special allocations over GCM CFIG Funds with lower potential performance-based fees or special allocations. As a control, GCM CFIG has adopted written policies and procedures pursuant to which it seeks to allocate investment opportunities among GCM CFIG Funds in a fair and equitable manner. In addition, performance-based fees and special allocations may create an incentive for us to recommend investments that may be riskier or more speculative than those that would be recommended under different compensatory arrangements. Please see Item 8 for additional details on how we address and mitigate these types of conflicts. please register to get more info

Our investment management and advisory clients consist of the GCM CFIG Investment Vehicles and investors in GCM CFIG Funds. Investors who invest in the GCM CFIG Investment Vehicles and investors in GCM CFIG Funds include:  charitable organizations  governments and governmental agencies  high net worth individuals  public and private pension plans  Taft-Hartley plans  endowments and foundations  sovereign wealth funds  insurance companies  corporations The GCM CFIG Investment Vehicles may be organized as U.S. or non-U.S. entities, and are operated as investment pools exempt from registration under the Investment Company Act of 1940 (as amended, the ICA). An investor who wishes to invest in a GCM CFIG Investment Vehicle may be required to commit to a minimum investment amount that varies depending on the GCM CFIG Investment Vehicle. We disclose this requirement in each GCM CFIG Investment Vehicle’s Documents. We make exceptions at our discretion. GCM CFIG Funds typically have investment strategies that are similar to those of the GCM CFIG Investment Vehicles. Characteristics of certain asset classes may require minimum account sizes for investors in such GCM CFIG Funds. We make exceptions at our discretion. please register to get more info

Our Investment Philosophy The following principles define our basic investment philosophy:  Follow a research-based approach. We typically employ a top down and bottom up research-based approach to our investment activities. Customized GCM CFIG Funds may follow a different approach, depending on a variety of factors including the investment objectives, mandate, and restrictions established by the particular investors in such Customized GCM CFIG Funds.  Seek to achieve an appropriate level of diversification in a Commingled GCM CFIG Fund (unless otherwise prescribed in the applicable GCM CFIG Fund Documents) or the level of diversification prescribed by the investor in a Customized GCM CFIG Fund.  Focus on fewer Investment Managers or Co-investments, with the objective of identifying what we believe to be the highest quality Investment Managers or Co-investments appropriate for the GCM CFIG Funds.  Seek to invest with Investment Managers that we regard as having a competitive advantage.  Conduct effective due diligence with respect to Investment Managers and the Underlying Funds and Co-investments they manage or advise. Diversification and Types of Investments We typically recommend diversifying the portfolio of a GCM CFIG Fund by type, strategy, industry, geography, sector, stage, and vintage year. Customized GCM CFIG Funds may follow a different approach, depending on a variety of factors including the investment objectives, mandate, and restrictions established by the particular investors in such Customized GCM CFIG Fund. The types of investments we typically seek to include in diversified portfolios for GCM CFIG Funds may include:  Investments in Underlying Funds acquired directly from Investment Managers at or near inception during the fundraising period (Primary Fund Investments)  Investments in Underlying Funds and/or companies acquired in secondary market transactions (Secondary Investments)  Co-Investments  Direct Investments The types of strategies we may seek to include in the investment portfolios of the GCM CFIG Funds include, but are not limited to, the following:  Leveraged Buyouts (i.e., Middle Market or Large)  Venture Capital  Growth Equity  Special Situations — i.e., Structured Equity, Distressed, and Subordinated Debt  Distressed Debt  Infrastructure (also referred to as Energy, Infrastructure, and Real Assets)  Real Estate  Small and Emerging Managers  Diverse Managers  Regionally-Focused Strategies  Responsible Investing  Emerging Markets General Investment Process 1. Deal Flow Evaluation GCM CFIG has various investment sub-committees that review investment opportunities identified through GCM CFIG’s sourcing process and ensure that investment opportunities are proactively tracked. These sub-committees, which generally meet on a weekly basis, are comprised of GCM CFIG investment professionals of various levels of seniority, including Principal Investment Committee members (defined herein). The intent of the investment sub-committee is to ask questions and highlight topics to the Deal Team in an effort to perform an adequate level of diligence for each investment opportunity. The Deal Teams and the sub-committees are not authorized to initiate the conduct of comprehensive due diligence. The Principal Investment Committee initiates this step. Further, the Deal Teams and the sub-committees are not authorized to make final decisions of whether to approve or disapprove investment opportunities on behalf of GCM CFIG Funds. One of the goals of sub-committee review is to subject each deal to a requisite level of scrutiny prior to its submission to the Principal Investment Committee. Sub-committee meetings—generally scheduled weekly—also provide the Deal Team with a forum to discuss any questions or concerns that have arisen and to receive input and guidance from a broad group of investment professionals. Once we identify and supports a potential Primary Fund Investment, Secondary Investment, Direct Investment, or Co- Investment (collectively, Qualifying Investments) for further consideration, additional Deal Team members are assigned to initiate due diligence. The Deal Team typically conducts an initial meeting with the Investment Manager of the Underlying Fund, or sponsor of the Co-Investment or Direct Investment and presents findings and a recommendation at a meeting of the relevant sub-committee. During this meeting, the Deal Team focuses on a variety of issues or considerations, including:  For Primary Fund Investments and Secondary Investments, the potential Investment Manager’s investment strategy, value-addition proposition, historical track record, the experience, responsibilities, and interactions among its professionals. Also, in the case of a secondary investment, the Deal Team discusses pricing.  For Co-Investments and Direct Investments, the investment thesis, company, industry, management, sponsor, transaction, and projected returns of the investment The relevant sub-committee discusses the pros and cons of commencing preliminary due diligence on the potential Qualifying Investment. Of the many factors involved in making this decision, key ones typically include investment merits, appropriate risk-return profile, and GCM CFIG Fund fit. If the relevant sub-committee determines that an opportunity warrants further investigation, the Deal Team commences preliminary due diligence on the potential Qualifying Investment. Given a condensed timeline for a particular investment opportunity, in certain limited circumstances, senior investment professionals may direct the Deal Team to proceed directly to comprehensive due diligence. The Portfolio Management Governance Group (PMG), which is composed of senior investment professionals, provides oversight for the portfolio management process across GCM CFIG Funds to ensure a consistent portfolio construction process as well as to reasonably ensure the appropriate implementation of the allocation policy. PMG, with support from Portfolio Management Operations (PMO), performs the following functions, among others:  reviews and provides feedback regarding Investment Guidelines and target portfolio construction of the GCM CFIG Funds  assesses eligibility of the GCM CFIG Funds for each Qualifying Investment  reviews portfolio allocation recommendations provided by PMO PMO verifies that each Qualifying Investment conforms with the Investment Guidelines of the participating GCM CFIG Funds prior to execution and retains appropriate support. 2. Preliminary Due Diligence Once the appropriate sub-committee determines that an investment opportunity meets the initial criteria, the relevant Deal Team commences preliminary due diligence with respect to the Qualifying Investment. This process seeks to prioritize resources and enables the Deal Team to conduct a high level review on the proposed investment for the principal purposes of highlighting the key risks and issues associated with the investment opportunity under review and developing indicative pricing for the assets in the case of Secondary Investments. Typical areas of focus at the preliminary due diligence stage may include:  Primary Fund Investments: investment strategy, quality of investor base, track record performance relative to other managers and applicable benchmarks, an assessment of the quality and/or capabilities of the team and preliminary review of legal terms  Secondary Investments: company or asset overview, industry, and sector analyses, competitive advantages and barriers to entry, assessment of pricing, financial modeling and exit opportunities, Investment Manager assessment and alignment of interests  Co-Investments and Direct Investments: company or asset overview, deal structure or downside mitigation, management, industry and sector analyses, competitive advantages and barriers to entry, assessment of pricing, financial modeling and exit opportunities Based on its findings, the Deal Team provides a Preliminary Investment Memorandum (PIM) to the relevant sub- committee for feedback. Once the Deal Team addresses the relevant sub-committee’s feedback, the Deal Team submits the PIM to the Principal Investment Committee, highlighting the key risks and issues associated with the investment opportunity under review and, in the case of Secondary Investments, indicative pricing for the interests. While the Deal Team produces the PIM, PMO prepares and circulates a preliminary assessment of the eligible GCM CFIG Funds for which the investment opportunity may be appropriate. Majority approval of the members of our Principal Investment Committee is required to move to comprehensive due diligence. 3. Comprehensive Due Diligence Comprehensive due diligence commences after Principal Investment Committee authorization. The designated deal team members for each investment opportunity complete comprehensive due diligence, typically including but not limited to:  on-site meetings with investment professionals of each potential Investment Manager or Co-Investment sponsor  an in-depth analysis of strategy, growth prospects, industry dynamics, management and potential conflicts  reference calls › regarding the Investment Manager that manages such Underlying Fund or Co-Investment and individual investment professionals of such Investment Manager, › to general partners and management of portfolio companies of comparable companies for Co-Investments or Direct Investments › to bankers that are in related industries or other similar Co-Investments or Direct Investments.  in the case of both Primary Fund Investments and Secondary Investments: › analysis of historical financial performance of the underlying investments of prior funds managed by such Investment Manager › evaluation of the unrealized investments of prior funds managed by such Investment Manager  additionally, in the case of a Secondary Investment › assessment of future exit timing and realization value for each underlying company › analysis of remaining unfunded commitments, including expected uses and return potential › evaluation of the future fees associated with the Underlying Fund, including the calculation of management fees and the expected allocation of distributions between the general partner and the limited partners and other elements of limited partner and general partner alignment  a review of each Co-Investment and Direct Investment’s capital structure, covenants, underwriting, and liquidity  a review and negotiation of the investment and economic terms and conditions In addition, at this stage, Operational Due Diligence and Legal commence their processes to evaluate investments from an operational and legal perspective. Operational Due Diligence and Legal:  evaluate the people, processes, and systems that support the Investment Manager’s infrastructure and operations  review and analyzes relevant legal, tax, and regulatory documentation  utilize independent third-party investigative firms to perform background checks of the Investment Manager, its key personnel, its target Underlying Funds, and the target company and its key management in the case of a Co- Investment 4. Principal Investment Committee, Operations Committee and Making Investment Decisions a. Investment Committee Memorandum (ICM) and Sub-Committee Review Upon completion of comprehensive due diligence with respect to a particular investment opportunity, the relevant deal team prepares an ICM or Pricing Sheet, as appropriate, for the Principal Investment Committee. The ICM discusses mitigating factors to the risks presented in the PIM relating to such investment opportunity, and typically contains:  For Primary Fund Investments: › an attribution analysis and portfolio revaluation to verify the Investment Manager’s stated performance and true source of returns › a detailed assessment of such Primary Fund Investment’s or Secondary Investment’s management team and that team’s record of value creation, including the results of extensive reference calls to other private equity managers, current and past limited partners and underlying portfolio companies  For a Secondary Investment, an appropriately detailed underwriting analysis and pricing recommendation given the characteristics of the Secondary Investment  For a Co-Investment, a detailed underwriting analysis The relevant investment sub-committee reviews the ICM. If the potential investment ultimately receives sub- committee support, the deal team prepares a Recommendation Memo (RM), which outlines the opportunity at a high level, economic terms, principal merits, and risks associated with the investment, among other information. b. Principal Investment Committee The Principal Investment Committee, which includes senior GCM Grosvenor investment professionals, makes the decisions to make and dispose of investments on behalf of most GCM CFIG Funds; certain GCM CFIG Funds have additional or alternate Investment Committee members or procedures. The Principal Investment Committee bases its decisions upon a variety of factors, including the merits of each individual investment and investment objectives, mandates, and restrictions of the GCM CFIG Funds after considering the findings contained in the related ICM and RM. The Principal Investment Committee meets on a regular basis. At the meetings, the Deal Teams present ICMs and RMs to the Principal Investment Committee and hold final discussions of the deal in question. In addition to approving investments, the Principal Investment Committee, also typically by majority vote, approves the eligible, participating GCM CFIG Funds and the maximum amount to be committed to Qualifying Investments on behalf of each eligible, participating GCM Fund. Following a particular investment decision, GCM CFIG conducts final legal negotiations and, upon agreement by the relevant parties, executes relevant documents. The size and composition of our Principal Investment Committee may change from time to time. c. Operations Committee The Operations Committee oversees GCM Grosvenor’s operational risk framework. In order to provide for the separation of duties between Investments and Operational Due Diligence, the Operations Committee works collaboratively with, but is independent of, Investments. Once Operational Due Diligence and Legal complete due diligence of a Qualifying Investment, the Operations Committee reviews and must approve from an operational perspective, a particular Investment Manager or sponsor and the particular Qualifying Investment managed by such Investment Manager or sponsor before GCM CFIG can invest the assets of a GCM CFIG Fund or recommend to a client that it invest its assets in such Qualifying Investment. Generally, the Operations Committee makes decisions by majority vote. In certain limited circumstances, the Operations Committee delegates the ability to unilaterally approve investments to the Chief Financial Officer, a member of the Operations Committee. The Chairman has the authority to veto any affirmative decision made by the Operations Committee. However, if the Operations Committee rejects an Investment Manager, Underlying Fund, Co-investment, or Direct Investment, the Chairman cannot override such rejection. See Operations Committee Charter. The size and composition of our Operations Committee may change from time to time. 5. Allocation of Investment Opportunities We and our affiliated adviser, GCMLP, have adopted global investment allocation policies and procedures designed to result in the fair and equitable allocation of investment opportunities in Underlying Funds among all eligible GCM CFIG Funds, GCM CFIG Investment Vehicles and investment vehicles managed or advised by GCMLP (GCMLP Funds, and collectively with GCM CFIG Funds and GCM CFIG Investment Vehicles, GCM Grosvenor Funds). Generally, our allocation methodology follows the same process for all types of investments, and may take into account a variety of relevant factors in determining eligibility, including the investment team primarily responsible for sourcing or performing due diligence on the transaction, the nature of the investment focus of each GCM Grosvenor Fund, the relative amounts of capital available for investment, anticipated expenses to the applicable GCM Grosvenor Fund and/or to GCM Grosvenor with regard to investment by the various GCM Grosvenor Funds, the investment pacing and timing of the GCM Grosvenor Funds and other considerations deemed relevant by GCM Grosvenor. In the event that the amount of available capacity from a particular Qualifying Investment is not sufficient to satisfy a full allocation to all eligible GCM Grosvenor Funds such that each eligible GCM Grosvenor Fund is allocated its target investment amount, it is our general policy to allocate the available capacity in the Qualifying Investment to the eligible GCM Grosvenor Funds pro rata among all eligible GCM Grosvenor Funds based on their respective total investor commitment targeted to the applicable investment strategy up to each participating eligible GCM Grosvenor Fund’s target investment amount. GCM Grosvenor may, in its discretion, adjust the target amount amongst Eligible GCM Grosvenor Funds for a variety of reasons, including the target investment pace, the remaining time until the expiration of the commitment period, and the investment strategy, which includes objectives and constraints for each GCM Grosvenor Fund or a minimum target investment size. In addition, GCM Grosvenor may, in its discretion, adjust the above allocations by limiting, or potentially prohibiting, an allocation to a GCM Grosvenor Fund for certain other legal or regulatory reasons. GCM Grosvenor may modify the pro rata allocations among eligible GCM Grosvenor Funds prior to the final applicable investment date for an investment opportunity, and may consider any relevant circumstances that it believes in good faith warrant such modification, including when the proposed allocation to an eligible GCM Grosvenor Fund is deemed de minimis or is otherwise impracticable (e.g., in light of the timing requirements necessary to implement an investment for a particular GCM Grosvenor Fund). 6. Allocation of Excess Investment Capacity Opportunities to invest in Qualifying Investments are often made available to GCM Grosvenor Funds on the basis of the total investments made in the aggregate by all GCM Grosvenor Funds, including GCM Grosvenor Funds that ordinarily do not invest in or have an investment focus on such Qualifying Investments, in the Underlying Funds or Co- Investments managed by the sponsor or source of the relevant Qualifying Investment. As a result, investments in Underlying Funds or Co-Investments by GCM Grosvenor Funds that do not invest in or have an investment focus on Qualifying Investments (Non-Participating Funds) may result in the generation of investment opportunities for GCM Grosvenor Funds that invest in or have an investment focus on Qualifying Investments (Participating Funds), without any compensating benefit being provided to Non-Participating Funds. Further, a sponsor or source of a particular investment opportunity might make such opportunity available to GCM CFIG and the GCM Grosvenor Funds in an amount greater than GCM CFIG, acting on behalf of GCM Grosvenor Funds, wishes to invest in such opportunity. In such a case, GCM CFIG may allocate such excess capacity or overage with respect to an investment opportunity to other parties, including parties who may pay fees to GCM CFIG in connection with allocating such opportunity, either in GCM CFIG’s discretion or pursuant to GCM CFIG’s agreements with such parties. Under certain circumstances, this could create an incentive for GCM CFIG to under-allocate such an opportunity to Participating Funds and over allocate such opportunity to such other parties. GCM CFIG recognizes that it has a fiduciary duty to the GCM CFIG Funds to act in good faith and with fairness in all of its dealings with them and will take such duties into account in dealing with all actual and potential conflicts of interest arising from the allocation of investment opportunities. Investment Strategies The GCM CFIG Funds generally invest in long-term private equity, real estate, or infrastructure investments, primarily through investing in Underlying Funds or in Co-Investments. The investment strategies used by the Investment Manager of a particular Primary Fund Investment to make investment decisions for such Underlying Fund may vary, sometimes significantly, from investment strategies implemented for Primary Fund Investments that have different Investment Managers. GCM CFIG Funds may invest in Qualifying Investments either directly or indirectly through special purpose vehicles formed for the purpose of investing in Operating Companies and other assets. Except as expressly prohibited in the GCM CFIG Fund Documents:  any investment in one class or series of securities of Operating Companies or other Co-Investments made by the GCM CFIG Funds or investors in such GCM CFIG Funds shall be made by such GCM CFIG Fund or such investors directly or indirectly through one or more special purpose vehicles  multiple GCM CFIG Funds or investors participating in a single investment will generally participate on the same terms In certain circumstances, it may be necessary or desirable for clients investing in a Co-Investment to invest in different ways. For example, to address accounting, tax, or regulatory considerations, one client invest directly in a Co-Investment while another may invest indirectly through an investment vehicle. If such investment vehicle is used to make an investment, the investor’s interests in such vehicle generally will be structured in a manner that would be reasonably expected to preserve, in all material respects, the overall economic relationship of the investors. Secondary Sales of Investments On occasion we may consider the sale of some or all of the investments of one or more GCM CFIG Funds (each, a Secondary Sale). We may consider a Secondary Sale of an investment on behalf of certain GCM CFIG Funds but not others. Reasons for a Secondary Sale can vary depending on the specific facts and circumstances associated with each GCM CFIG Fund. For example, a Secondary Sale could be considered for any of, but not limited to, the following reasons: at the specific request of a client, because a particular GCM CFIG Fund is approaching the end of its term, because GCM CFIG receives an unsolicited offer, or because the sponsor of a particular investment proposes a restructuring or other liquidity event. Risks and Other Special Considerations An investment in a GCM CFIG Fund is speculative and involves substantial risk, including the possible loss of the entire amount invested, due to, among other factors:  the nature of our investment programs  the significant continuing uncertainty in the global financial markets  significant fees and costs—including advisory, transaction and opportunity costs—associated with an investment in a GCM CFIG Fund
There can be no assurance that any GCM CFIG Fund will achieve its investment objectives or avoid significant losses. Past
performance is not necessarily indicative of future results, and the performance of the GCM CFIG Funds could be volatile.
You should not invest in a GCM CFIG Fund unless you have no need for liquidity with respect to the investment, you are fully able to bear the financial risks of the investment for an extended period of time, which may be longer than the GCM CFIG Fund’s stated term, and you are fully able to sustain the possible loss of the entire investment. You should consider an investment in a GCM CFIG Fund as a long-term investment that is appropriate only for a limited portion of your overall portfolio. Set forth herein are the general categories of risk that apply to investing in the GCM CFIG Funds. These risks are discussed in greater detail in the relevant GCM CFIG Fund Documents. Certain of these risks may be exacerbated in the case of GCM CFIG Funds with concentrated portfolios. These risks are not intended to be all inclusive. Reliance on Underlying Managers – GCM CFIG invests on behalf of clients primarily in private equity, infrastructure, and real estate funds and companies sponsored and managed by third parties. GCM CFIG generally does not have an active role in the management of the assets of the underlying funds or companies, including the valuation by the underlying funds of their investments. GCM CFIG’s ability to withdraw from or transfer interests in such funds and companies is limited. Further, the performance of each investment made by GCM CFIG depends significantly on decisions made by third parties, which could adversely affect the returns achieved by GCM CFIG. Identification and Availability of Investment Opportunities – The success of GCM CFIG Funds depends on the identification and availability of suitable investment opportunities. The availability of investment opportunities will be subject to market conditions and other factors outside the control of GCM CFIG. Past returns of GCM CFIG Funds have benefited from investment opportunities and general market conditions that may not recur, including favorable borrowing conditions in the debt markets, and there can be no assurance that Underlying Funds will be able to avail themselves of comparable opportunities and conditions. There can be no assurance that the Underlying Funds will be able to identify sufficient attractive investment opportunities to meet their investment objectives. Legal, Tax and Regulatory Risk – Legal, tax and regulatory developments may adversely affect a GCM CFIG Fund, Underlying Fund or Co-Investment during the term of the investment. The regulatory environment for private funds is evolving, and currently there are numerous legislative and regulatory proposals in the United States, Europe and other countries that could affect an Underlying Fund and its trading activities, and therefore could affect the GCM CFIG Funds. The GCM CFIG Investment Vehicles themselves may also be directly affected by such legislative and regulatory proposals because they also are structured as private funds. Changes in the regulation of private funds and their trading activities may adversely affect the ability of a GCM CFIG Investment Vehicle or Underlying Fund to pursue its investment strategy. There has been an increase in governmental, regulatory, and self-regulatory scrutiny of the alternative investment industry in general. It is impossible to predict what, if any, changes in laws and regulations may occur, but any laws and regulations that restrict the ability of a GCM CFIG Fund or Underlying Fund to make certain investments that could have a material adverse impact on a GCM CFIG Fund’s or Underlying Fund’s portfolio. A GCM CFIG Fund, an Underlying Fund, a Co-Investment, or GCM CFIG may also be subject to regulation in the jurisdictions in which they engage in business. Investors should understand that a GCM CFIG Fund’s, an Underlying Fund’s or a Co- Investment’s business is dynamic and is expected to change over time. Therefore, a GCM CFIG Fund, an Underlying Fund, or a Co-Investment may be subject to new or additional regulatory constraints in the future. The offering materials and any other documents received in connection with an investment in a GCM CFIG Fund, an Underlying Fund, or a Co-Investment cannot address or anticipate every possible current or future regulation or negative event that may affect the GCM CFIG Fund, the Underlying Fund or the Co-Investment, or GCM CFIG or its businesses. Such regulations and events may have a significant impact on the investors or the operations of the GCM CFIG Fund, the Underlying Fund, or the Co-Investment. Illiquidity Risk – An investment in a GCM CFIG Fund requires a long-term commitment, with no certainty of return. There most likely will be little or no near-term cash flow available to investors in GCM CFIG Funds. The securities issued by Underlying Funds and Co-Investments typically cannot be sold except pursuant to a registration statement filed under the U.S. Securities Act of 1933, as amended (Securities Act) or in a private placement or other transaction exempt from registration under the Securities Act and that complies with any applicable non-U.S. securities laws. As a result, a GCM CFIG Fund’s investments may be highly illiquid, and there can be no assurance that any GCM CFIG Fund will be able to realize on such investments in a timely manner. Similarly, the interests in a GCM CFIG Investment Vehicle generally will not be registered under the Securities Act or any other applicable securities laws. There may be no public market for such interests and none may be expected to develop. In addition, an investor in a GCM CFIG Investment Vehicle generally may not transfer its interest in a GCM CFIG Investment Vehicle without the consent of the manager of such GCM CFIG Investment Vehicle, which ordinarily may be withheld by the manager in its sole discretion. Investors in a GCM CFIG Investment Vehicle may not withdraw capital from a GCM CFIG Investment Vehicle and, as a result, may not be able to liquidate their investments prior to the end of the GCM CFIG Investment Vehicle’s term. Risks Associated with Portfolio Companies of Underlying Funds – The portfolio companies in which the Underlying Funds have invested or may invest may involve a high degree of business and financial risk. These companies may be in an early stage of development, may not have a proven operating history, may be operating at a loss or have significant variations in operating results, may be engaged in a rapidly changing business with products subject to a substantial risk of obsolescence, may require substantial additional capital to support their operations, to finance expansion or to maintain their competitive position, may have a high level of leverage, or may otherwise have a weak financial condition. In addition, these portfolio companies may face intense competition, including competition from companies with greater financial resources, more extensive development, manufacturing, marketing, and other capabilities, and a larger number of qualified managerial and technical personnel. In addition, during periods of difficult market conditions or slowdowns in a particular investment category, industry, or region, portfolio companies may experience decreased revenues, financial losses, and difficulty in obtaining access to financing and increased costs. During these periods, these companies may also have difficulty in expanding their businesses and operations and may be unable to pay their expenses as they become due. A general market downturn or a specific market dislocation may result in lower investment returns for the Underlying Funds in which a client invests, which would adversely affect investment returns. Substantial Fees and Expenses – Clients typically pay management fees, offering and organizational expenses and operational expenses as set forth in their governing documents, whether or not they make any profits. While it is difficult to predict the future expenses of clients, such expenses may be substantial. Please see Item 5 for additional information on fees and expenses. Portfolio Valuation – Valuations of a GCM CFIG Fund’s or an Underlying Fund’s portfolio, which may affect the amount of the management fee or performance fee or allocation payable to us, are expected to involve uncertainties and discretionary determinations. Third-party pricing information may not be available regarding a significant portion of a GCM CFIG Fund’s or Underlying Fund’s investments in certain asset classes, and in some circumstances we may rely on valuation models that we have created in order to value the assets and calculate the account value of the GCM CFIG Fund or the Underlying Fund. In addition, to the extent third-party pricing information is available, a disruption in the secondary markets for investments in Underlying Funds and Co-Investments may limit the ability to obtain accurate market quotations for purposes of valuing investments and calculating the net asset value of a GCM CFIG Fund’s or an Underlying Fund’s investments. Further, because of the overall size and concentrations in particular markets and maturities of positions that may be held by a GCM CFIG Fund or an Underlying Fund from time to time, the liquidation values of a GCM CFIG Fund’s or an Underlying Fund’s securities and other investments may differ significantly from the interim valuations of these investments derived from the valuation methods described herein. Absence of ICA Oversight – While a GCM CFIG Investment Vehicle or an Underlying Fund may be considered similar in some ways to an investment company, it is not required and does not intend to register as such under the ICA and, accordingly, its investors are not accorded the protections of the ICA. Similarly, GCM CFIG Funds that are not structured as legal entities are not subject to the ICA. Dependence on Key Personnel – The success of a GCM CFIG Fund may depend in substantial part on the skill and expertise of our personnel, as well as the skill and expertise of the personnel of Underlying Funds. There can be no assurance that we or any Underlying Fund will always be in a position to continue to employ skilled and experienced personnel. The loss of key personnel by us or an Underlying Fund could have a material adverse effect on a GCM CFIG Fund. Political Risk – Any new Executive Branch administration may involve changes in U.S. regulations and laws as well as economic and tax policy. There can be no certainty as to what actions any new administration will take in this regard and whatever the ultimate outcome of a new administration’s proposals, there is likely to be substantial uncertainty regarding the state and effect of financial regulation resulting from any regulatory changes. There can be no assurance that changes in U.S. economic and tax policy or to the regulation of the financial markets will not have a material adverse effect on the investments and investment strategies pursued by GCM Grosvenor Funds. Tax Treatment – There may be changes in tax laws or interpretations of such tax laws adverse to a GCM CFIG Fund, an Underlying Fund, a Co-Investment, or its investors. There can be no assurance that the structure of a GCM CFIG Fund, an Underlying Fund or a Co-Investment will be tax efficient to any particular investor. Also, there can be no assurance that a GCM CFIG Fund will have sufficient cash flow to permit it to make annual distributions in the amount necessary to permit its investors to pay all tax liabilities resulting from their interests in such GCM CFIG Fund. Prospective investors in GCM CFIG Funds are urged to consult their tax own advisers with reference to their specific tax situations. An Underlying Fund may, in an effort to minimize taxation, take certain tax positions and/or use certain tax structures that may in the future be disallowed or reversed, which could result in material tax expenses to such Underlying Fund. Follow-On Investments – A GCM CFIG Fund or an Underlying Fund may be called upon to provide additional funding for Co- Investments in which it has an investment, or may have the opportunity to increase its investment in such Co-Investments. There can be no assurance that a GCM CFIG Fund or an Underlying Fund will wish to make additional investments or that it will have sufficient available capital or funds to do so. Any decision by a GCM CFIG Fund not to make additional investments or its inability to make them may have a substantial negative impact on a Co-Investment in need of such an investment, may diminish the GCM CFIG Fund’s ability to influence the Co-Investment’s future development, or may result in reduced returns from the Co-Investment due to dilution. It is important to note that a GCM CFIG Fund may no longer be permitted to commit capital without investor approval and sufficient available capital or funds. Even with such approval and available capital or funds, the GCM CFIG Fund still may not be able to invest for various reasons. Reliance on Management of Co-Investments – While it is our intent to invest the assets of GCM CFIG Funds in Co- Investments with qualified operating management in place alongside qualified investment managers, there can be no assurance that such management will remain in place or continue to operate successfully. Although we will monitor the performance of Underlying Funds and Co-Investments, each GCM CFIG Fund will rely upon management to operate the Underlying Funds and Co-Investments on a day-to-day basis. Concentration and Performance Risk – Because each GCM CFIG Fund may only make a limited number of investments, and because those investments generally will involve a high degree of risk, poor performance by a few of the investments could severely affect the total returns to investors in the GCM CFIG Funds. Additionally, the performance of a GCM CFIG Fund or any other investment vehicle or account managed or advised by us or our affiliates are not necessarily indicative of the results that will be achieved by any other GCM CFIG Fund. Controlling Interest Liability – A GCM CFIG Fund or an Underlying Fund may have controlling interests in some of the Co- Investments in which it invests. The exercise of control over a Co-Investment may impose additional risks of liability for environmental damage, product defects, failure to supervise management, violation of governmental regulations (including securities laws) or other types of liability in which the limited liability generally characteristic of business ownership may be ignored. If these liabilities were to arise, the GCM CFIG Fund or Underlying Fund might suffer a significant loss. Risks upon Disposition of Investments – In connection with the disposition of an investment in a Co-Investment, a GCM CFIG Fund or an Underlying Fund may be required to make representations about the business and financial affairs of the Co-Investment of a type typically made in connection with the sale of any business, or may be responsible for the contents of disclosure documents under applicable securities laws. A GCM CFIG Fund or an Underlying Fund may also be required to indemnify the purchasers of such investment or the underwriters to the extent that any such representations or disclosure documents turn out to be incorrect, inaccurate, or misleading. These arrangements may result in contingent liabilities, which might ultimately have to be funded by the investors in the GCM CFIG Funds. GCM CFIG Fund Documents contain provisions to the effect that if there is any such claim in respect of a Co-Investment, it will be funded by the investors in such GCM CFIG Fund to the extent that they have received distributions from the GCM CFIG Fund, subject to certain limitations. Cybersecurity Risk – Cyberattacks and security vulnerabilities could result in a breach despite the various protections utilized by GCM Grosvenor and GCM Grosvenor vendors. A breach could potentially result in the disclosure of client data, the misuse of confidential or proprietary information, theft of assets, regulatory issues, or damage to the firm’s reputation. Foreign Investment Risk – Primary Fund Investments, Secondary Investments and Co-Investments in which the GCM CFIG Funds may invest (directly or indirectly through Underlying Funds) may be organized and operated outside of the United States. Such investments involve risks not typically associated with investments in securities issued by U.S. companies. For instance, investments in non-U.S. businesses:  may require significant government approvals under corporate, securities, exchange control, non-U.S. investment and other similar laws and regulations  may require financing and structuring alternatives and exit strategies that differ substantially from those commonly used in the United States  can expose the investing GCM CFIG Fund to potential losses arising from changes in foreign currency exchange rates on unrealized investments, uncalled capital commitments to investments and investment reserves. All of the foregoing factors, and others, may increase transaction costs and adversely impact the value of a GCM CFIG Fund’s investments in non-U.S. Co-Investments. To the extent a GCM CFIG Fund or Underlying Fund invests in Co- Investments that operate in emerging market countries, those investments involve certain risks not typically associated with investments in the securities of companies in more developed markets, including the direct and indirect consequences of potential political, economic, social, and diplomatic changes in those countries. The governments in those countries typically participate to a significant degree, through ownership interests or regulation, in local business, often exercising a controlling influence in certain key sectors of the economy. In emerging markets, these risks may be heightened. Unknown Impact of Brexit – The outcome of the June 23, 2016 United Kingdom (UK) referendum on whether to leave or remain a member state of the European Union (EU) was in favor of leaving. Under the process for leaving the EU contemplated in Article 50 of the Treaty on the Functioning of the European Union (TFEU), the UK would remain a member state until the EU and UK came to terms on a withdrawal agreement, or failing that, two years following the notification of the intention to leave. Article 50 was triggered on March 29, 2017, formally beginning the process for UK’s withdrawal from the EU. As of the date of this filing, the EU and UK have extended the date of UK’s exit from the EU to at least April 12, 2019, however the parties have not come to terms on a withdrawal agreement. Given the size and importance of the UK’s economy, (a) uncertainty or unpredictability about its legal, political and economic relationship with Europe; (b) any new laws or regulations adopted to replace those which cease to apply on leaving the EU; and (c) uncertainties relating to the possibility, or scope, of possible transitional arrangements to be agreed between the UK and the EU may be, or continue to be, a source of instability, create significant currency fluctuations, and/or otherwise adversely affect international markets, arrangements for trading or other existing cross-border co-operation arrangements (whether economic, tax, fiscal, legal, regulatory or otherwise) for the foreseeable future including beyond the date of the UK’s withdrawal from the EU or the expiration of any transitional arrangements which may be agreed. The outcome of the UK referendum could also have a destabilizing effect if other member states were to consider the option of leaving the EU. For these reasons, the decision of the UK to leave the EU could have materially adverse consequences on GCM Grosvenor Funds, the performance of their investments or investment strategies and their ability to source, identify, and invest in a sufficient number of opportunities to permit GCM Grosvenor Funds to sufficiently diversify their portfolios or to otherwise fulfill their investment objectives. As a result, this may have a materially adverse effect on the potential return on an investment in a GCM Grosvenor Fund. Non-Diversification Risk – The portfolio of a GCM CFIG Fund or an Underlying Fund may be subject to wider fluctuations in value if it is non-diversified than if it was subject to broader diversification requirements. For a complete discussion of a particular GCM CFIG Investment Vehicle’s investment strategies and the principal investments risks of those strategies, please read carefully the GCM CFIG Fund Documents received from us in connection with such GCM CFIG Fund. Conflicts of Interest In addition, GCM CFIG, GCMLP, our affiliated entities, and our related persons are subject to certain actual or potential conflicts of interest in conducting its business and making investment decisions for the GCM Grosvenor Funds and the Investment Managers are subject to similar as well as certain additional actual and/or potential conflicts of interest in managing their respective Underlying Funds. Some of these conflicts have been discussed throughout. Certain of these actual and potential conflicts of interest are discussed herein and in the current GCM Grosvenor Fund Documents provided to each prospective investor in a particular GCMLP Fund or GCM CFIG Fund, and/or in the document entitled GCM Grosvenor – Supplemental Disclosures Regarding Conflicts of Interest, a copy of which is available from us upon request. GCM Grosvenor currently provides or may in the future provide a broad spectrum of financial services, including, without limitation, investment advisory, broker-dealer, asset management, loan origination, capital markets, and idea generation services, to a variety of clients, including GCM Grosvenor Funds. GCM Grosvenor expects to sponsor, manage, and/or advise additional GCM Grosvenor Funds in the future, including GCM Grosvenor Funds that have investment objectives, programs, strategies and positions that are similar to or have interests adverse to each other. Because GCM Grosvenor has different financial services businesses and sponsors, manages, and/or advises multiple GCM Grosvenor Funds, it is subject to a number of actual and potential conflicts of interest, greater regulatory oversight and more legal and contractual restrictions than those to which it would otherwise be subject if it had only one line of business or sponsored, managed and/or advised only a single GCM Grosvenor Fund. Even if one GCM Grosvenor Fund has investment objectives, programs or strategies that are similar to those of another GCM Grosvenor Fund, GCM Grosvenor still gives advice or takes action with respect to the investments held by, and transactions of, the other GCM Grosvenor Funds that may differ from the advice given or the timing or nature of any action taken with respect to the investments held by, and transactions of, such GCM Grosvenor Fund for a variety of reasons, including, without limitation, differences between the investment strategy, financing terms, regulatory treatment and tax treatment of the other GCM Grosvenor Funds and such GCM Grosvenor Fund. As a result, one GCM Grosvenor Fund and another GCM Grosvenor Fund will likely have substantially different portfolios and investment returns. Prospective and existing investors in a GCM Grosvenor Fund should generally understand that (i) the relationships among such GCM Grosvenor Fund, the other GCM Grosvenor Funds and GCM Grosvenor are complex and dynamic; and (ii) as GCM Grosvenor’s and GCM Grosvenor Funds’ businesses change over time, GCM Grosvenor and its personnel will likely be subject, and such GCM Grosvenor Fund will likely be exposed, to new or additional conflicts of interest. In the ordinary course of business, and in particular in managing and making investment decisions for GCM Grosvenor Funds, GCM Grosvenor engages in activities in which its interests or the interests of certain GCM Grosvenor Funds may conflict with the interests of other GCM Grosvenor Funds and the investors in such GCM Grosvenor Funds. Such conflicts of interest could affect the objectivity of GCM Grosvenor and adversely affect one or more of the GCM Grosvenor Funds and/or the performance of the GCM Grosvenor Funds or returns to their investors. Certain of these actual and potential conflicts are summarized herein. In addition, each investor and prospective investor in a GCM Grosvenor Fund is urged to review carefully any relevant GCM Grosvenor Fund’s constituent or offering documents (GCM Grosvenor Fund Documents) for additional information regarding GCM Grosvenor’s business, such GCM Grosvenor Fund and the conflicts of interest to which GCM Grosvenor is subject. GCM Grosvenor maintains policies and procedures that address actual and potential conflicts of interest. In the event that a conflict of interest arises, GCM Grosvenor will generally attempt to resolve such conflict according to such policies and procedures and in a fair and equitable manner, on a case-by-case basis. GCM Grosvenor will take into consideration the interests of the relevant parties, including the interests of GCM Grosvenor, and the circumstances giving rise to the conflict in its resolution of conflicts. GCM Grosvenor will have the power to resolve, or consent to the resolution of, conflicts of interest on behalf of, and such resolution will be binding on, the GCM Grosvenor Funds. These resolutions include, without limitation, refraining from investing in or disposing of the investment, giving rise to the conflict of interest, appointing an independent party to provide approval on behalf of the relevant GCM Grosvenor Fund or consulting an investor advisory committee. GCM Grosvenor cannot resolve all conflicts of interest in a manner that is equitable or favorable to all GCM Grosvenor Funds and all investors in such GCM Grosvenor Funds and the investors in GCM Grosvenor Funds will generally have no means of confirming that any of such conflicts have, in fact, been equitably resolved. GCM Grosvenor has an inherent conflict of interest when identifying an issue as a conflict and when resolving conflicts of interest that involve its own interests. There can be no assurance that any actual or potential conflict of interest will not result in a less favorable outcome for the GCM Grosvenor Fund than if such conflict of interest did not exist. By investing in a GCM Grosvenor Fund, each investor will be deemed to have acknowledged and consented specifically to (i) the existence of such actual, apparent and potential conflicts of interest, including, without limitations, those described herein and in the relevant GCM Grosvenor Fund Documents; and (ii) the actions taken by GCM Grosv enor to address such conflicts and, to the extent permitted by applicable law, to have waived any claims with respect to the existence of any conflicts of interest. GCM Grosvenor Policies and Procedures Policies and procedures implemented by GCM Grosvenor in an effort to mitigate potential conflicts of interest and/or address certain regulatory requirements and contractual restrictions reduce the synergies that would otherwise exist across its various businesses and that GCM Grosvenor could otherwise draw on in pursuing attractive investment opportunities for GCM Grosvenor Funds. GCM Grosvenor has established compliance functions to administer GCM Grosvenor’s information sharing policies and procedures and to identify and monitor potential conflicts of interest. Although GCM Grosvenor Funds generally seek to leverage GCM Grosvenor’s firm-wide resources to help source, conduct due diligence on, structure, and create value for GCM Grosvenor Funds’ investments, the information sharing policies and procedures referenced above, as well as certain legal, contractual, and tax constraints and other considerations could significantly limit GCM Grosvenor Funds’ ability to do so. For example, GCM Grosvenor may come into possession of material non-public information with respect to (i) companies in which a GCM Grosvenor Fund is invested or is considering investing (each, a Portfolio Company); and/or (ii) companies that are current GCM Grosvenor clients. Due to the receipt of such information, GCM Grosvenor may be restricted from sharing such information with the GCM Grosvenor professionals responsible for making GCM Grosvenor Funds’ investment or divestment decisions or from making such investments or divestments, even where the disclosure of such information would be in the best interest of one or more GCM Grosvenor Funds or would otherwise influence the decisions taken by such investment professionals with respect to such actual or potential investment or divestment. Additionally, the terms of confidentiality or other agreements with or related to companies in which GCM Grosvenor has entered, either on its own behalf or on behalf of advisory clients of GCM Grosvenor, may restrict or otherwise limit the ability of a GCM Grosvenor Fund to make investments in or otherwise engage in businesses or activities competitive with such companies. GCM Grosvenor may also enter into one or more strategic relationships (e.g., in certain regions or with respect to certain types of investments) that, while intended to provide greater opportunities for a GCM Grosvenor Fund, may require such GCM Grosvenor Fund to share such opportunities or otherwise limit the amount of certain, or all such opportunities the GCM Grosvenor Fund could otherwise take. Accordingly, there can be no assurance that GCM Grosvenor Funds will be able to fully leverage all of the available resources and industry expertise of GCM Grosvenor. Additionally, there may be circumstances in which one or more individuals associated with GCM Grosvenor cannot provide services to one or more GCM Grosvenor Funds because of certain confidential information available to those individuals. Multiple GCM Grosvenor Funds GCM Grosvenor sponsors, manages, and/or advises multiple GCM Grosvenor Funds. The investment strategies pursued, and types of investments made, by the various GCM Grosvenor Funds can be similar to one another. Therefore, certain GCM Grosvenor Funds compete with other GCM Grosvenor Funds and/or Underlying Funds in identifying and seeking to acquire investments. GCM Grosvenor and its related persons might have an incentive to favor certain GCM Grosvenor Funds over other GCM Grosvenor Funds. For example, with regard to the selection of investment opportunities or the allocation of investment opportunities that have limited investment capacity, because GCM Grosvenor may receive greater compensation from the favored GCM Grosvenor Funds for its services or otherwise, including, without limitation, in arrangements without contingencies (such as a carried interest clawback or performance-based fee or allocation loss carryforward) or arrangements where the favored GCM Grosvenor Fund is associated with different expenses, including in light of an agreement by GCM Grosvenor to bear certain expenses on behalf of such GCM Grosvenor Fund. GCM Grosvenor and its related persons may also have an incentive to favor certain GCM Grosvenor Funds over other GCM Grosvenor Funds if GCM Grosvenor or its related persons have investments in such favored GCM Grosvenor Funds. Additionally, certain GCM Grosvenor Funds invest in other GCM Grosvenor Funds, and GCM Grosvenor may be authorized to vote with respect to the interests held by such investing GCM Grosvenor Funds and otherwise act as their representative with respect to GCM Grosvenor Funds in which such other GCM Grosvenor Funds invest (including, without limitation, serving as such investing GCM Grosvenor Funds’ representative on an advisory or similar committee). Investment in Different Parts of the Capital Structure GCM Grosvenor Funds may invest in companies in which GCM Grosvenor or one or more other GCM Grosvenor Funds also invest, either directly or indirectly through an Underlying Fund. Investments in a company by certain GCM Grosvenor Funds may be made prior to the investment by other GCM Grosvenor Funds, concurrently, including as part of the same financing plan or subsequent to the investments by such other GCM Grosvenor Funds. Any such investment by a GCM Grosvenor Fund may consist of securities or other instruments of a different class or type from those in which other GCM Grosvenor Funds are invested, and may entitle the holder of such securities or other instruments to greater control or to rights that otherwise differ from those to which such other GCM Grosvenor Funds are entitled. In connection with any such investments—including as they relate to acquisition, owning, and disposition of such investments—the GCM Grosvenor Funds may have conflicting interests and investment objectives, and any difference in the terms of the securities or other instruments held by such parties may raise additional conflicts of interest for the GCM Grosvenor Funds and GCM Grosvenor. For example, certain GCM Grosvenor Funds may invest in the common equity of a company that subsequently issues debt that is held, directly or indirectly, by one or more other GCM Grosvenor Funds; the interests of these two groups of investors in the company may under certain circumstances be unaligned or adverse—particularly in times of stress for the company. This conflict may be exacerbated to the extent that representatives of GCM Grosvenor serve on an advisory or other board or committee related to such company or GCM Grosvenor Funds’ investment in such company. In certain instances, GCM Grosvenor Funds and/or GCM Grosvenor may invest as a minority investor as part of a larger investing group or syndicate. In such cases, the financial sponsor, and not GCM Grosvenor, will be in the position to negotiate and potentially make decisions on behalf of the holders of the relevant class of equity or debt holders. GCM Grosvenor recognizes that conflicts arise under such circumstances and will endeavor to treat all GCM Grosvenor Funds fairly and equitably. To that end, GCM Grosvenor has adopted procedures that are designed to enable GCM Grosvenor to address such conflicts and to ensure that GCM Grosvenor Funds are treated fairly and equitably. Carried Interest, Performance-Based Fees and Allocations and Management Fees GCM Grosvenor sometimes receives carried interest or other performance-based fees or allocations that may create an incentive for GCM Grosvenor to make more speculative investments and determinations, directly or indirectly on behalf of GCM Grosvenor Funds, or otherwise take or refrain from taking certain actions than it would otherwise make in the absence of such carried interest or performance-based fees or allocations. In addition, GCM Grosvenor may have an incentive to make exit determinations based on factors that maximize economics in favor of GCM Grosvenor or its employees. Certain employees or related persons of GCM Grosvenor can receive directly a portion of GCM Grosvenor’s carried interest or performance-based fees or allocations with respect to one or more GCM Grosvenor Funds, which may similarly influence such employees’ or related persons’ judgments. In connection therewith, any clawback obligation may create an incentive for GCM Grosvenor to defer disposition of one or more investments if such disposition would result in a realized loss and/or the finalization of dissolution and liquidation of a GCM Grosvenor Fund where a clawback obligation would be owed. GCM Grosvenor receives management fees in respect of certain GCM Grosvenor Funds on an as invested basis or only in respect of invested capital where GCM Grosvenor may have an incentive to make investments more quickly, or at all, or defer disposition or the write-off of investments, for such GCM Grosvenor Funds in order to earn management fees that it otherwise would not, absent such a fee arrangement. Other Fees GCM Grosvenor may earn fees or similar compensation in a variety of ways, including from or in connection with services provided or related to portfolio investments or in connection with actual or potential investments, including, without limitation, board of directors’ fees and supervisory/monitoring fees with respect to investments and other fees, break-up and similar transaction fees, and may receive these fees on an accelerated basis in connection with certain transactions. Except as otherwise disclosed, GCM Grosvenor Fund investors will not receive the benefit of fees or other compensation received by GCM Grosvenor in connection with the provision of services by GCM Grosvenor to GCM Grosvenor Funds or third parties. Other GCM Grosvenor Business Activities GCM Grosvenor and its related persons may engage in any activities, including, without limitation, a broad range of advisory, capital markets and other businesses or ventures. GCM Grosvenor has no obligation to make investment or other opportunities in any such businesses or ventures available to any GCM Grosvenor Fund or to the investors in any GCM Grosvenor Fund. Except to the extent GCM Grosvenor determines otherwise, in connection with its other businesses and ventures, GCM Grosvenor may enter into agreements related to clients or potential investments, restricting the ability of the GCM Grosvenor Funds to make certain investments or engage in certain activities, which would otherwise be of benefit to the GCM Grosvenor Funds. In addition, from time to time, GCM Grosvenor will provide services beyond those currently provided. GCM Grosvenor Funds will not participate in the risks or rewards of such businesses or ventures and the investors in the GCM Grosvenor Funds will not receive a benefit from fees generated by such activities. Further, such businesses and ventures (i) compete with the GCM Grosvenor Funds for GCM Grosvenor’s time and attention (as well as the time and attention of GCM Grosvenor’s related persons); and (ii) potentially create additional conflicts of interest or raise other special considerations. Conflicts of interest resulting from the foregoing include the allocation of management time among GCM Grosvenor Funds and other clients of GCM Grosvenor. Nothing in the governing documents of any GCM Grosvenor Fund generally (i) requires GCM Grosvenor and its affiliates to devote their full business time to the business and affairs of any particular GCM Grosvenor Fund or to the business and affairs of the GCM Grosvenor Funds in general; (ii) limits or restricts GCM Grosvenor or its related persons from engaging in and devoting time and attention to other businesses or ventures or from rendering services of whatever kind or nature; or (iii) restricts GCM Grosvenor or its related persons from forming additional investment funds, from entering into investment advisory relationships or from engaging in other business activities. As GCM Grosvenor sponsors, advises, and/or manages numerous GCM Grosvenor Funds, the officers and employees of GCM Grosvenor may not spend a significant portion of their time on matters related to any particular GCM Grosvenor Fund, and GCM Grosvenor or its personnel may have financial or other incentives to favor certain GCM Grosvenor Funds over other GCM Grosvenor Funds. Additionally, potential investments by GCM Grosvenor Funds are subject to approval by a GCM Grosvenor investment, operations, or other committees, whose professionals serve this function for all or certain GCM Grosvenor Funds. It is expected that an investment, operations or other committees and its professionals will face additional conflicts of interest in allocating their time, attention, and potential investment opportunities among GCM Grosvenor Funds. In addition, as permitted by law, GCM Grosvenor and its related persons, in investing and trading for its proprietary accounts may make use of information obtained by GCM Grosvenor in the course of investing for the GCM Grosvenor Funds. GCM Grosvenor does not generally establish information barriers between internal investment teams. GCM Grosvenor and its related persons will have no obligation to compensate any GCM Grosvenor Fund (or any investor therein) in any respect for its receipt of such information or to account to any GCM Grosvenor Fund (or any investor therein) for any profits earned from GCM Grosvenor’s or its related persons’ use of such information. In addition, while GCM Grosvenor maintains compliance policies and procedures, including personal trading policies, which please register to get more info

We are required to disclose to you all legal and disciplinary events relating to us or to our personnel that are material to your evaluation of our advisory business or the integrity of our management. To the best of our knowledge, there are no legal or disciplinary events relating to us or our personnel that are material to your evaluation of our advisory business or the integrity of our management. please register to get more info

Affiliated Registered Investment Adviser We are under common control with GCMLP, an investment adviser registered as such with the SEC. GCMLP is also registered with the Commodity Futures Trading Commission as a commodity pool operator and a commodity trading advisor, and is a member of the National Futures Association. Since 1971, GCMLP and its predecessors have specialized in providing hedge fund investment management and advisory services to their clients. While we share certain operational infrastructure with GCMLP, we generally maintain separate investment teams and investment processes. However, investment and non-investment personnel are encouraged to collaborate with their colleagues at GCMLP, and investment opportunities sourced by us or by GCMLP may be allocated pursuant to GCM Grosvenor’s policies across the enterprise. Affiliated Investment Managers GCM Investments UK LLP (GCM UK), an affiliate of GCM Grosvenor, is a UK based firm that provides certain services to GCM Grosvenor. GCM UK is authorized and regulated by the UK Financial Conduct Authority to provide investment advisory and arranging services to professional investors. GCM UK seeks to obtain information on and access to UK and Europe based investment managers and to furnish GCM Grosvenor advice with respect to such managers. In addition, employees of GCM UK meet with existing and prospective clients of GCM Grosvenor in the UK and Europe and assist employees of GCM Grosvenor when they are present in the UK. As compensation for the services GCM UK performs, GCM Grosvenor pays GCM UK a service fee based on a percentage mark-up over the cost of providing such services. GCM UK has an incentive to introduce GCM Grosvenor Funds to GCM UK’s clients because additional investments in such products will result in additional investment management or advisory fees for GCM Grosvenor. In cases where GCM UK provides investment advisory or arranging services to investors, such investors will be informed of the affiliation between GCM Grosvenor and GCM UK, and thus will be aware of this incentive prior to the time they invest in a GCM Grosvenor Fund. GCM Investments Hong Kong Limited (GCM HK), an affiliate of GCM Grosvenor, is located in Hong Kong. GCM HK is licensed to deal in securities (Type 1) and advise on securities (Type 4) by the Hong Kong Securities and Futures Commission. It seeks to obtain information on and access to Asia-based investment managers and provides GCM Grosvenor advice with respect to such managers. In addition, employees of GCM HK provide ongoing client service to GCM Grosvenor clients in Asia and assistance to employees of GCM Grosvenor when they are traveling in Asia. As compensation for the services GCM HK performs, GCM Grosvenor pays GCM HK a service fee based on a percentage mark-up over the cost of providing such services. GCM Japan (as defined herein) may act as a discretionary investment manager on behalf of clients in Japan and, in that connection, may allocate client assets to one or more investment vehicles managed or advised by GCMLP or GCM CFIG. Affiliated Placement Agents/Distributor Our affiliate, GRV Securities LLC (GSLLC), serves as placement agent or distributor for certain GCM Grosvenor Funds. GSLLC, a Delaware limited liability company of which we are the sole common member, is registered as a broker-dealer under the Exchange Act and is a member of the Financial Industry Regulatory Authority, Inc. GSLLC’s sole functions with respect to GCM CFIG is to act as a private placement agent for certain securities (including interests in certain GCM Grosvenor Funds). Pursuant to a Master Placement Agent Agreement, we and GCMLP compensate GSLLC on a flat annual fee basis for the placement agent and distribution services provided by GSLLC, regardless of the success of GSLLC’s services. GSLLC has no employees. However, certain of our employees, including many of our executive-level employees, are registered as representatives of GSLLC so that they may engage in private placement activities on behalf of certain GCM Grosvenor Funds. We are exclusively responsible for compensating such employees, and neither we nor GSLLC pays any sales commissions to any such employees in connection with the private placement activities they perform on behalf of the GCM Grosvenor Funds. GCM Investments Japan K.K. (GCM Japan), an affiliate of GCM Grosvenor, is located in Tokyo, Japan. GCM Japan is registered as a securities company in Japan with the Kanto Local Finance Bureau. GCM Japan may act as placement agent for certain GCM Grosvenor Funds that are privately offered in Japan to Japanese investors, provide ongoing services to Japanese investors in such vehicles and provide research services to GCM Grosvenor. GCM Grosvenor may compensate GCM Japan for such placement agent services with an asset-based fee and may compensate GCM Japan for ongoing client and research services based on a percentage mark-up over the cost of providing such services. GCM Japan is exclusively responsible for compensating its employees, and neither GCMLP or GCM CFIG, nor GCM Japan, pays any sales commissions to such employees in connection with the private placement activities they perform. GSLLC and GCM Japan have an incentive to introduce GCM Grosvenor Funds to prospective investors, because additional investments in such products will result in additional investment management or advisory fees for GCM Grosvenor. However, all prospective investors are informed of the affiliation between GCM Grosvenor and GSLLC or GCM Japan, as applicable under the circumstances, and are thus aware of this incentive prior to the time they invest funds in a GCM Grosvenor Fund. Other Affiliates GCM Investments (Korea) Co. Ltd. (GCM Korea), an affiliate of GCM Grosvenor, is located in Seoul, South Korea. The activities of GCM Korea are not regulated in South Korea. GCM Korea provides ongoing services to Korean clients in investment vehicles or accounts managed by GCM Grosvenor. In addition, employees of GCM Korea provide assistance to employees of GCM Grosvenor when they are present in South Korea. GCM Grosvenor may compensate GCM Korea for ongoing client services based on a percentage mark-up over the cost of providing such services. GCM Korea does not introduce GCM Grosvenor Funds to prospective Korean clients. Affiliated General Partners We are affiliated with certain general partners (as disclosed in the ADV Part 1 Schedule D Section 7.A.1) of certain GCM CFIG Investment Vehicles. Such affiliated general partners are ultimately controlled by GCM Grosvenor. The management and control of each GCM CFIG Investment Vehicle is vested exclusively in its general partner or similar managing entity (each, a GP or Manager). We use the term GP or Manager also to apply to the managing entity of a GCM CFIG Investment Vehicle that is not structured as a partnership, such as the managing member of a GCM CFIG Investment Vehicle that is structured as a limited liability company. Typically, the GP or Manager of each GCM CFIG Investment Vehicle is our affiliate. The investors in the GCM CFIG Investment Vehicles generally have no part in the management or control of the GCM CFIG Investment Vehicles and have no authority or right to act on behalf of the GCM CFIG Investment Vehicles in connection with any matter. The Manager of each GCM CFIG Investment Vehicle has delegated certain of its rights, power, authority, duties, and responsibilities to us pursuant either to:  such GCM CFIG Investment Vehicle’s Documents, including any applicable side letter agreements, which are negotiated on a case by case basis  an investment advisory or investment management agreement please register to get more info

Personal Trading Code of Ethics We have adopted a Code of Ethics pursuant to Rule 204A-1 under the Advisers Act and Rule 17j-1 under the ICA (Code of Ethics). The Code of Ethics outlines the Firm’s duties of care and loyalty; the standards of conduct required of all covered persons; and the requirements applicable to outside business activities, conflicts of interest, and personal trading. Our personnel have several basic obligations under the Code of Ethics: (1) act consistently with our fiduciary duties to our clients (2) comply with applicable federal securities and commodities laws (3) understand and adhere to the Firm’s compliance policies and procedures (4) periodically submit certain statements or certifications to us (5) obtain pre-clearance from us in connection with certain types of activities and transactions (Pre-Clearance Transactions), including (under certain circumstances) investments in securities issued in private placements or in initial public offerings (6) refrain from engaging in certain types of prohibited transactions Compliance may deny an employee’s request to engage in a Pre-Clearance Transaction or revoke approval of a previously approved Pre-Clearance Transaction if they determine:  such employee is delinquent in filing reports required to be filed by such employee pursuant to the Code of Ethics  such transaction or activity involves a company on the Restricted List  such employee may unfairly benefit from such transaction or activity at the expense of our or our affiliate’s clients  such employee may benefit from such transaction or activity as a result of information that is proprietary to us, any of our affiliates or any of our affiliates’ clients  such transaction or activity involves, or appears to involve, a conflict between the interests of such employee or us and those of any of our or our affiliates’ clients  such transaction or activity involves undue litigation, regulatory, enforcement or reputational risk to us  such transaction or activity is otherwise prohibited or conflicts with the terms and conditions of the Code of Ethics In applying the foregoing criteria, Compliance may take such facts and circumstances into account as appropriate. We will provide you a copy of our Code of Ethics upon your request. please register to get more info

In our capacity as the investment manager of or investment adviser to the GCM CFIG Funds, we are a fiduciary that owes the following duties, among others, to the GCM CFIG Funds in connection with all transactions in securities where we have the power and authority to effect such transactions for the GCM CFIG Funds:  to seek best price and best execution in connection with such transactions, where applicable to such transaction  to effect such transactions in a manner that is fair to all affected GCM CFIG Funds  to exercise diligence and care throughout the transaction process The GCM CFIG Funds ordinarily invest in Underlying Funds directly with such Underlying Funds without the involvement of a financial intermediary such as a broker-dealer. Commissions are typically not payable in connection with such investments. However, the GCM CFIG Funds may from time to time acquire or dispose of interests in Underlying Funds in private secondary market transactions. In general, the number of financial intermediaries active in the private equity fund secondary market is small. The commissions charged by such intermediaries may vary significantly from intermediary to intermediary, and from transaction to transaction. Our investment strategies generally do not involve the direct purchase of publicly traded securities, either in the over-the- counter or exchange markets. However, in certain cases, Underlying Funds in which the GCM CFIG Funds invest may make, to the GCM CFIG Funds, in-kind distributions of publicly traded securities issued by Operating Companies held by such Underlying Funds. Also, in certain cases, Operating Companies whose securities were acquired by the GCM CFIG Funds in private transactions may register those securities for public resale. Finally, the GCM CFIG Funds may, with the prior written authorization of our Principal Investment Committee, purchase publicly traded securities in the over-the-counter or exchange markets. To the extent that the GCM CFIG Funds that we manage on a discretionary basis purchase or sell securities in the public markets, we have the authority to determine the financial intermediaries to be used in connection with such purchases or sales and to negotiate the commissions or other transactional compensation to be paid to such intermediaries in connection with such purchases or sales; which commissions or other compensation are borne by the affected GCM CFIG Funds. In determining which financial intermediaries to use to effect purchases and sales of securities on behalf of the GCM CFIG Funds, we focus on the quality of the execution-related services provided by the intermediaries, including factors such as the ability of the intermediaries to execute transactions efficiently, their responsiveness to instructions, their facilities, their reliability, and their financial stability. We do not necessarily select those that charge the lowest commissions or other transactional costs. To the extent that GCM CFIG Funds that we advise on a non-discretionary basis purchase or sell securities in the public markets, we do not have the authority to determine the financial intermediaries used in connection with such transactions. Accordingly, we cannot negotiate the commissions or other transactional compensation to be paid to such intermediaries in connection with such transactions, unless the investor in the relevant GCM CFIG Fund expressly confers that authority on us and we agree to accept such authority. In all such cases, the commissions or other compensation are borne by the relevant GCM CFIG Funds. We currently do not have any formal soft dollar arrangements. We may from time to time use financial intermediaries that provide research-related products or services to most or all of their customers, and although we do not request research- related products or services from such financial intermediaries, we may on occasion receive and use research provided by such intermediaries. Access to such research is not contingent on any level of trading or commissions generated, and we believe such research is available to all institutional money managers of similar size. Further, since the research provided is not material in nature and quantity and is provided to us without our request, we believe that our receipt of such research does not have a material effect on our selection of financial intermediaries. please register to get more info

We manage the GCM CFIG Funds in accordance with the investment objectives, mandates and client-imposed restrictions set forth in GCM CFIG Funds’ Documents, representations made to relevant investors in the GCM CFIG Funds and applicable regulatory restrictions. The investments made by GCM CFIG Funds generally are long-term in nature. Accordingly, the review process is not directed toward a short-term decision to purchase or sell securities. However, we carefully monitor Primary Fund Investments, Secondary Investments, and Co-Investments in which the GCM CFIG Funds invest. GCM Grosvenor reviews GCM CFIG Funds on an on-going basis and provides reports in a manner, and on a frequency, as may have been negotiated with the investors in the GCM CFIG Funds. In addition, investors in the GCM CFIG Funds generally are provided with periodic reports and relevant tax reporting information. Special reports may be developed to meet specific investor requirements or respond to inquiries. For each GCM CFIG Fund that is an entity, and for which we have custody (as further described in Item 15 – Custody), we deliver or cause to be delivered to each person who was an investor in such GCM CFIG Fund at any time during such fiscal year a written report containing audited financial statements of the GCM CFIG Fund for such fiscal year. Such audited financial statements generally include or are accompanied by:  notes to the financial statements  a statement of assets, liabilities, and investors’ capital, including a condensed schedule of investments  a statement of operations  a statement of changes in investors’ capital  a statement of cash flows  the financial statements of any GCM CFIG Fund in which such GCM CFIG Fund invests In the case of Customized GCM CFIG Funds, our investment management or investment advisory services are tailored to the needs of the individual investors in such Customized GCM CFIG Funds. Investors may impose reasonable guidelines, mandates, or restrictions to customize an investment strategy or satisfy legal, regulatory, tax or other special concerns. Different Reporting Packages Different investors, including different investors in the same GCM CFIG Fund, as well as certain other persons, including (i) persons to whom we provide investment advisory services on a non-discretionary basis and (ii) persons who currently have, or who previously have had, an interest in us or who otherwise currently are, or who previously have been, associated with us, receive oral and/or written reports from us that differ in form, substance, level of detail, timing and/or frequency. Recipients of our oral and written reports should be aware that:  we do not permit such recipients to copy, transmit or distribute such reports, or any data or other information contained therein, in whole or in part, or authorize such actions by others, without our express prior written consent, and any such action taken without our express prior written consent may constitute a breach of contract and applicable copyright laws  by their receipt of such reports, such recipients will be deemed to have acknowledged that: (i) the data and/or other information contained therein may include data and/or information that, under applicable law, may be deemed to be material, non-public information regarding particular securities and/or the issuers thereof; (ii) under certain circumstances, United States securities laws prohibit the purchase and sale of securities by persons or entities who are in possession of material, non-public information relating to such securities and/or the issuers thereof; (iii) securities laws of other jurisdictions may contain a similar prohibition; and (iv) as a result, it is possible that trading in securities that are the subject of data and/or information contained in such reports may be prohibited by law If you are a recipient of our oral or written reports, we strongly urge you to review your own policies and procedures relating to the possible receipt of confidential or material, non-public information to ensure that any information that you receive from us relating to particular securities and/or the issuers thereof will not be used in any manner that conflicts with applicable laws. please register to get more info

We may enter into a written agreement with a referrer or solicitor pursuant to Rule 206(4)-3 under the Advisers Act. Pursuant to such an agreement, we would provide the referrer or solicitor with this Brochure and a related disclosure document (Disclosure Document). The referrer or solicitor would then be required to deliver to each prospective participant in a GCM CFIG Fund at the time of solicitation:  this Brochure  the Disclosure Document  a written disclosure statement on the solicitor’s letterhead that: › advises the participant of the nature of the relationship between us and the referrer or solicitor › includes a statement that we will compensate the referrer or solicitor for the services it provides under the referral or solicitation agreement and indicates the terms of such compensation arrangement, including a description of the compensation paid or to be paid by us to the referrer or solicitor under the referral/solicitation agreement › indicates whether the participant will be charged amounts in addition to the investment advisory fee in connection with the referral or solicitation agreement Non-Affiliated Placement Agents From time to time, we engage non-affiliated placement, distribution, or similar agents to assist us in marketing interests in our investment products. If you acquire an interest in any of our investment products as a result of a recommendation made by any such placement, distribution or similar agent, you should not view such recommendation as being disinterested, as we generally will pay the agent for the introduction. To the extent that such agent is compensated by GCM Grosvenor, such compensation will be separately disclosed to investors. please register to get more info

Pursuant to the Advisers Act—which imposes certain requirements on SEC-registered investment advisers that have custody of client funds or securities—we are deemed to have custody of the funds and securities of certain GCM CFIG Funds even though:  subject to certain SEC-permitted exceptions, we and our affiliates do not physically hold the funds or securities of such GCM CFIG Funds  the funds and securities of such GCM CFIG Funds are not held or registered in our name or in the name of any of our affiliates Although we are deemed, under applicable rules, to have custody of the funds and securities of certain GCM CFIG Funds that are entities, we are generally exempt from many of the provisions of the custody rule because we undertake to deliver to the investors, within 120-180 days after the end of the fiscal year of such GCM CFIG Fund, financial statements that are:  prepared in accordance with U.S. GAAP, or with accounting principles other than U.S. GAAP under certain circumstances  audited by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board please register to get more info

In the case of GCM CFIG Funds over which we exercise investment discretion, we sometimes have sole discretion without consent of the investors, as to which securities will be bought or sold, and in what amount. Certain investors may have greater involvement in the investment process. The governing documentation for a GCM CFIG Fund may, however, place certain restrictions on the type and amount of securities that we can buy on behalf of such GCM CFIG Fund. In certain cases we serve in a non-discretionary capacity where the investor in a GCM CFIG Fund maintains discretion over which securities may be bought and sold, in which amount and when. Such a non-discretionary arrangement would be described in such GCM CFIG Fund Documents. In certain cases where we have been granted discretionary investment authority over GCM CFIG Funds, the investors in those GCM CFIG Funds have informally reserved the right to approve or not approve our investment decisions for those GCM CFIG Funds prior to the implementation of such decisions. please register to get more info

Background From time to time, GCM CFIG receives requests from Investment Managers or other parties (other than a client) to vote a security held by a GCM CFIG Fund, or to vote on any matter (or consent to any action) relating to a Project Agreement (Proxy Request). GCM CFIG seeks to vote Proxy Requests in the best interests of our clients for which we have the authority to vote. GCM CFIG’s authority to vote or make recommendations for GCM CFIG Funds is based on regulatory requirements, any arrangements made with the client and whether we have investment discretion. GCM CFIG has adopted policies and procedures that establish standards for the proxy voting process, identification, and management of conflicts of interest and client disclosure obligations. You may request a copy of our Proxy Voting Policies and Procedures (Proxy Voting Policy), that are summarized herein, or request an opportunity to review our proxy voting records, by contacting our Investor Relations Team (telephone: +1.855.426.9321; e-mail: client.services@gcmlp.com). General Policy to Take Action in Response to Proxy Requests GCM CFIG votes Proxy Requests considering the available facts and in a manner consistent with the Proxy Voting Policy and GCM CFIG’s fiduciary duties. GCM CFIG considers relevant information and evaluates other issues that could have an impact on the value of such securities. In general, GCM CFIG votes Proxy Requests to try to maximize the overall value of the affected GCM CFIG Funds. When responding to Proxy Requests, GCM CFIG seeks to:  identify and takes action on Proxy Requests in a timely manner  address any conflicts of interest appropriately In the case of a GCM CFIG Fund over which GCM CFIG exercises investment discretion, GCM CFIG takes action in response to each Proxy Request that it receives in connection with managing such GCM CFIG Fund unless:  such GCM CFIG Fund is a single investor or participant GCM CFIG Fund;  GCM CFIG has agreed in writing with the single investor or participant that GCM CFIG is not required to take action in response to Proxy Requests for an affected GCM CFIG Fund, unless subject to ERISA; and  GCM CFIG has agreed in writing with the single investor or participant that GCM CFIG will not take action in response to Proxy Requests for an affected GCM CFIG Fund. In the case of a GCM CFIG Fund over which GCM CFIG does not have investment discretion, if requested to do so by the investors in the fund, GCM CFIG will recommend the action that an affected GCM CFIG Fund should take in response to any received Proxy Request unless:  the affected GCM CFIG Fund is a single investor or participant GCM CFIG Fund that is subject to ERISA; or  an appropriate authorized fiduciary of the single investor or participant has agreed in writing that: › a party associated with such single investor or participant (e.g., the plan sponsor of such single investor or participant) has reserved the authority and right to take actions in response to Proxy Requests relating to the investments in the affected GCM CFIG Fund; and › GCM CFIG will not make recommendations with respect to Proxy Requests for the affected GCM CFIG Fund. In certain cases, however, operating agreements between GCM CFIG and its investors may permit GCM CFIG to abstain from acting on a Proxy Request or from recommending what action should be taken with respect to a Proxy Request. An example of such instance is where the expected cost or administrative burden of giving due consideration to the Proxy Request does not justify the potential benefits to the affected GCM CFIG Funds that might result from adopting or rejecting the proposals in question. Investment Discretion and Client Instructions With respect to GCM CFIG Funds over which we exercise investment discretion, we ordinarily do not consult with investors prior to acting on Proxy Requests relating to held investments. In certain cases, however, investors in such accounts may reserve the right in operating agreements to approve or disapprove of GCM CFIG’s decisions with respect to acting on Proxy Requests for the affected GCM CFIG Funds. GCM CFIG reviews each Proxy Request to determine if acting on such Proxy Request would be in the best interest of the affected GCM CFIG Funds and its investors. As a result, depending on the particular circumstances of different GCM CFIG Funds, GCM CFIG may vote the securities of one GCM CFIG Fund differently than it votes those of another GCM CFIG Fund, or may vote differently on various proposals, even though the securities or proposals are similar or identical. Conflicts Generally, conflicts of interest will be identified by members of our Principal Investment Committee as well as individuals involved in the proxy voting process and brought to the attention of our Global Chief Compliance Officer (CCO) or designee. The CCO or designee will determine the materiality of the conflict, unless subject to ERISA, and in consultation with other GCM CFIG personnel, determine the appropriate course of action. For GCM CFIG Funds subject to ERISA, GCM CFIG does not respond to a Proxy Request until all conflicts have been cured or avoided to the satisfaction of the CCO or its designee. please register to get more info

We are required to disclose any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to our clients. We have no financial condition that impairs or is reasonably likely to impair our ability to meet our contractual commitments to our clients, and we have never been the subject of any bankruptcy petition. please register to get more info