ABRA CAPITAL MANAGEMENT, LP

Item 1 - Cover Page Part 2A of Form ADV (the “Brochure”) Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 March 2026 This Brochure provides information about the qualifications and business practices of Abra Capital Management, LP (“ACM”), a registered investment adviser. Registration does not imply a certain level of skill or training but only indicates that ACM has registered its business with state and federal regulatory authorities, including the United States Securities and Exchange Commission (“SEC”). If you have any questions about the contents of this Brochure, please contact us at acm@abra.com. The information in this Brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about Abra Capital Management, LP, is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 - Summary of Material Changes Abra Capital Management LP does not consider the revisions in this version of its Brochure to be materially different from the disclosures contained in its most recent other than annual amendment dated February 2026. The updates primarily clarify, reorganize, and refine existing language, including separating and consolidating certain sections, in order to improve readability and reduce potential ambiguity, duplication, or inconsistency. Item 4. Advisory Business. Abra Financial Holdings Inc., the indirect parent company of Abra Capital Management LP, has publicly announced that it has entered into a definitive business combination agreement with New Providence Acquisition Corp III (NASDAQ: NPAC). Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 2  Item 3 - Brochure Table of Contents Item 1 - Cover Page ...................................................................................................................................... 1 Item 2 - Summary of Material Changes........................................................................................................ 2 Item 3 - Brochure Table of Contents............................................................................................................. 3 Item 4 – Advisory Business .......................................................................................................................... 4 Item 5 – Fees and Compensation .................................................................................................................. 7 Item 6 – Performance-Based Fees and Side-by-Side Management ............................................................ 11 Item 7 - Types of Clients ............................................................................................................................. 11 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 12 Item 9 – Disciplinary Information .............................................................................................................. 21 Item 10 - Other Financial Industry Activities and Affiliations ................................................................... 22 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 23 Item 12 - Brokerage Practices ..................................................................................................................... 24 Item 15 – Custody ....................................................................................................................................... 29 Item 16 - Investment Discretion ................................................................................................................. 31 Item 17 - Voting Securities ......................................................................................................................... 32 Item 18 - Financial Information .................................................................................................................. 33 3  Item 4 – Advisory Business Company Description, Length of Business, and Principals Abra Capital Management, LP (“ACM” or “Firm” or “Adviser”), a Delaware limited partnership formed in August 2022 maintains its principal office at 1160 Battery Street East, Suite 100 San Francisco, California 94111. ACM registered with the Securities Exchange Commission as an investment adviser in 2024. Abra Capital Management LLC, a Delaware limited liability company, serves as ACM’s general partner and owns 100% controlling interest. Abra Financial Holdings, Inc., (“AFH”), a Delaware corporation, is both the sole owner and Managing Member of Abra Capital Management. LLC. (collectively referred to as “Abra”). AFH, the indirect parent company of ACM has publicly announced that it has entered into a definitive business combination agreement with New Providence Acquisition Corp III (NASDAQ: NPAC). Abra is focused specifically on Digital Assets (defined below) with the Adviser focused on wealth management strategies for clients seeking exposure. Abra was founded by Bill Barhydt. Key leadership of the Adviser is Marissa Kim (Head of Asset Management). these conflicts ACM enters into intercompany arrangements with affiliates for technology, operational, and support services. These arrangements create conflicts of interest, including potential economic benefits through disclosure, contractual to affiliates. ACM addresses arrangements, and internal policies and procedures. Types of Advisory Services Adviser provides investment management and Advisory services primarily with respect to Digital Assets and digital asset–related investment strategies. Services the Adviser can arrange for a Client include: investment recommendations risk monitoring and portfolio rebalancing • portfolio construction and asset allocation among Digital Assets • • execution oversight for purchases and sales of Digital Assets • • participation in staking or validator-based strategies • participation in digital asset lending or borrowing arrangements • collateral management for digital asset positions • participation in decentralized finance (“DeFi”) or protocol-based strategies • other yield-generating digital asset investment strategies (each one or more and collectively “Advisory Services”) Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 4  These services may be provided on either a discretionary or non-discretionary basis depending on the authority granted in the Client’s Advisory agreement (the “Advisory Agreement”). ACM currently provides Advisory services to: legacy private investment funds (each or collectively the “Fund”). • separately managed accounts (“SMAs”), and • Throughout this brochure, each SMA client or Fund is referred to as a “Client.” Digital Assets “Digital Assets” generally refers to blockchain-based digital tokens or units of value recorded on distributed ledger technology. Digital Assets may include, but are not limited to: blockchain protocol tokens or “native tokens” • cryptocurrencies such as Bitcoin and Ether • • USD-backed stablecoins or other fiat-referenced tokens • alternative digital tokens (“altcoins”) • tokenized assets or security tokens • synthetic assets or other blockchain-based financial instruments • non-fungible tokens (“NFTs”) where applicable Advisory Agreements and Authority Each Client enters into a written Advisory Agreement with ACM. The Advisory Agreement specifies the scope of services and level of authority granted to ACM. ACM will not implement recommended strategies without the Client’s authorization. Discretionary Accounts, For discretionary accounts Clients authorize Adviser to: rebalance portfolios take other actions necessary to implement investment strategies • buy or sell Digital Assets • allocate assets among investment strategies • • participate in staking, lending, or protocol-based strategies • ACM exercises discretionary authority within the scope defined in the Client’s Advisory Agreement (“Authorized Actions”). Clients may modify or restrict such authority only through written amendment to the Advisory Agreement. 5  Non-Discretionary Accounts For non-discretionary accounts, ACM may provide investment recommendations; however, Client initiation or approval must be obtained before executing transactions. Private Funds ACM provided Advisory services to certain legacy funds. Legacy funds are no longer accepting new investors. Information provided in this brochure relating to the funds is qualified in its entirety by the applicable fund offering documents (“Offering Documents”), which contain the details regarding investment strategies, fees, and risks. This brochure does not constitute an offer to sell interests in any fund or securities. Any such offers made are pursuant to their offering documents and applicable securities laws. Tailoring Advisory Services and Restrictions ACM’s Advisory services are focused primarily on Clients seeking to incorporate exposure to Digital Asset investments and or strategies and are not intended to provide comprehensive financial planning or wealth management services across all asset classes. Importantly, in providing Advisory services, ACM relies on the extent and accuracy of information disclosed by the Client such as: financial circumstances investment objectives risk tolerance investment experience • • net worth and liquid investable assets • • • ACM may tailor certain aspects of its Advisory services to a Client’s investment objectives and restrictions as agreed upon in the Advisory Agreement negotiated. Predefined Strategies Advisory services that encompass predefined strategies may not be specifically tailored to the individual circumstances in each transaction, rather assets the Client chooses to allocate a portion of assets which are then generally implemented in accordance with the Adviser’s overall strategy described. Wrap Fee Programs ACM does not participate in a wrap fee program. Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 6  Client Assets As of December 31, 2025, ACM managed $334,730,631 in regulatory assets under management (“RAUM”). Of this amount: • $140,332,020 was managed on a discretionary basis, and • $194,398,611 was managed on a non-discretionary basis. Of this amount approximately $ 79,000,000. was allocated to predefined strategies. Regulatory assets under management are calculated in accordance with the requirements of Form ADV. Item 5 – Fees and Compensation A. Advisory Fees Adviser charges Clients an Advisory fee for investment management services provided to Client accounts. Advisory Fees generally range from 0.20% to 2.00% annually, depending on the investment strategy selected, the size and composition of the Client’s portfolio, and the scope of services provided. Specific fee schedules and billing arrangements are disclosed in each Client’s Advisory Agreement and for strategy selections available through the Abra Application. Typical Advisory fee ranges include: Annual Advisory Fee 0.20% of assets under management up to 1.00% of assets under management Strategy / Service Digital Asset Custody Staking and Yield Strategies (ETH, SOL, USDC) Digital Income Strategy Collateral or Loan Management up to 2.00% of assets under management approximately 0.20% of assets under management Advisory Fees compensate Adviser for services including: reporting and client servicing • portfolio management • digital asset strategy development • risk monitoring and oversight • execution oversight • Advisory Fees are separate from trading spreads, blockchain network fees, lending costs, staking infrastructure costs, or other third-party service fees, some of which are described below. 7  Adviser may negotiate Advisory fees with certain Clients. Yield Strategies (Yield, Lending, and Digital Asset Income) Certain strategies seek to generate yield or income from digital asset holdings through activities which may include: • on-chain digital asset lending • validator staking participation • on-chain liquidity provisioning • basis trades Certain strategies may reference target or anticipated yield ranges for illustrative purposes only. Such targets are not guaranteed and may not be achieved. Clients that allocate to these strategies are not separately charged an asset-based Advisory fee, unless otherwise disclosed Rather where excess yield is generated an Advisory fee may be calculated and earned. This structure creates conflict of interest because Adviser has an incentive to generate excess yield and utilize strategies capable of producing excess yield. Adviser addresses this conflict through internal supervisory procedures including: • strategy risk oversight • counterparty due diligence • portfolio monitoring • compliance review Yield targets, anticipated returns, or income rates are never guaranteed and will fluctuate based on market conditions and volatility, counterparty performance, blockchain network conditions, protocol changes, liquidity constraints, and other risks. Fee Calculation and Digital Asset Valuation Advisory Fees calculated on value are based on Digital Assets held in Client accounts. Digital Assets valued using the U.S. dollar are based on the closing price as of 23:59:59 Coordinated Universal Time (UTC) on the final day of the relevant billing period. Pricing data is generally sourced from widely recognized digital asset pricing aggregators that compile market data from multiple exchanges. Such pricing sources may include CoinMarketCap or similar pricing providers. Because Digital Asset prices can vary between trading venues, price differences affect asset valuations and any calculations based upon such values. ACM seeks to apply a consistent valuation methodology in adopting valuation policy. Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 8  Billing Practices and Fee Deduction Advisory Fees based on the average daily balance of assets under management during the billing period are generally calculated monthly in arrears. Clients authorize Advisory Fee payment in accordance with the terms of the Advisory Agreement. For each digital asset in a yield or collateral strategy, ACM arrives at both in-kind and USD end- of-day value. The sum of those daily values is divided by the number of days in the month to arrive at the average daily balance (ADB). ADB is used to calculate the monthly fee by multiplying it at the monthly fee rate (1/12 of the annual fee rate) which can vary by product and strategy. The ACM’s end of the month invoice details itemized fee calculations. ACM does an automate sweep of the invoiced amount from the reserve portion of account. Where USDC is not available the equivalent value of BTC or ETH may be used. If there aren’t sufficient assets the balance will roll forward to future invoices. Client should be aware that fees and costs paid in-kind in BTC or ETH can cause a taxable event. Client statements inform on: • assets under management • digital asset balances • transaction history • unrealized gains and losses • Advisory fees charged • portfolio allocations Nonpayment of fees or costs can cause restrictions on further transactions other than liquidation, and accrue other costs, until payments are satisfied, all subject to the Advisory Agreement and in accordance with the Adviser’s fiduciary duties. B. Other Costs and Expenses Advisory Fees described above do not include the costs and expenses that may be associated with digital asset transactions or services chosen by the Client. In such cases, Clients will incur additional expenses not limited to: lending counterparty fees • Digital Asset trading or swapping spreads, including Digital Asset wrapping fees • blockchain transaction fees, such as network transaction fees or bridging fees • USD/Digital Asset conversion fees • wire fees • staking validator infrastructure costs • Costs associated with Client requests and third-party providers are generally paid by the Client and apply whether the Client’s investments generate profits or losses. Typical costs may include: 9  Typical Cost included in execution spread approximately 0.10% plus bank fees Transaction Digital Asset trading USD wire conversion to stablecoin approximately 0.10% Stablecoin conversion to USD Blockchain network transaction fees pass-through at cost Asset wrapping or bridging Loan origination up to approximately 0.25% up to approximately 1.00% of loan amount These costs can change based on market conditions, blockchain network congestion, and service provider pricing. Certain SMA Clients incur a custody fee of up to 0.20% annually, calculated monthly based on the average U.S. dollar market value of Digital Assets held. Assets deployed into certain investment strategies or non-discretionary programs accessed through Abra’s application (the “Abra App”) may not be included in the custody fee calculation. Additional details regarding custody fees are provided in the Advisory Agreement. Execution Pricing and Trading Spreads Where Digital Asset transactions are executed through exchanges, liquidity providers, market makers, or other counterparties, the transaction cost can include spreads above or below prevailing market prices. These spreads can incorporate compensation to liquidity providers or other service providers involved in executing transactions. Clients should be aware that execution cost can differ from price quotes displayed on public exchanges. ACM seeks to ensure execution is obtained through providers that can be reasonable under the circumstances, which may be based on liquidity, market conditions, available counterparties or other conditions. C. Prepayment of Fees and Refunds ACM does not require prepayment. If a Client prepaid Advisory fees prior to the end of the billing period, any unearned portion of the prepaid Advisory fee will be refunded on a prorated basis as of the termination date. D. Compensation for Sale of Investment Products Neither Adviser nor its supervised persons receive: • commissions Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 10  referral compensation for recommending securities or investment products. • asset-based sales charges • distribution fees • ACM’s compensation is derived solely from Advisory fees or strategy-based compensation described above. Clients may execute transactions through brokers, exchanges, custodians, or other service providers not affiliated with ACM. Adviser does not charge Advisory fees in addition to commissions or markups imposed by third parties, nor does it offset Advisory fees against such commissions. Item 6 – Performance-Based Fees and Side-by-Side Management ACM manages multiple Client accounts simultaneously, including accounts that pay different types of fees or participate in different investment strategies. This practice is commonly referred to as side-by-side management. Side-by-side management creates conflicts of interest. For example: • ACM could have an incentive to allocate more favorable investment opportunities to accounts that generate higher fees. • Accounts with performance-linked compensation arrangements could create incentives to favor those accounts over accounts paying only asset-based fees. • ACM could theoretically allocate profitable transactions to certain accounts while allocating less favorable trades to others. These conflicts are commonly referred to as trade allocation conflicts or “cherry-picking.” ACM has adopted policies and procedures designed to mitigate these risks, including: • Trade allocation policies designed to allocate investment opportunities fairly across Clients • Supervisory review of trade allocations • Compliance monitoring • Periodic reviews by ACM’s compliance personnel These procedures are intended to ensure that investment opportunities are allocated in a manner that ACM believes is fair and equitable to all Clients, taking into account each Client’s investment objectives, strategy parameters, liquidity needs, and regulatory considerations. Additional information regarding trade allocation practices is described under Item 10 – Other Financial Industry Activities and Affiliations – Allocation of Investment Opportunities. Item 7 - Types of Clients 11  A. Minimum Account There is no minimum account size for Clients. B. Clients ACM generally provides Advisory Services to: 1. SMAs, for individuals, trusts, family offices and institutions; and 2. Legacy funds Abra Tron Trust, a Delaware statutory trust, Abra Zilliqa Trust, a Delaware statutory trust and Plutus Lending LLC (“PLL Fund”) a Delaware limited liability company are not open to new investors. The PLL Funds are legacy accounts. The fee structures and investment objectives and strategies are detailed in the respective Fund Offering Documents. The Funds are exempt from registration under the Investment Company Act of 1940 as amended, and whose securities are not registered under the Securities Act of 1933 as amended. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss A. Executive Investment Committee Methods and Analysis ACM’s Executive Investment Committee (“EIC”) is responsible for establishing, supervising, and monitoring Adviser’s investment strategies and related investment policies. The EIC oversees the implementation of strategies and may, in its discretion, delegate certain responsibilities to subcommittees or designated managers, subject to ongoing supervision. Members of the EIC are selected based on their education and/or experience in digital asset markets, including trading, lending, staking, and decentralized yield strategies. The EIC determines, in its discretion, which strategies are made available as part of the ACM’s Advisory services. In evaluating potential strategies, the EIC may consider a range of qualitative and quantitative factors, which may include, but are not limited to: (i) historical performance characteristics; (ii) the experience, quality, and resources of the development or management team associated with a protocol or application; (iii) the operating history and maturity of the protocol or application; (iv) the scope and frequency of third-party audits by reputable smart contract auditing firms; (v) any known history of security incidents, exploits, or material bugs; (vi) measures of usage, assets deployed, and available liquidity, including total value locked (“TVL”) and exit liquidity; (vii) governance structure and mechanisms; (viii) potential centralization or governance concentration risks; and (ix) operational, technological, and implementation risks. Where demand for a particular yield or investment strategy exceeds available capacity, client participation is allocated in accordance with ACM’s written Allocation Policy. The consideration of the foregoing factors does not eliminate the risks associated with any strategy. Additional risks related to Digital Assets and related strategies are described under “Risk Factors”. Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 12  ACM can employ any combination of analysis tools, such as fundamental, market, and protocol- based analysis for evaluating Digital Assets and digital asset investment opportunities, such as: • Fundamental analysis, including evaluation of blockchain protocols, token economics, governance structures, developer activity, and adoption trends. • Market analysis, including liquidity, volatility, trading volume, and price behavior across digital asset exchanges. • Protocol analysis, including review of staking mechanisms, validator incentives, consensus models, and smart contract architecture. • Liquidity analysis, including evaluation of liquidity across decentralized financed platforms or exchanges. ACM may evaluate macroeconomic factors, regulatory developments, and technological changes that may impact the digital asset ecosystem. These analyses rely on publicly available blockchain data, market data providers, industry research, and internal analysis. No investment strategy can guarantee success or eliminate the risk of loss Yield and Income Strategies ACM can create strategies designed to generate income or yield from Digital Asset holdings (the “Yield Strategies”). The Yield Strategies can include: • DeFi based lending and borrowing • Staking and liquid staking with or without looping • Liquidity provision with hedging • Fixed rate yield for term • Stablecoin lending with or without looping • Hedging of stake • Options • Funding rate arbitrage Conflicts of Interest ACM’s Executive Investment Committee has discretion in selecting, approving, and allocating investment strategies and opportunities among Clients. As a result, Clients may participate in similar strategies at different times or on different terms, which may lead to differences in performance outcomes. In addition, capacity limitations, liquidity constraints, or operational considerations may affect the timing or availability of certain strategies for particular Clients. The Adviser has an incentive to allocate Client assets to strategies that generate higher fees or performance-based compensation. ACM seeks to manage these potential conflicts, in accordance with its fiduciary obligations through written policies and procedures, including its Allocation Policy, but such measures may not entirely eliminate all conflicts or their effects. Conflicts of Interest Related to Protocol Development 13  ACM or its affiliates may have financial interests associated with certain digital asset protocols in Client portfolio. With respect to the AbraFi protocol, members of the Abra team contributed to aspects of the protocol’s development. As a result, ACM or its affiliates may receive or hold allocations of AFI governance tokens or other economic interests associated with the protocol. Because the value of such tokens or interests may increase as adoption or use of the protocol grows, ACM and its affiliates have a financial incentive related to the protocol. This incentive could create a potential conflict of interest when evaluating whether the protocol is appropriate for use in client strategies. ACM addresses this potential conflict through its fiduciary obligations under the Investment Advisers Act of 1940, by: • internal investment committee review of strategies • risk and operational due diligence of protocols • disclosure of conflicts of interest to clients • ongoing monitoring of strategy suitability Clients should remain aware that ACM’s economic interests in protocol-related tokens or other assets may differ from client interests. B. Portfolio Strategies The Adviser offers investment strategies described below. Staking (Proof-of-Stake (“PoS”) Networks) Staking Strategies involve committing Digital Assets to participate in the validation, consensus, or security of POS blockchain networks in exchange for rewards. The Adviser uses liquid staking as well as looping, which involves repeated borrowing and restaking of liquid staking tokens. Staking involves risks not generally associated with traditional securities investment, including validator performance risk, protocol or governance changes, and technical or operational failures. Staked assets can be subject to lock-up or unbonding periods during which they cannot be withdrawn or transferred, limiting liquidity. In certain circumstances, staked assets can be subject to “slashing,” penalties, or partial confiscation due to validator errors, downtime, or violations of protocol rules. Staking rewards are variable and not guaranteed and can decline materially or cease entirely due to changes in network participation, economics, or protocol rules. Lending and Borrowing (Decentralized Lending Protocols(“DAPPs”)) Lending Strategies involve lending Digital Assets through DAPPs that operate on public blockchain networks and execute transactions via smart contracts. These arrangements expose Clients to protocol, and smart contract risks, or the risk that protocol mechanisms fail. Smart contract vulnerabilities, oracle failures, governance attacks, or protocol changes can result in partial or total loss of principal. Interest or rewards paid in-kind or in a protocol’s native Digital Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 14  Asset are subject to market volatility and can decline in value. The protocol does not involve a traditional legal counterparty; however, users are exposed to smart contract, oracle, liquidity, and governance-related risks that function similarly to counterparty risk. Liquidity Provision Liquidity Provision strategies involve contributing Digital Assets as a liquidity provider to decentralized exchange (“DEX”) protocols to facilitate trading between Digital Asset pairs. Certain protocols may also support leveraged or margin trading by third parties, which may increase volatility, liquidation activity, and associated risks to liquidity providers. Liquidity providers can receive a share of transaction fees or other incentives paid in-kind. The Adviser may seek to reduce directional market exposure through hedging strategies; however, such strategies may not be effective. See additional Risks in Item 8. Portfolio Allocation Adviser may construct diversified portfolios consisting of Digital Assets such as Bitcoin, Ethereum, and other blockchain-based assets. Portfolio construction may consider: liquidity technology characteristics • market capitalization • • network adoption • • portfolio diversification Aggregation Client retains separate account ownership, owning proportional participation in the strategy. C. Risk of Loss and Digital Asset Investment Risks General Risk of Loss; Speculative and Volatile Markets Investing in Digital Assets involves a high degree of risk, including the potential loss of the entire amount invested. Digital asset markets are speculative and subject to extreme price volatility, rapid changes in liquidity, and evolving market structure. Digital assets generally do not have the same consumer protections, regulatory oversight, or insurance protections typically associated with traditional financial markets. Clients should have the financial ability to bear the total loss of their digital asset allocation. The risks described below are not exhaustive, and additional risks may arise. D. Market and Portfolio Risks 15  Concentration and Allocation Risk Client portfolios may be concentrated in particular Digital Assets, blockchain networks, sectors, or protocols. Concentration may increase the magnitude of losses during adverse market conditions. Conversely, to outperforming asset classes may cause lower allocations underperformance relative to broader markets. Correlation and Diversification Risk Digital assets may not provide diversification benefits. Correlations between Digital Assets and other risk assets, including equities, may increase during periods of market stress, potentially resulting in simultaneous declines across otherwise diversified portfolios. Liquidity and Market Disruption Risk Digital asset markets may experience reduced liquidity, wide bid–ask spreads, slippage, trading halts, venue outages, or rapid changes in market depth. Market disruptions may impair a Client’s ability to buy, sell, transfer, or withdraw Digital Assets at desired prices, or at all. Digital Asset Trading Venue Risk Digital asset trading occurs primarily on electronic trading venues that may be subject to operational failures, cyber incidents, fraud, insolvency, or regulatory intervention. If a trading venue used by the Adviser becomes insolvent, suspends withdrawals, or experiences operational disruption, Clients may experience delays or losses in accessing or transferring Digital Assets. Digital Asset Valuation Risk Digital asset prices may vary significantly across trading venues. Valuation of Digital Assets for reporting or fee calculation purposes may rely on pricing data from third-party sources, which may differ from prices available on other exchanges. E. Strategy Risks Digital Asset Yield Strategy Risk The Yield Strategies differ materially from traditional income-producing investments and involve significant and unusual risks, including the risk of total loss. Yield Strategies may involve staking, lending, liquidity provisioning, collateralized financing transactions, or participation in decentralized protocols. These strategies expose Clients to risks including validator performance failures, slashing penalties, collateral liquidation, protocol failures, liquidity lockups, delayed withdrawals, and loss of assets pledged as collateral. Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 16  Returns from Yield Strategies are variable and not guaranteed. Adverse market conditions, protocol failures, counterparty insolvency, or regulatory actions could result in losses that exceed earned yield or the loss of the entire amount invested. Yield Strategies may also involve exposure to underlying digital asset market movements (“beta risk”) and may involve incidental exposure to protocol tokens or similar Digital Assets. Staking, Lending, and Liquidity Provision Risk Strategies involving staking, lending, or liquidity provisioning depend on the proper functioning of validators, counterparties, or decentralized protocols. Failures by validators or lending counterparties, network disruptions, governance decisions, or protocol vulnerabilities may result in partial or total loss of assets involved in such strategies. Decentralized Finance (DeFi) Risk Certain strategies may involve decentralized finance protocols that operate through automated smart contracts without centralized oversight. DeFi protocols may be vulnerable to coding errors, governance attacks, exploits, liquidity failures, or other technical vulnerabilities that could result in loss of Digital Assets. Smart Contract Risk Certain strategies rely on smart contracts deployed on blockchain networks. Smart contracts may contain coding errors, design flaws, or security vulnerabilities that could result in loss of Digital Assets. F. Technology and Network Risks Blockchain Network and Protocol Risk Digital assets depend on blockchain networks, cryptographic protocols, and, in many cases, smart contracts. Protocol upgrades, forks, bugs, governance actions, validator or miner concentration, censorship, or network congestion may adversely affect the functionality, security, transferability, or value of Digital Assets. Certain Digital Assets provide governance rights; however, the Adviser’s custody or operational infrastructure may not support participation in all governance activities, and Clients may be unable to exercise such rights. Fork and Airdrop Risk Blockchain networks may experience forks or protocol changes that result in the creation of new Digital Assets. The Adviser may determine, in its discretion, whether and how to support such events. Clients may not receive assets resulting from forks or airdrops, and such events may affect the value or functionality of Digital Assets held in Client accounts. 17  Blockchain Network Fee Risk Transactions on blockchain networks require payment of network transaction fees. During periods of network congestion, transaction fees may increase significantly, which may delay transactions or make certain transfers economically impractical. Network Concentration Risk Certain blockchain networks may be influenced by a relatively small number of validators, miners, developers, or governance participants. Concentration of control may affect network governance, transaction processing, or network security. Governance Capture Risk Certain blockchain networks allow token holders to vote on protocol changes or governance matters. Concentration of voting power among a small group of token holders or network participants could allow such participants to influence protocol rules, transaction validation, or economic outcomes in ways that adversely affect other participants. Validator Concentration and Slashing Risk Certain blockchain networks that use proof-of-stake or similar consensus mechanisms rely on validators to confirm transactions and maintain network security. If a validator fails to perform its duties correctly, engages in misconduct, or experiences technical failures, the network may impose penalties known as “slashing,” which can result in the loss of a portion of staked Digital Assets. In addition, validator participation on certain networks may be concentrated among a relatively small number of participants. Concentration of validation power could increase operational, governance, or security risks. If validators controlling significant portions of network activity experience outages, technical failures, or coordinated attacks, the network’s stability or security may be adversely affected. Clients participating in staking strategies may therefore experience losses associated with validator failures, slashing penalties, or disruptions in validator operations. Cross-Chain Bridge and Interoperability Risk Certain digital asset ecosystems rely on cross-chain bridges or interoperability protocols that allow Digital Assets to move between different blockchain networks. These bridge systems may rely on complex smart contracts, validator networks, or custodial mechanisms. Cross-chain bridges have historically been targets of cybersecurity exploits and technical failures. Vulnerabilities, coding errors, governance attacks, or operational failures associated with bridge infrastructure may result in loss of Digital Assets or disruption of network functionality. If Digital Assets held in Client accounts rely on bridge infrastructure or wrapped asset representations across networks, failures or exploits affecting such systems may result in loss, delays in transfers, or reduced liquidity. Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 18  G. Operational and Security Risks Cybersecurity Risk Client accounts and Adviser operations are subject to cybersecurity risks, including unauthorized access, credential compromise, ransomware, denial-of-service attacks, data theft, or other cyber incidents. Cyber incidents may result in losses, operational disruption, reputational harm, and regulatory exposure. No cybersecurity program can eliminate all risks. Software and Operational Risk The Adviser and its service providers rely on software, trading systems, and technology infrastructure. Systems may fail, contain errors, or perform in unexpected ways, resulting in delayed execution, incorrect transfers, unexpected costs, or losses. Operational errors or failures by the Adviser or third-party service providers may adversely impact Client accounts. Theft, Irreversibility, and Loss of Access Digital asset transactions are generally irreversible once confirmed on a blockchain. Losses may result from hacking, malware, social engineering, operational error, validator failures, smart contract vulnerabilities, or misconduct by custodians or counterparties. Misappropriated or misdirected Digital Assets may not be recoverable. Risks of Strategies Strategies involve additional risks including: • availability among clients • operational complexity breakdown in tracking proportional interests • delays in withdrawals to unwind positions • dependency on protocol or validator performance • potential liquidity constraints. If an operational error occurs client accounts could experience delays resulting in losses and corrections. H. Third-Party Risks Key Management Risk Client Digital Assets are managed with multi-party computation (“MPC”) or similar key- management arrangements involving multiple systems and service providers. Failure, compromise, or malfunction of any component of such systems may delay access to assets or result in loss. 19  Third-Party Service Provider Risk Where the Adviser relies on third parties such as exchanges, they may restrict activity based on legal, operational, or risk considerations. Financial distress, insolvency, fraud, cyber incidents, or regulatory actions affecting any service provider can impair Client access to assets and in a way that results in losses. Stablecoin Reserve Transparency Risk Certain stablecoins rely on reserve assets held by issuers or custodians to maintain their value. If reserves are insufficient, improperly managed, or lack transparency, stablecoins may lose their peg to the underlying reference asset. I. Regulatory and Structural Risks Regulatory and Legal Risk The regulatory treatment of Digital Assets and related activities, including staking, lending, and yield strategies, can evolve, be ambiguous or uncertain. Changes in laws, regulations, regulatory guidance, or enforcement actions can adversely affect the value of Digital Assets, the availability of service providers, compliance costs, and the Adviser’s ability to implement strategies. No FDIC or SIPC Protection; Limited Insurance Digital Assets are generally not insured by the Federal Deposit Insurance Corporation (FDIC) and are not protected by the Securities Investor Protection Corporation (SIPC).The FDIC does not cover crypto assets, even if held at an insured bank. SIPC only protects registered securities, excluding most Digital Assets unless specifically registered with the SEC Any private insurance coverage may be limited and subject to exclusions. J. Macroeconomic and Business Risks Macroeconomic Risk Macroeconomic conditions such as changes in interest rates, inflation, global liquidity, or currency fluctuations may adversely affect digital asset valuations and market liquidity. Key Personnel Risk The Adviser’s performance depends in part on the continued service of key personnel. The loss of key personnel could adversely affect the Adviser’s ability to implement strategies or manage risk. Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 20  Force Majeure Risk Events beyond the control of the Adviser or its service providers, including natural disasters, war, terrorism, pandemics, sanctions, power failures, or government intervention, may disrupt markets and operations and cause losses. The tax treatment of Digital Assets and yield-generating activities, including staking rewards and lending income, is complex and uncertain. Tax rules may change, and taxable events may occur even when assets are illiquid or not distributed. The Adviser does not provide tax advice, and Clients should consult their own tax advisers regarding the tax consequences of digital asset investments. K. Asset-Specific Digital Asset Risks Bitcoin (BTC) Risk Bitcoin operates on a decentralized network maintained by independent miners who validate transactions. Bitcoin is subject to significant volatility and may be adversely affected by regulatory developments, changes in mining economics, network congestion, cybersecurity incidents, or government restrictions affecting the ability to transact in Bitcoin. Ethereum (ETH) Risk Ether is the native asset of the Ethereum network, which supports smart contracts and decentralized applications. Risks include smart contract vulnerabilities, validator failures, protocol upgrades, network congestion, governance decisions, and competition from alternative blockchain platforms. Solana (SOL) Risk Solana is subject to high volatility, historical network outages, and regulatory uncertainty regarding its classification. Risks include validator concentration, network disruptions, smart contract vulnerabilities, and liquidity lockups associated with staking. Stablecoin Risk Stablecoins are designed to maintain a value pegged to a reference asset, such as the U.S. dollar. Stablecoins may experience de-pegging, reserve insufficiency, liquidity constraints, issuer risk, or regulatory intervention affecting issuers or banking partners. Stablecoins are not guaranteed to maintain a stable value and may trade at a premium or discount during periods of market stress. Item 9 – Disciplinary Information Adviser is required to disclose all material facts regarding any legal or disciplinary events that could be material to a Client’s evaluation of the Adviser or the integrity of its management. Adviser was not a party to the proceedings below and maintains policies and procedures designed to promote compliance with applicable federal and state securities laws. These proceedings, 21  settlements, and restrictions did not include the Adviser and does not affect Adviser’s ability to provide Advisory services herein. A. Disciplinary Information Regarding PLL In 2023 and 2024, Plutus Lending LLC (an affiliate of ACM) (PLL) entered into multiple regulatory settlements relating to certain offerings. PLL neither admitted nor denied the findings in these matters. In January 2024, PLL entered into a multi-state settlement led by the Texas State Securities Board and joined by 30 or more other states. Under the terms of the settlement, PLL returned customer Digital Assets in accordance with the settlement terms. In June 2024, PLL entered a similar settlement with state money transmitter regulators led by the Washington Department of Financial Institutions. PLL complied with the terms of the settlement. On August 24, 2024, the U.S. Securities and Exchange Commission (“SEC”) settled charges against PLL that alleged unregistered offers and sales of securities and operation, as an unregistered investment company. Without admitting or denying the SEC’s allegations, PLL consented to the entry of a final judgment in January 2025 that included an injunction and the payment of a $1.65 million civil penalty. B. Disciplinary Information Regarding Certain Affiliates Certain entities associated with members of ACM’s management, including entities operating under the Abra brand, such as Plutus Financial, Inc. and Plutus Technologies Philippines Corp. were the subject of regulatory investigations relating to digital asset lending products that led to settlements with U.S. federal and state regulators for licensing violations and in providing certain digital asset services. These matters were resolved without admission or denials of the regulators’ findings, through these settlements. Affiliates guaranteed and satisfied an orderly return of customer Digital Assets in those certain jurisdictions, a wind-down of certain U.S. retail business operations and satisfied the payment of the civil monetary penalties the parties agreed upon. These certain entities and individuals also agreed to temporary restrictions on activities requiring specific licensing for that defined period of time. Item 10 - Other Financial Industry Activities and Affiliations ACM (Abra Capital Management LLC), a limited liability company, with a principal office at 1160 Battery Street East, Suite 100 San Francisco, California 94111, is a wholly owned subsidiary of AFH (Abra Financial Holdings Inc.), a Delaware holding company operating businesses related to Digital Assets. AFH develops and operates technology and other strategies through affiliate entities to facilitate the expansion of digital asset related business enterprise services it can offer to clients. AFH provides and supports ACM with certain technology including the “Abra Application” wherein Clients are informed and can deploy into strategies in accordance with fees listed. Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 22  In fulfilling its duties to its Clients, Adviser endeavors to put the interests of its Clients first. However, Clients should be aware that AFH or ACM’s affiliates can receive economic benefits from affiliate commercial activities. Adviser manages conflicts through disclosures, to enable Clients to make informed decisions and through policies and procedures that require it to act in the Client’s best interests. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Pursuant to SEC Rule 204A-1, ACM as an SEC- as a registered investment advisers whose certain employees, and personnel (supervised persons) have access to client information or securities recommendations (“Access Persons”) has adopted and maintains a written code of ethics they must abide by. Access Persons include, generally, any partner, officer or director and any employee or other supervised person of the Adviser who, in relation to the clients, (1) has access to non-public information regarding any purchase or sale of securities, or non-public information regarding securities holdings or (2) is involved in making securities recommendations, executing securities recommendations or has access to such recommendations that are nonpublic. The Code sets forth a standard of business conduct that takes into account the Adviser’s status as a fiduciary and requires employees to place the interests of our clients above their own interests and the interests of the Adviser. The Code also requires employees to comply with applicable federal securities laws. The Code sets forth certain reporting and pre-clearance requirements with respect to personal trading by Access Persons. Moreover, the Code seeks to ensure the protection of nonpublic information about the activities of our clients. The Adviser’s personnel are required to certify to their compliance with the Code of Ethics on an annual basis. For purposes of ACM’s Code of Ethics, ACM treats Digital Assets that qualify as traditional securities similarly by subjecting employees to the same safeguards, prohibitions, and disclosures. Employees are required to promptly bring violations of the Code to the attention of the Adviser’s Chief Compliance Officer (the “CCO”). ACM will provide a copy of the Code of Ethics to any Client or prospective Client upon request by emailing their customer service representative or email above. ACM endeavors to make decisions in the best interest of its Clients, and to eliminate, mitigate, and/or disclose material conflicts of interest that arise between ACM and Clients. In order to monitor conflicts of interest, ACM monitors non-discretionary transactions in the personal accounts of its employees and contractors designated as “Access Persons”, including investing in Digital Assets. An Access Person must disclose on an initial and annual basis the holdings of all personal investment accounts, as well as all transactions in such accounts on a quarterly basis. It is the express policy of ACM that no person employed by ACM use material, non-public information obtained during the course of their work in deciding whether to purchase or sell any 23  asset prior to any pending transaction(s) being executed for an Advisory account. This policy is intended to prevent employees from benefiting from transactions placed on behalf of Advisory accounts. Securities in Which the Adviser or a Related Person Has a Material Financial Interest ACM and its supervised persons may buy or sell securities, including Digital Assets, for their own accounts that are the same as, or different from, those recommended to Clients. In addition, certain supervised persons or related persons of ACM may be Clients of the Adviser. From time to time, ACM or a related person may have a material financial interest in a security or Digital Asset that is also recommended to Clients. In such circumstances, ACM or such related person may have an incentive to recommend transactions in those assets. ACM seeks to manage these potential conflicts of interest through its Code of Ethics, which includes personal trading policies, reporting and monitoring requirements, and restrictions designed to ensure that Client interests are placed ahead of those of ACM and its personnel. Securities Adviser or Related Person Recommends Same Investments From time to time, ACM or a related person may recommend the same investments in a security or Digital Asset that is also recommended to Clients. In such circumstances, ACM or such related person could be incentivized to recommend transactions in those assets causing a potential conflict. ACM seeks to manage these potential conflicts of interest through its Code of Ethics, which includes personal trading policies, reporting and monitoring requirements, and restrictions designed to ensure that Client interests are placed ahead of those of ACM and its personnel. Adviser Client Simultaneous Purchases Where a related person recommends securities to Clients, or buys or sells securities for Client accounts, at or about the same time that the related person or Fund buys or sells the same securities for its own (or the related person's own) account, ACM seeks to manage these potential conflicts of interest through its Code of Ethics, which includes allocation and personal trading policies, reporting and monitoring requirements, and restrictions designed to ensure that Client interests are placed ahead of those of ACM and its personnel. Item 12 - Brokerage Practices Regulation of Digital Assets continues to develop globally. Regulatory authorities and legislative bodies evaluating and implement laws and issue guidance that can affect how Digital Assets are classified, held, and used in Advisory strategies. These changes could impose additional regulatory obligations or limitations on these investment activities that may compel the Adviser Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 24  to modify its business practices. As a result, regulatory developments can impact digital asset investments or the Adviser’s ability to offer certain digital asset-related strategies and service providers Adviser contracts. Adviser generally monitors these conditions to ensure it maintains an effective compliance framework pursuant to such legislation and guidance. A. Broker Selection Factors Adviser may facilitate transaction on behalf of its Clients through contracts with service providers who can accommodate Digital Assets. At Adviser’s discretion it may use or implement technology of providers and its services to fulfill orders. A Client can transfer Digital Assets in-kind (through a blockchain transaction) to their SMA or to withdraw Digital Assets in-kind (through a blockchain transaction). The factors at the core of Adviser consideration or limitations in selecting or recommending service providers for client transactions, and determining the reasonableness of their compensation (e.g., commissions), are based on the quality and extent of any services they make available related to Digital Assets. Research and Other Soft Dollar Benefits. 1. Adviser does not receive research or other products or services other than execution from a broker-dealer or a third party in connection with client securities transactions (“soft dollar benefits”), The Adviser does not receive research, whether proprietary research (created or developed by the broker-dealer) or research created or developed by a third party. a. Use of Brokerage Commissions The Adviser does not use client brokerage commissions (or markups or markdowns) to obtain research or other products or services, nor receive a benefit because it does not have to produce or pay for the research, products or services. b. Research and Service Incentive Adviser does not have an incentive to select or recommend a broker-dealer based on any interest in receiving research or other products or services, rather than on our clients’ interest in receiving most favorable execution. c. Commission Soft dollar Benefits- Markups and Markdowns Adviser does not cause clients to pay commissions (or markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar benefits (paying-up). d. Soft Dollar Benefits & Allocations 25  Adviser does not have soft dollar benefits for service clients’ accounts nor is paid for benefits. If Adviser were to receive them, they would allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. e. Related Person Commission Acquisitions There are no types of products or services the adviser or any of its related persons acquired with client brokerage commissions (or markups or markdowns) within your last fiscal year. f. Directing Client Transactions The Adviser has not directed client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals. 2. Adviser does not consider selecting or recommending broker dealers, for itself, or a related person to receive client referrals from a broker-dealer or third party. Adviser may arrange to facilitate the execution of transactions across multiple digital asset exchanges, OTC liquidity providers, or decentralized trading protocols in order to obtain liquidity or price improvement. a. Broker Recommendation Incentives Adviser does not have an incentive to select or recommend a broker-dealer based on interest in receiving client referrals, rather than on its clients’ interest in receiving most favorable execution. b. Procedures for Directing Brokerage for Client Referrals In the last fiscal year Adviser did not direct client transactions to a particular broker-dealer in return for client referrals. 3. Directed Brokerage. a. Client Directed Brokerage Required Adviser may direct transactions through a broker dealer, and requires that a Client may only as well, who is able to facilitate Digital Asset transactions. Adviser has no broker-dealer affiliates nor another economic relationship that creates a material conflict of interest. b. Client Directed Brokerage Permitted In certain circumstances, where Clients may wish to direct Adviser to execute transactions through a specific provider such as a trading venue, exchange, liquidity provider, or other service provider Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 26  (collectively, a “Directed Venue”), Adviser may be limited in its ability to seek the most favorable execution terms available across other venues. As a result, Clients who wish to direct to a venue may receive prices that are less favorable than those that might otherwise be obtained if Adviser were permitted to select the venue. Directed Venue arrangements may also result in higher transaction costs, such as wider spreads, higher trading fees, or reduced liquidity compared to other available venues. In addition, when Clients seeks to direct to a venue, Adviser may be unable to manage transactions which might otherwise reduce transaction costs or improve efficiency. Clients should consider these potential disadvantages before directing Adviser to use a particular Directed Venue, though Adviser will only accommodate where operationally feasible and consistent with applicable law and contractual arrangements available to the Adviser. Aggregated Orders. Adviser does not aggregate Client accounts. Item 13 – Review of Accounts A. Periodic Account Reviews The Adviser monitors Client accounts on an ongoing basis as part of its investment Advisory services. Reviews are conducted by investment Advisory personnel under the supervision of the Adviser’s Investment Committee (or equivalent governing body) and/or designated supervisory personnel. Client accounts are reviewed to ensure consistency with each Client’s investment objectives, risk tolerance, and applicable investment strategy, including target allocations and position weightings. The Adviser utilizes internal systems, tools, and, where applicable, automated processes or algorithms to support portfolio monitoring and management. B. Review Triggers The Adviser may periodically review investment strategies and portfolio construction methodologies to determine whether adjustments are appropriate in light of market conditions, relevant factors or specific events such as: Incomplete or failed trade executions; • Significant market movements or periods of market instability; • Elevated volatility in Digital Asset markets; • Changes in liquidity conditions or market depth; • Price dislocations or disruptions in pricing data; • • Rapidly changing market conditions, including widening bid-ask spreads; • Trading halts or disruptions affecting specific Digital Assets; and 27  • Changes in a Client’s financial circumstances, investment objectives, or risk tolerance (if communicated to the ACM C. Client Reporting Clients are informed, through the Abra Application, typically as applicable: • Digital Asset holdings and balances; • Transaction activity; • Realized and unrealized gains and losses; • Advisory fees charged; • Transaction-related costs; and • Custody-related fees and other expenses. D. Report Content and Frequency Portfolio activity and performance updates: • Total assets under management; • Asset allocation and portfolio composition; • Cash balances (if applicable); • Performance information, including unrealized gains and losses; • Pricing data and valuation information; and • A summary of recent transactions. Important Considerations Clients are encouraged to review all information carefully and promptly notify the Adviser of any discrepancies or concerns. Item 14 – Client Referrals and Other Compensation A. Economic Benefits from Non-Clients and Related Conflicts of Interest ACM does not currently receive economic benefits from non-clients in connection with providing investment Advisory services. ACM does not receive compensation such as sales awards, prizes, or other incentives from third parties in exchange for recommending specific investments, products, or service providers to Clients. If ACM were to enter arrangements in which it receives economic benefits from non-clients, such arrangements would present a conflict of interest because they could create an incentive for the Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 28  ACM to make recommendations based on such benefits rather than solely in the best interests of Clients. ACM would disclose any such arrangements as required by applicable law. B. Client Referrals and Solicitation Arrangements ACM does not currently compensate any person or entity for referring prospective Clients to the ACM. If ACM engages a third party to act as a solicitor or promoter in the future, such arrangement would be structured in compliance with Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Marketing Rule”), including appropriate written agreements and required disclosures to Clients. Any compensation paid to a solicitor or promoter would create a conflict of interest because the solicitor would have a financial incentive to recommend ACM. Clients would not incur additional fees as a result of such arrangements unless specifically disclosed. C. Internal Compensation and Related Conflicts Certain employees of ACM, including personnel involved in marketing and business development, are eligible to receive variable compensation based on factors such as the growth of the ACM’s business, overall firm performance, and/or individual performance metrics. This compensation structure creates a conflict of interest because such personnel have a financial incentive to promote ACM’s services and to encourage prospective Clients to engage ACM. ACM seeks to mitigate these conflicts through supervision, compliance policies and procedures, and by requiring that all marketing and solicitation activities are conducted in accordance with applicable regulatory requirements. Important Considerations Clients should be aware that any form of compensation tied to client referrals or business development may create incentives that are not aligned with a Client’s interests. ACM is committed to acting as a fiduciary and to disclosing material conflicts of interest so that Clients can make informed decisions. Item 15 – Custody The custody of Client assets is governed by Rule 206(4)-2 under the Investment Advisers Act of 1940 (the “Custody Rule”). Under the Custody Rule, an investment adviser is deemed to have custody if it holds, directly or indirectly, Client funds or securities, or has any authority to obtain possession of them. ACM is deemed to have custody of Client assets in the following circumstances: • Authority to deduct Advisory fees from Client accounts; 29  • Authority to transfer Digital Assets on behalf of Clients; and/or • Access to or control over Digital Asset wallets associated with Client accounts. Digital Asset custody differs from traditional securities custody in that control over Digital Assets is based on control of cryptographic private keys rather than physical possession or account title. A. Digital Asset Infrastructure Client Digital Assets use institutional-grade digital asset infrastructure designed to mitigate risks associated with private key management. Such as: • Multi-party computation (“MPC”) wallet technology; • Multi-signature wallet architecture; • Hardware security modules; • Cold storage systems; and • Secure key management and governance frameworks. Segregated blockchain addresses are subject to defined transaction authorization procedures, operational controls, and audit logging. The Adviser utilizes Fireblocks Ltd. (Fireblocks) as a technology provider for digital asset wallet infrastructure pursuant to a services agreement. Fireblocks provides MPC-based wallet technology designed to reduce single points of private key compromise by distributing cryptographic key shares across multiple secure environments. Under this architecture: • Cryptographic signing authority is distributed across multiple isolated environments; • Private key shares are not fully reconstructed in any single location; and • No single individual or system can unilaterally transfer Client Digital Assets. Layered security controls can include: • Role-based access controls and governance workflows; • Dual-approval or multi-approval transaction processes; • Two-factor authentication (2FA) for system access; and • Enhanced authentication controls for asset transfers, including multi-step verification procedures. The Abra Application informs on balances, transaction history, and account activity. Clients are encouraged to review account information carefully and promptly report any discrepancies. Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 30  Digital Asset involves some unique risks not typically present in traditional securities arrangements, such as: • Loss, theft, or compromise of private keys; • Cybersecurity incidents; • Blockchain protocol or network failures; and • Operational risks associated with digital asset infrastructure. Item 16 - Investment Discretion ACM may provide discretionary or non-discretionary investment management services, depending on the Client’s Advisory Agreement. Discretionary Authority For discretionary accounts, Clients grant Adviser authority to: rebalance portfolios • buy or sell Digital Assets • allocate assets among digital asset strategies • participate in staking, lending, or protocol-based activities • select counterparties and trading venues • This authority allows Adviser to execute transactions without obtaining Client consent prior to each trade. Non-Discretionary Accounts For non-discretionary accounts, Adviser may provide investment recommendations, but Clients must approve transactions before they are executed. Operational Authority Clients may grant Adviser the authority necessary to implement digital asset investment strategies, including: initiating blockchain transactions interacting with digital asset protocols • • • managing wallet infrastructure used for Client accounts • participating in validator or staking infrastructure Such authority is exercised solely for purposes consistent with the Client’s investment strategy and Advisory Agreement. 31  All purchases or sales are subject to the specified investment objectives, guidelines, or limitations previously set forth by the Client in the Advisory Agreement. Blockchain Protocol Events Adviser retains discretion to determine whether and how to support blockchain protocol events, including forks, airdrops, or similar events affecting Digital Assets held in an SMA. In making such determinations, Adviser may consider operational, legal, regulatory, security, and custody infrastructure limitations, as well as its fiduciary obligations to Clients. Depending on these considerations, Adviser may determine, in its discretion, to: i decline to support or recognize a new Digital Asset created through a fork or airdrop; ii support the new Digital Asset only after a period of time following the fork or airdrop; or iii where permitted under applicable client agreements or custody arrangements, retain rights to certain forked or airdropped assets. ACM’s current operational and custody infrastructure does not support active participation in blockchain forks or airdrops, and ACM does not undertake to capture, claim, or distribute Digital Assets resulting from such events. As a result, Clients may not receive Digital Assets generated through forks or airdrops that affect Digital Assets held in their accounts. Failure to support forks or airdrops may adversely affect the value or potential benefits associated with such Digital Assets. Clients who wish to participate in forks or airdrops may elect to maintain Digital Assets with another service provider capable of supporting such functionality. Item 17 - Voting Securities A. Voting Authority Rule 206(4)-6 under the Investment Advisers Act of 1940 requires registered investment advisers to disclose their policies and procedures regarding the voting of client securities. ACM generally does not have authority to vote client securities because the Digital Assets managed by Adviser typically do not represent equity securities that carry traditional proxy voting rights. In addition, ACM’s current custody and operational infrastructure does not support participation in on-chain governance activities associated with certain Digital Assets. Certain Digital Assets allow token holders to participate in governance processes, including voting on protocol proposals, software upgrades, or other matters that may influence network operations or economic outcomes. At this time, Clients holding Digital Assets in SMAs managed by Adviser are unable to participate in such governance activities through ACM’s infrastructure. Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 32  As a result, Clients may not be able to exercise governance rights associated with Digital Assets held in their accounts, and the outcome of governance proposals may indirectly affect the value or performance of those Digital Assets. Clients who wish to participate in governance activities associated with Digital Assets may elect to maintain such assets with another service provider capable of supporting governance participation. Private Funds The private investment funds previously managed by Adviser generally do not hold equity securities or other instruments that submit matters to a vote of security holders. If Adviser is required to vote on any securities held by a fund, Adviser will exercise such voting authority in a manner that it believes is consistent with the best interests of the applicable fund and its investors. Prior to exercising voting authority, Adviser will review the relevant facts and circumstances to determine whether any material conflict of interest exists involving ACM, its affiliates, employees, or related persons. If a material conflict of interest is identified, Adviser may take one or more of the following steps to address the conflict: • seek the recommendation of the applicable fund Advisory board (if any); • disclose the conflict of interest and obtain guidance from the relevant Client or governing body; • rely on the recommendation of an independent third-party proxy voting service provider. • or take other actions that ACM reasonably believes are in the best interests of the Client. Proxy Voting Policies and Information Adviser will provide Clients with a copy of any proxy voting policies and procedures upon written request. Clients may also request information regarding how, if any, Adviser voted proxies for securities held in applicable Funds by contacting ACM in writing. Item 18 - Financial Information A. Fee Prepayment ACM does not require or solicit prepayment of more than one thousand two hundred USD ($1,200) in Advisory fees per Client, six (6) months or more in advance. Therefore, ACM is not required to include: 33  1. an independently audited GAAP balance sheet prepared by a CPA with principles noted, for its most recent fiscal year; nor 2. the fair value of securities at cost; nor 3. a CPA qualification conforming to Article 2 of SEC Regulation S-X Discretionary Disclosure Adviser has discretionary authority to manage Client assets. Adviser does not believe there is any financial condition that is reasonably likely to impair Adviser’s ability to meet its contractual commitments to Clients. Bankruptcy ACM nor any affiliate have been the subject of a bankruptcy petition at any time during the past ten (10) years. Abra Capital Management, LP 1160 Battery Street East, Suite 100 San Francisco, California 94111 34