BELLATORE FINANCIAL, INC.

Item 1 – Cover Page Bellatore Financial, Inc. 1790 Hughes Landing Blvd, Suite 575 The Woodlands, TX 77380 832-585-0110 https://bellatore.com/ Firm Brochure ADV Part 2A November 2025 This Brochure provides information about the qualifications and business practices of Bellatore Financial, Inc. (“Bellatore”). If you have any questions about the contents of this Brochure, please contact us at 832-585-0110. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Bellatore is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about Bellatore also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for Bellatore is 143543. i  Item 2 – Material Changes This Item of our Brochure will discuss only specific material changes that are made to the Brochure since our last annual update. The last Form ADV annual update of our Brochure was in March of 2025. Material Changes: HFG Opportunity Fund LP, is a Delaware limited partnership (the “Fund”). The Fund’s investment objective is to seek to generate long-term capital appreciation and attractive risk-adjusted returns through careful selection of a diversified portfolio of public and private Portfolio Investments, including private funds (“Underlying Funds”). The Partnership aims to achieve its objective by employing a flexible, opportunistic investment approach across multiple asset classes, including public and private debt, public and private equity, and alternative investments. PPB HFGO Mgt LLC, a Delaware limited liability company, is the general partner of the Fund (the “PPB General Partner”); and Bellatore Financial, Inc., a Delaware corporation, is the investment manager of the Fund (the “Investment Manager”). The Investment Manager will direct the investment and reinvestment of the assets of the Fund, in accordance with the investment criteria and investment strategy described in the Partnership Agreement and/or the Fund’s Confidential Private Placement Memorandum. Please refer to Items 4, 5, 8 and 10 of this brochure. ******** Currently, our Brochure may be requested by contacting us at 832-585-0110. Our Brochure is also available on www.adviserinfo.sec.gov or you may request from us free of charge. The SEC’s web site also provides information about any persons affiliated with Bellatore who are registered, or are required to be registered, as investment adviser representatives of Bellatore. ii  Item 3 - Table of Contents Item 1 – Cover Page ....................................................................................................................................... i Item 2 – Material Changes ............................................................................................................................ ii Item 3 - Table of Contents ........................................................................................................................... iii Item 4 – Advisory Business ........................................................................................................................... 1 Item 5 – Fees and Compensation ................................................................................................................. 4 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 9 Item 7 – Types of Clients ............................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 10 Item 9 – Disciplinary Information ............................................................................................................... 30 Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 30 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ................................ 32 Item 12 – Brokerage Practices .................................................................................................................... 34 Item 13 – Review of Accounts..................................................................................................................... 36 Item 14 – Client Referrals and Other Compensation .................................................................................. 37 Item 15 – Custody ....................................................................................................................................... 38 Item 16 – Investment Discretion ................................................................................................................ 38 Item 17 – Voting Client Securities ............................................................................................................... 39 Item 18 – Financial Information .................................................................................................................. 39 iii  Item 4 – Advisory Business Bellatore Financial, Inc. (“Bellatore” or the “Firm”) is located in The Woodlands, Texas and provides asset management services to select financial advisory businesses across the U.S. Bellatore is principally owned by Bellatore Holdings, Inc. (formerly known as Bella Fund Holdings, Inc.), which is primarily owned by Larry A. Harvey. A complete listing of Bellatore’s ownership can be found on the Firm’s ADV Part 1. Bellatore has provided investment advisory services since 2007. As of December 31, 2024, Bellatore managed $565,467,485 in assets under management, $20,011,421 on a discretionary basis and $545,456,064 on a non-discretionary basis. Bellatore was founded with a central purpose: to empower advisors through higher quality solutions. Bellatore provides turn-key asset management programs to independent registered investment advisors to help provide those advisors with more time for what truly matters—enhancing their businesses and servicing client relationships. Bellatore also provides customized outsourcing centered on business management, back-office support, investment solutions and wealth planning. Bellatore provides its advisory firm clients with consultative advice regarding the design of investment advisory products and services including positioning, strategy and efficacy of plans, programs and products. Additionally, Bellatore provides investment management and model portfolio solutions to the clients of the advisory firms that partner with Bellatore. Bellatore's Management Authority All portfolios are maintained as separate accounts in the client's name with a qualified independent custodian. The managed portfolio consists of all assets held in the client’s account. Bellatore exercises its power and authority under the terms of the relevant program agreement. Bellatore does not maintain custody or possession of client assets or funds. Bellatore provides ongoing investment supervision of the portfolios and provides quarterly reporting to clients regarding their accounts. UNIFIED MANAGED ACCOUNT PROGRAM The Unified Managed Account Program (“UMAP”) provides clients investment advisory services through an open-architecture structure that combines a variety of securities and strategies. Under the terms of the UMAP client agreement, Bellatore provides asset allocation 1  guidance and strategies, portfolio construction, trading, rebalancing, performance reporting, account monitoring and administration. CAPITAL ALLOCATION & MANAGEMENT PROGRAM The Capital Allocation & Management Program (the “CAM Program”) is a discretionary investment management offering in which Bellatore constructs and manages portfolios that consist of mutual funds and/or exchange traded funds (“ETFs”), or a combination of mutual funds and ETFs. These portfolios are designated in varying degrees from conservative, to moderate, to aggressive. In consultation with their independent advisor, clients can choose from a group of portfolios that most closely match their investment objectives and risk tolerances. Bellatore manages the portfolios to respond to changing capital market conditions and periodically rebalances the portfolios as needed. Clients may change the portfolio type if their circumstances change. The portfolio implementation options consist of: Tax Efficient Portfolios for taxable accounts; Tax Deferred Portfolios for qualified accounts, Exchange Traded Fund Portfolios for tax efficiency; Exchange Traded Funds for qualified accounts; and Hybrid Portfolios of mutual funds and exchange traded funds. The Hybrid portfolios may be used for taxable accounts but will not be managed for tax efficiency. For tax deferred portfolios, the Firm has Tax Advantage Portfolios of Variable Annuities from either Security Benefit Corporation or Jefferson National Life Insurance Company. CAM Program Sub-Advisory Services Bellatore provides sub-advisory services on managed money platforms, and as such, provides investment advisory services to certain clients of these firms. Bellatore constructs and manages mutual funds and/or ETF portfolios, as well as hybrid portfolios consisting of combinations of such instruments, which have varying degrees of risk ranging from conservative to aggressive. The investment and reinvestment of client's assets are in accordance with the specific investment styles, risk tolerances and the investment objectives and policies set forth in the appropriate client agreement, as updated periodically by the client. 2  ALTIUS SELECT INVESTMENT PORTFOLIOS The Altius Select Investment Portfolios Program (the “Altius Program”) provides investment advisory services designed to meet individual clients’ investment objectives through investments in mutual funds, based on information clients prepare with the assistance of their investment advisor. Clients participating in the Altius Program enter into an agreement with Bellatore and their advisor. The Altius Program client agreement grants Bellatore the authority to: change or modify the Portfolios, asset allocation percentages, and selection of investments; effect transactions in client accounts without seeking approval or discussing investments decisions with clients first; periodically rebalance client assets; and manage client assets for compliance with the portfolios’ investment objectives. The Altius Program consists of portfolios of mutual funds that correspond to specific investor profiles, ranging from conservative to aggressive, with suggested asset allocations developed by Bellatore’s investment committee. Each portfolio is comprised of mutual funds that represent the various asset class allocations included in the corresponding investor profile. Bellatore selects and monitors the mutual funds included in the portfolios. With the assistance of their Advisor, clients may select the portfolio that may best fit their current investment objectives. Altius Program Sub-Advisory Services Bellatore provides sub-advisory services on managed money platforms, and as such, provides investment advisory services to certain clients of these firms. Bellatore constructs and manages mutual fund portfolios, which have varying degrees of risk ranging from conservative to aggressive. The investment and reinvestment of client's assets are in accordance with the specific investment styles, risk tolerances and the investment objectives and policies set forth in the appropriate client agreement, as updated periodically by the client. DOL Disclosure When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • • Meet a professional standard of care when making investment recommendations (give prudent advice); Never put our financial interests ahead of yours when making recommendations 3  • • • • (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and Give you basic information about conflicts of interest. HFG Opportunity Fund LP HFG Opportunity Fund LP, is a Delaware limited partnership (the “Fund” or “Partnership”). The Fund’s investment objective is to seek to generate long-term capital appreciation and attractive risk-adjusted returns through careful selection of a diversified portfolio of public and private Portfolio Investments, including private funds (“Underlying Funds”). The Partnership aims to achieve its objective by employing a flexible, opportunistic investment approach across multiple asset classes, including public and private debt, public and private equity, and alternative investments. PPB HFGO Mgt LLC, a Delaware limited liability company, is the general partner of the Fund (the “PPB General Partner”); and Bellatore Financial, Inc., a Delaware corporation, is the investment manager of the Fund (the “Investment Manager”). The Investment Manager will direct the investment and reinvestment of the assets of the Fund, in accordance with the investment criteria and investment strategy described in the Partnership Agreement and/or the Fund’s Confidential Private Placement Memorandum. Please refer to Item 10 for other Financial Industry Activities and Affiliations and disclosure of the firms’ conflicts of interest related to same. Item 5 – Fees and Compensation UMAP Fees UMAP account fees are billed and deducted in advance by Bellatore from client accounts each calendar quarter. The number of billing days in a quarter is based on the actual number of days in each quarter. When a new account is opened, or a deposit is made into an existing client account, fees are billed immediately for the remaining days in that calendar quarter. Thereafter, those accounts are included in the regular calendar quarter billing schedule and fee calculations. Quarterly fees are calculated based on the current market value of assets in the account as of the beginning of each calendar quarter. Accounts that are terminated by clients in the middle of a calendar quarter will receive a pro-rata rebate of the Firm’s most recent quarterly fee, as specified in the UMAP client agreement. Fees and services may be adjusted based on factors such as client type, asset class, pre- existing or family relationships, portfolio complexity, account size, or other special 4  circumstances or requirements. Related household accounts may be aggregated for fee calculation purposes in certain circumstances. UMAP Fee Schedule Household Assets with Bellatore UMAP Fee Up to $250,000 0.75% $250,000 to $500,000 0.70% $500,000 to $1,000,000 0.50% $1,000,000 to $2,000,000 0.40% $2,000,000 to $5,000,000 0.35% $5,000,000 and above 0.25% In addition to the foregoing Fee Schedule, certain UMAP clients may be charged a fixed fee that may vary from $100,000 to $500,000 depending on the relationship size, complexity and level of service required. Each client signs a tri-party UMAP agreement and receives a copy of the Firm’s Form ADV Part 2A. The agreement can be terminated by the independent advisor, Bellatore or the client upon thirty (30) days’ prior written notice. Upon termination of the agreement, clients receive a prorated refund of fees for the quarter in which the effective date of termination occurs. In addition to the advisory fees payable to the client’s advisor, clients also incur charges payable to the custodian of the account, as well as to the broker-dealer that executes transactions in the account. Clients designate the custodian to be used for their account. The Firm currently has arrangements with Charles Schwab & Co. which may change from time to time. The custodian’s fee will be debited directly from the client’s account by the custodian. CAM Program Fees CAM Program fees are billed and deducted in advance by Bellatore from client accounts each calendar quarter. The number of billing days in a quarter is based on the actual number of days in each quarter. When a new account is opened, or a deposit is made into an existing client account, fees are billed immediately for the remaining days in that calendar quarter. Thereafter, those accounts are included in the regular calendar quarter billing schedule and fee calculations. Quarterly fees are calculated based on the current market value of assets in the account as of the beginning of each calendar quarter. Accounts that are terminated by 5  clients in the middle of a calendar quarter will receive a pro-rata rebate of the Firm’s most recent quarterly fee, as specified in the CAM client agreement. CAM Program Fee Schedule Household Assets with Bellatore CAM Program Fee Up to $250,000 0.75% $250,000 to $500,000 0.70% $500,000 to $1,000,000 0.50% $1,000,000 to $2,000,000 0.40% $2,000,000 to $5,000,000 0.35% $5,000,000 and above 0.25% Fees and services may be adjusted based on factors such as client type, asset class, pre- existing or family relationships, portfolio complexity, account size, or other special circumstances or requirements. Related household accounts may be aggregated for fee calculation purposes in certain circumstances. Firm charges not collected directly from client's account will be invoiced quarterly and due and payable upon receipt of invoice. Bellatore acknowledges that lower fees for comparable services may be available from other firms. Each client signs a tri-party CAM Program Agreement and receives a copy of the Firm’s Form ADV Part 2A. The agreement can be terminated by the independent advisor, Bellatore or the client upon thirty (30) days’ prior written notice. Upon termination of the agreement, clients receive a prorated refund of fees for the quarter in which the effective date of termination occurs. In addition to the advisory fees payable to the client’s advisor, clients may also incur charges payable to the custodian of the account, as well as to the broker-dealer that executes transactions in the account. Clients designate the custodian to be used for their account. The Firm currently has arrangements with Charles Schwab & Co. which may change from time to time. For variable annuity portfolios, the Firm has arrangements with Jefferson National Life Insurance Company and Security Benefit Corporation. The custodian’s fee will be debited directly from the client’s account by the custodian. CAM Program Sub-Advisory Services Fees For CAM sub-advisory services accounts, these managed money platforms normally maintain client records, submit reports to clients at least quarterly and withdraw fees for payment to Bellatore quarterly in advance. Bellatore's fee is based on a percentage of assets under 6  management in each account and typically starts at 0.4% (forty basis points). Fees and services vary by managed money platform. Account terminations are governed by the managed money platform account agreement and normally include a pro-rata refund of prepaid fees. Bellatore is available to consult with the advisors and their clients regarding positions of the portfolios, risk return assumptions or performance. Altius Program Fees Altius Program fees are billed and deducted in advance by Bellatore from client accounts each calendar quarter. The number of billing days in a quarter is based on the actual number of days in each quarter. When a new account is opened, or a deposit is made into an existing client account, fees are billed immediately for the remaining days in that calendar quarter. Thereafter, those accounts are included in the regular calendar quarter billing schedule and fee calculations. Quarterly fees are calculated based on the current market value of assets in the account as of the beginning of each calendar quarter. Accounts that are terminated by clients in the middle of a calendar quarter will receive a pro-rata rebate of the Firm’s most recent quarterly fee, as specified in the Altius client agreement. Altius Program Fee Schedule Household Assets with Bellatore Altius Program Fee Up to $250,000 0.45% $250,000 to $500,000 0.40% $500,000 to $1,000,000 0.35% $1,000,000 to $2,000,000 0.30% $2,000,000 to $5,000,000 0.25% $5,000,000 to $10,000,000 0.20% $10,000,000 to $20,000,000 0.15% $20,000,000 and above 0.10% Fees and services may be adjusted based on factors such as client type, asset class, pre- existing or family relationships, portfolio complexity, account size, or other special circumstances or requirements. Related household accounts may be aggregated for fee calculation purposes in certain circumstances. Firm charges not collected directly from client's account will be invoiced quarterly and due and payable upon receipt of invoice. Bellatore acknowledges that lower fees for comparable services may be available from other firms. Each client signs a tri-party Altius Program Agreement and receives a copy of the Firm’s Form ADV Part 2A. The agreement can be terminated by the independent advisor, Bellatore or the 7  client upon thirty (30) days’ prior written notice. Upon termination of the agreement, clients receive a prorated refund of fees for the quarter in which the effective date of termination occurs. In addition to the advisory fees payable to the client’s advisor, clients may also incur charges payable to the custodian of the account, as well as to the broker-dealer that executes transactions in the account. Clients designate the custodian to be used for their account. The Firm currently has arrangements with Charles Schwab & Co. which may change from time to time. Altius Program Sub-Advisory Services Fees For Altius sub-advisory services accounts, these managed money platforms normally maintain client records, submit reports to clients at least quarterly and withdraw fees for payment to Bellatore quarterly in advance. Bellatore's fee is based on a percentage of assets under management in each account and charges a maximum fee of 0.45% (forty-five basis points). Fees and services vary by managed money platform. Account terminations are governed by the managed money platform account agreement and normally include a pro-rata refund of prepaid fees. Bellatore is available to consult with the advisors and their clients regarding positions of the portfolios, risk return assumptions or performance. HFG Opportunity Fund LP Fees Bellatore (the “Investment Manager”) is paid a Management Fee for compensation of services rendered in the investment management of the Partnership. The Management Fee shall be paid quarterly in advance on the first Business Day of each Fiscal Quarter. The Management Fee in respect of each Class A Limited Partner shall be (0.65% per annum) by such Class A Limited Partner’s Capital Account balance, as of the last Business Day of such previous Fiscal Quarter (or, if such Class A Limited Partner was not a Partner on such date, the first Business Day of the current Fiscal Quarter). The Management Fee in respect of each Class B Limited Partner shall be (1.00% per annum) by such Class B Limited Partner’s Capital Account balance, as of the last Business Day of the immediately preceding Fiscal Quarter (or, if such Class B Limited Partner was not a Partner on such date, the first Business Day of the current Fiscal Quarter). In the event that a Class A Limited Partner’s Advisory Agreement with Bellatore is terminated and such Class A Limited Partner remains invested in the Partnership, all Class A Interests held by such Class A Limited Partner at the time of termination of the Advisory Agreement shall automatically be converted to Class B Interests and be subject to the increased Management Fee, without any further action required by the General Partner, Investment Manager, or Limited Partner. The Investment Manager, in its sole discretion, may waive or reduce the Management Fee with respect to certain Limited Partners without notice to, or consent of, any other Limited Partner. 8  Additional Fees Clients will bear their proportionate share of the fees and expenses of any mutual fund, or ETF, in which they invest. These fees and expenses may include investment advisory, administrative, distribution, transfer agent, custodial, legal, audit, and other customary fees and expenses, including redemption fees, related to investments in mutual funds or ETFs and are in addition to the fees charged by Bellatore. Clients are encouraged to read the prospectuses of any funds in which their assets are invested for a more complete explanation of these fees and expenses. Item 6 – Performance-Based Fees and Side-By-Side Management Bellatore does not charge any performance-based fees. Item 7 – Types of Clients Bellatore provides asset management services to individual investors, corporations, charitable organizations, profit sharing plans and trusts. The Firm also provides registered investment advisors, or their investment advisor representatives, (collectively referred to as “Financial Advisors”) with business management services, consulting services and sub- advisory services. UMAP, CAM Program and Altius Program To open an account, clients must complete and sign the appropriate account agreement, fee disclosure statement and account trading instructions. In most cases, clients are required to complete the appropriate custodian’s paperwork including a new account agreement and a Limited Power of Attorney (LPOA). Completed paperwork is sent to Bellatore for review of accuracy, compliance and completeness. After review, accounts are established and invested when properly funded. All client account assets are held at a qualified custodian and clients select which custodian they would like to use. The client’s choice of Custodian is limited, however, to those that have a relationship with Bellatore. The custodian maintains custody of all of client assets and provides such other functions as crediting interest and dividends on client’s assets and crediting principal on called or matured securities in client’s account, together with other custodial functions customarily performed with respect to securities brokerage accounts. 9 Bellatore provides periodic reports that includes, among other things, a consolidated report identifying all assets in client’s managed account and the asset allocation of the program  account(s), as well as listing the investment performance of the account, and maintaining, or causing to be maintained, records of account assets, including all purchases, redemptions, sales and exchanges. Additionally, Bellatore may monitor client accounts for asset class drift and client contribution and distribution needs. Clients may terminate their agreement upon thirty (30) days’ prior written notice to their Financial Advisor and Bellatore. Once notified of an account termination, the client’s Financial Advisor and/or Bellatore will direct the custodian to deliver cash and securities held in the client’s account as instructed in writing by client, unless the client requests that the account be liquidated. If the client’s account is liquidated as a result of termination, proceeds will be payable to the client upon settlement of all transactions in the account. The client will be entitled to a pro rata refund of any pre-paid quarterly advisory or administrative fees, based upon the number of days remaining in the quarter after the date of termination. Account Minimums With the exception of UMAP, the CAM Program and Altius Program impose a minimum client account size. Additionally, Financial Advisors using Bellatore’s services may impose a separate minimum client account size greater than our stated minimums. Please refer to your Financial Advisor’s disclosure brochure for more information. Clients investing in the CAM Program or Altius Program must typically meet the following minimum initial investment and account balance requirements: Minimum Initial Investment and Minimum Minimum Account Balance Subsequent Investment Program Option Altius Program CAM Program (non-ETF models) CAM Program (ETF models) $25,000 $25,000 $50,000 $0 $0 $0 Bellatore may waive the minimum initial investment and/or minimum account balance. The criteria that are considered in waiving the minimum initial investment and/or minimum account balance include, but are not limited to: householding of accounts, advisor relationship, etc. Bellatore reserves the right to terminate any client account that falls below the applicable minimum account requirements due to withdrawals or market action. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss 10 Methods of Analysis, Sources of Information and Investment Strategies  Bellatore uses a comprehensive set of investment tools and services to deliver consistent investment results for Financial Advisors to use with their clients. Bellatore developed its investment process based on rigorous research and a disciplined, academically-based investment philosophy. The Firm’s distinct investment philosophy forms the foundation for all of its investment programs, tools and services. Scientific Portfolio Theory The Firm’s methods of analysis and investment strategies are self-branded under the label of Scientific Portfolio Theory (“SPT”). SPT is comprised of three disciplines: understanding of investments, understanding of money management and understanding of investors. The Firm’s understanding of investments begins with the principles of Modern Portfolio Theory (“MPT”). From this research, Bellatore believes that risk and return are related. MPT also provides tools that help with the design of efficient portfolios. Efficient portfolios allocate investments across multiple, dissimilar asset classes as a way of attempting to reduce risk while increasing return. Additionally, Bellatore believes markets are generally efficient. This belief leads the Firm to spend less time actively searching for the next big investment and more time attempting to build an efficient portfolio for an investor from well-designed asset class strategies. Bellatore’s understanding of money management provides a number of key insights into what the Firm looks for in investment managers. Bellatore looks for experienced, institutional quality managers that are able to benefit from more efficient trading techniques and have access to institutional trading platforms. When implementing SPT, the Firm seeks managers that stay focused on the asset class mandate they were hired to manage, which results in lower style drift and more predictable investment performance. Bellatore recognizes that investment costs can weigh down investment returns, so the Firm seeks managers that provide low-cost, value-added trading and execution. Bellatore’s understanding of investors is the third component of SPT. The Firm believes that the better it understands investors and their behaviors, the better its advice and planning techniques will be. The field of Behavioral Economics and the more focused discipline of Behavioral Finance provide the theory and tools to help evaluate and explain investor behaviors and preferences. Behavioral Portfolio Theory is an example of one of these tools, and it forms the basis of Bellatore’s goal-based investment planning techniques. Where most academic research assumes that investors are rational, optimizing individuals, Behavioral Finance suggests that investors are normal. Investors have investment preferences that go beyond risk and return, and when Financial Advisors are aware of these preferences, they are better equipped to make suitable investment recommendations and investment plans. 11  When all three of these understandings are built into the investment planning process, Bellatore believes that investors are better suited to weather market movements and achieve their investment goals. Fund Structure Risk Factors The HFG Opportunity Fund LP may be deemed to be a highly speculative investment and is not intended as a complete investment program. It is designed only for sophisticated persons who are able to bear the economic risk of the loss of their investment and who have no need for liquidity in their investment. Risk factors include the following: General The Partnership Has No Operating History and No Significant Assets. The Partnership is a newly-organized entity with no history of operations or earnings. Furthermore, the Partnership is relying solely on this offering for equity capital and has no other assets. The Partnership’s proposed operations are subject to all business risks associated with new enterprises. The likelihood of the Partnership’s success must be considered in light of the problems, expenses, difficulties, complications, and delays frequently encountered in connection with the formation and growth of a business. There is no assurance that the operations of the Partnership will be profitable or that any investment in the Interests will be recouped. . Term of Investment. An investment in the Partnership requires a specified, multi-year-term commitment with no certainty of a return of any portion of capital invested in the Partnership. There may be a significant period of time before the Partnership has completed its investments in particular Portfolio Investments and each Portfolio Investment may not be liquidated for a substantial period of time after the initial purchase. Similarly, the Underlying Funds in which the Partnership invests may not complete their investment program for a significant period of time and may not liquidate their investments for a substantial period of time after initial purchase. For both the Partnership and the Underlying Funds, losses on unsuccessful investments may be realized before gains on successful investments are realized and dispositions of such investments may require a lengthy time period. While it is the intention of the Investment Manager to achieve target returns over such period, other factors, such as overall market conditions, the performance of individual Portfolio Managers, the competitive environment and the availability of potential purchasers, may shorten or lengthen the Partnership’s or an Underlying Fund’s holding period. It is uncertain as to No Assurance of Partnership Profit, Cash Distributions or Appreciation when profits, if any, will be realized. Distributions to the Limited Partners are made in the sole discretion of the General Partner. Cash that might otherwise be available for distribution will also be reduced by payment of Partnership obligations, payment of Partnership expenses 12  (including fees payable and expense reimbursements to the General Partner and the Investment Manager) and establishment of appropriate reserves. As a result, if the Partnership is profitable, the Limited Partners in all likelihood will be credited with Partnership net income and may incur the consequent income tax liability (to the extent that they are subject to income tax), even though Limited Partners receive little or no Partnership distributions. Strategy Risks General Economic/market Conditions. The business of the Partnership could be adversely affected from time to time by such matters as changes in general economic, industrial and political conditions; changes in tax laws, prices and cost; and other factors of a general nature that are beyond the control of the Partnership. Various social and political tensions in the United States and around the world (including conflicts between Russia and Ukraine and conflicts in the Middle East), among other factors, could contribute to increased market volatility, could cause economic uncertainties or a significant downturn in the United States and worldwide, and could have long term effects on the United States and worldwide financial markets. As the result of such developments, the business, operating results, financial condition and prospects of the Partnership and its investments could be materially and adversely affected. Additionally, a period of deteriorating general economic conditions could negatively impact the Partnership’s ability to dispose of its investments by adversely affecting the market for such investments. The stability and sustainability of growth in global economies may be impacted by terrorism or acts of war. Portfolio Investment Selection. The Investment Manager will seek to identify Portfolio Investments that it believes will produce attractive returns. A general description of the process by which the Investment Manager will seek to identify such investments is set forth above. In determining whether to make a particular investment, the Investment Manager will use whatever factors it deems appropriate, regardless of conventional criteria or ratings provided by rating agencies. There is no assurance that the Investment Manager’s analysis in this regard, as implemented, will take into considerations all appropriate factors, or appropriately weight the factors that are considered in its analysis. There is also no assurance that the Portfolio Investments selected by the Investment Manager will have a low risk of loss or produce any level of income or capital appreciation. Similar risks will apply to each Portfolio Manager’s investment program. Real Estate. Real estate investments are affected by, among other things: (i) changes in general economic and market conditions; (ii) changes in the value of real estate properties; (iii) risks related to local economic conditions, overbuilding and increased competition; (iv) increases in property taxes and operating expenses; (v) changes in zoning laws and other governmental laws, rules and regulations; (vi) casualty and condemnation losses; (vii) 13  variations in rental income, neighborhood values or the appeal of property to tenants; (viii) the availability of financing; (ix) changes in interest rates and leverage, and (x) the illiquidity of real estate. Private Credit. Debt securities of all types of issuers may have speculative characteristics, regardless of whether they are rated. The issuers of such instruments (including sovereign issuers) may face significant ongoing uncertainties and exposure to adverse conditions that may undermine the issuer’s ability to make timely payment of interest and principal in accordance with the terms of the obligations. Private credit borrowers are often small- to medium-sized companies with high leverage and relatively low collateralizable assets. This makes them vulnerable to interest rate changes and economic conditions, which can lead to defaults and large losses. In the environment of inflation and rising interest rates, higher interest payments on floating-rate debt could stress borrowers' balance sheets, leading to a significant increase in defaults. Venture Capital. Investments in new ventures are subject to greater risk of loss than investments in companies with more stable operations or financial condition. New ventures may require considerable additional capital to develop technologies and markets, acquire customers and achieve or maintain a competitive position. This capital may not be available at all, or on acceptable terms. Further, the technologies and markets of such companies may not develop as anticipated, even after substantial expenditures of capital. Such companies may face intense competition from established companies with much greater financial and technical resources, more extensive development, manufacturing, marketing and service capabilities, and a greater number of qualified managerial and technical personnel. Smaller Funds and New Managers. The Partnership may invest in relatively small Underlying Funds that do not have significant assets and/or Underlying Funds that are managed by relatively new managers and/or investment teams. Such Underlying Funds may have limited or no performance history, may have limited capital to invest, may have limited investment opportunities, may have limited opportunities to raise additional capital, and are subject to the business risks associated with new enterprises. Growth Equity. The Partnership may directly or indirectly (via Underlying Funds) invest in growth-equity investments. While growth equity investments offer the opportunity for significant capital gains, such investments may involve a higher degree of business and financial risk that can result in substantial or total loss. Growth equity portfolio companies may operate at a loss or with substantial variations in operating results from period to period, and many growth equity portfolio companies will need substantial additional capital to support additional research and development activities or expansion, to achieve or maintain a competitive position, and/or to expand or develop management resources. Growth equity portfolio companies may face intense competition, including from companies with greater 14  financial resources, better brand recognition, more extensive development, marketing and service capabilities, and a larger number of qualified managerial and technical personnel. equity and equity-oriented securities of earlier stage, privately held companies. These companies may have no revenues and may not be profitable. They require considerable additional capital to develop technologies and markets, acquire customers and achieve or maintain a competitive position. This capital may not be available at all, or on acceptable terms. Furthermore, the markets of such companies may not develop as anticipated, even after substantial expenditures of capital. Such companies may face intense competition, including competition from established companies with much greater financial and technical resources, more extensive development, manufacturing, marketing and service capabilities, and a greater number of qualified managerial and technical personnel. Such companies may have substantial variations in operating results from period to period and may experience failures or substantial declines in value at any stage. Middle-Market Investments. The Partnership may directly or indirectly (via Underlying Funds) invest in middle-market companies. Such companies may lack management depth or the ability to generate internally or obtain externally the funds necessary for growth. Companies with new revenue streams could sustain significant losses if projected markets do not materialize. Further, such companies may have, or may develop, only a regional market for specific revenue streams and may be adversely affected by purely local market conditions. To the extent there is any public market for the middle-market company securities held by the Partnership, such securities may be subject to more abrupt and erratic market price movements than those of larger, more established companies. Middle-market companies tend to have lower capitalizations and fewer resources and, therefore, often are more vulnerable to financial stress or failure, and the risk of bankruptcy or insolvency is often higher. Such companies also may have shorter operating histories on which to judge future performance when making the decision to invest. Lastly, such companies may face intense competition from larger companies and could entail a greater risk than investment in larger companies. Many middle-market companies will operate with substantial variations in operating results from period to period. Many of these companies will need substantial additional capital to support expansion or to achieve or maintain a competitive position. Such companies may face intense competition, including from companies with greater financial resources, more extensive development, manufacturing, marketing and service capabilities and a larger number of qualified managerial and technical personnel. Volatility Risk. The Partnership's investment program may involve the purchase and sale of relatively volatile securities and/or investments in volatile markets. Fluctuations or prolonged changes in the volatility of such securities and/or markets can adversely affect the value of investments held by the Partnership. 15  Leveraged Investments. The Partnership may directly or indirectly (via Underlying Funds) invest in highly leveraged companies. While investments in leveraged companies offer the opportunity for capital appreciation, such investments also involve a high degree of risk. Economic, recessions operating problems and other general business and economic risks may have a pronounced effect on the profitability or survival of highly leveraged companies. Also, increased interest rates generally increase highly leveraged companies interest expenses. In the event a highly leveraged company cannot generate adequate cash flow to meet debt service, the Partnership may suffer a partial or total loss of capital invested in such company. Partnership Debt. The Partnership is permitted to take on debt to further its investment position. By law, obligations owed on debt have priority over obligations to equity holders, meaning that the Partnership’s use of debt instruments could reduce or even eliminate (in the worst circumstances) returns to investors. This is particularly true given the historically high costs of debt capital under current market conditions due to the highest interest rates seen in a generation or more. Thus, while there may be situations where it makes financial sense for the Partnership to use debt to further its investment objectives, the General Partner and Investment Manager intend to be judicious in how it leverages this sort of capital on behalf of the Partnership. Equity Securities. The Partnership may acquire interests, directly or indirectly, in various types of equity securities. Such equity securities may range in market capitalization from large-cap equity securities (with a very large market capitalization) to microcap equity securities (with a very small market capitalization). The Partnership may purchase equity securities of both U.S. issuers as well as equity securities of non-U.S. issuers (or the American Depositary Receipts (“ADRs”) issued by such non-U.S. issuers). The value of equity securities held by the Partnership are subject to market risk, including changes in economic conditions, growth rates, profits, interest rates and the market’s perception of these securities. The value of such securities will also depend on company- specific events (including a company’s earnings, management, product development, financing, competitors, customer base, execution of its business strategy, etc.), industry- specific events, political developments, regulatory changes, and many other factors. The value of non-U.S. securities (as well as their ADR counterparts) may depend on a variety of factors including political developments in the countries where the issuers of such securities operate, the value of foreign currencies, etc. While offering greater potential for long-term growth, equity securities are more volatile and riskier than some other forms of investment and are lower in terms of priority of payments than debt securities in the event of the bankruptcy of the issuer. Control Investments. The Partnership may directly or indirectly (via Underlying Funds) invest in controlling equity interests in portfolio companies which, depending upon the amount of 16  equity owned by the Partnership or Underlying Fund, contractual arrangements between the portfolio company and the Partnership or Underlying Fund, and other relevant factual circumstances, could result in an extension to one year of the 90-day bankruptcy preference period with respect to payments made to the Partnership or Underlying Fund to satisfy debts or other contractual obligations. The exercise of control and/or significant influence over a portfolio company imposes additional risks of liability for environmental damages, product defects, failure to supervise management, pension and other fringe benefits, violations of government regulations (including securities laws) and other types of liability in which the limited liability generally characteristic of business operations may be ignored. In addition, ownership of a controlling percentage of equity, representation on a board of directors and/or contractual rights, may lead others to conclude that the Partnership or Underlying Fund controls, participates in the management of, or influences the conduct of, a portfolio company. These factors could expose the assets of the Partnership or Underlying Fund to claims by a portfolio company, its other security holders, its employees, its other creditors or governmental agencies. These factors could also make it easier for any claims of the Partnership or Underlying Fund against the portfolio company to be subordinated or recharacterized as equity interests compared to similar claims of third parties. Minority Investments. The Partnership may directly or indirectly (via Underlying Funds) take minority positions in portfolio companies, without power individually to exert significant control over such portfolio companies’ boards of directors, management, operations and strategic direction. Such portfolio companies may have other goals not completely aligned with those of the Partnership or Underlying Fund, and the Partnership or Underlying Fund may not be in a position to limit or influence actions taken by such portfolio companies, or otherwise protect the value of the Partnership’s or Underlying Fund’s investment in such portfolio companies. In such cases, the Partnership or Underlying Fund will rely significantly on the existing management and boards of directors of such companies, which may include representatives of other investors with whom the Partnership or Underlying Fund is not affiliated and whose interests or views may conflict with those of the Partnership or Underlying Fund. Although engaging in a specific transaction or sale of an entire portfolio company may be a beneficial disposition for the Partnership or Underlying Fund, the majority holder or holders of interest in the portfolio company may prevent the portfolio company from entering into such transactions, which could result in the Partnership’s or Underlying Fund’s investments being frozen in minority positions that incur substantial losses. Therefore, there can be no assurance that the Partnership or Underlying Fund will be able to realize the value of its investments or distribute proceeds from a sale or disposition of such a portfolio company in a timely manner. Illiquidity of Underlying Fund Investments. The Partnership may directly or indirectly (via Underlying Funds) invest in securities that are subject to restrictions on sale because they 17  were acquired from the issuer in “private placement” transactions or because the Partnership or Underlying Fund will be deemed to be an affiliate of the issuer. Generally, the Partnership or Underlying Fund will not be able to sell these securities publicly in the United States without the expense, time and other burdens required to register the securities under the Securities Act, or will be able to sell the securities only under Rule 144 or other rules under the Securities Act which permit limited sales under specified conditions. Further, practical limitations may inhibit the Partnership’s or Underlying Fund’s ability to liquidate certain of its investments in portfolio companies because the issuer will be privately held and the Partnership or Underlying Fund may own a relatively large percentage of the issuer’s equity securities. Sales may also be limited by market conditions, which may be unfavorable for sales of securities of particular issuers or issuers in particular industries. The above limitations on liquidity of the Partnership’s or Underlying Fund’s investments could prevent a successful sale thereof, result in delay of any sale, or reduce the amount of proceeds that might otherwise be realized by the Partnership or Underlying Fund from its investment. Smaller Capitalization Companies in General. Investments in smaller capitalization companies often involve significantly greater risks than the securities of larger, better-known companies because they may lack the management expertise, financial resources, product diversification and competitive strengths of larger companies. The prices of the securities of smaller companies may be subject to more abrupt or erratic market movements than larger, more established companies, as these securities typically are traded in lower volume and the issuers typically are more subject to changes in earnings and prospects. In addition, when selling large positions in small capitalization securities, the seller may have to sell holdings at discounts from quoted prices or may have to make a series of small sales over a period of time. Secondary Transactions. The Partnership may invest in Underlying Funds by purchasing existing limited partnership interests in already existing funds (that is, via secondary offerings), rather than investing in newly raised funds. In addition to the other risks of investing in Underlying Funds noted herein, secondary transactions raise additional risks because such funds are private and the market for such transactions are relatively illiquid. These factors result in a restricted market for such transactions, information asymmetries between the sellers and purchasers of such interests, and uncertainty surrounding the valuation of the interests. For example, because the market for private equity secondary transactions is smaller and less liquid than the public markets, it can be challenging to buy or sell these investments, especially in times of market volatility or economic downturn. Similarly, because, private equity funds are privately traded and, unlike publicly traded funds, are not required to make information about the fund and its investments available to prospective investors, the seller of fund interests may be privy to information about the fund and its investments that it doesn’t share with the Partnership. Finally, the valuations of the 18  private equity fund’s investments can be uncertain and subjective, which can make it difficult to accurately assess the value of the secondary investment and may lead to potential losses if the valuation turns out to be overstated. Structured Notes. Investments in structured notes involve significant risks that investors should carefully consider. Structured notes are complex financial instruments that typically combine debt securities with derivatives to provide customized returns based on the performance of underlying assets, indices, or market conditions. While they can offer unique benefits, these investments carry substantial risks, including but not limited to the following: • Issuer Credit Risk. Structured notes are unsecured obligations of the issuing entity. If the issuer experiences financial difficulties, becomes insolvent, or defaults, the structured notes may lose all or part of their value, regardless of the performance of the underlying asset. The Partnership will have no recourse to the underlying asset or index and will bear the full credit risk of the issuer. • Lack of Liquidity. Structured notes may have limited secondary markets, and there may be no active trading market for a specific note. This illiquidity can result in significant difficulties for the Partnership in selling structured notes at desired prices or times. If the Partnership needs to liquidate its position before maturity, it may be forced to sell at a significant discount to the note's theoretical value. • Complexity and Lack of Transparency. Structured notes are highly complex instruments, with returns and risk profiles that may be difficult to fully understand or predict. The valuation and performance of these notes may depend on multiple variables, including the performance of underlying assets, interest rate changes, and market volatility. Misunderstanding these complexities can lead to unexpected losses. • Market Risk and Performance of Underlying Assets. The value of structured notes is often linked to the performance of underlying assets, indices, or other market benchmarks. Adverse movements in the prices of these underlying assets or indices can cause the value of the structured note to decline or result in the loss of principal. Market volatility and unpredictable fluctuations further exacerbate this risk. • Lack of Principal Protection. Many structured notes do not guarantee the principal at maturity. If the performance of the underlying asset or index does not meet the structured note's specified terms, the Partnership may suffer partial or total loss of its invested principal. Even structured notes labeled as "principal-protected" may not provide full protection in the event of issuer default or certain adverse market conditions. • Interest Rate Risk. Structured notes may include fixed-income components that are sensitive to changes in interest rates. Rising interest rates can negatively affect the market value of 19  these notes. Additionally, some structured notes may not offer periodic interest payments, resulting in a lack of income during the holding period. • Derivative Exposure. Structured notes often incorporate derivative components, which introduce additional risks such as counterparty risk, leverage, and heightened sensitivity to market conditions. The complexity of derivative pricing may also make it difficult to accurately assess the fair value of the structured note. • Performance Caps and Participation Limits. Structured notes may include provisions such as performance caps or participation limits that restrict the potential upside of the investment. Even if the underlying asset performs well, the structured note's return may be limited, resulting in lower-than-expected gains for the Partnership. • Early Redemption Risk. Certain structured notes allow the issuer to redeem the instrument before its stated maturity date, often at unfavorable terms for investors. If early redemption occurs, the Partnership may be forced to reinvest proceeds in less favorable market conditions, which could negatively affect the Partnership's returns. • Valuation Risk. The valuation of structured notes can be challenging due to their complexity, lack of standardized pricing models, and limited secondary market activity. Pricing discrepancies between the issuer, the Partnership's valuation agent, and secondary market quotes can lead to uncertainty about the note's fair value. This uncertainty may impact the Partnership's reported net asset value (NAV). • Tax Treatment Uncertainty. The tax treatment of structured notes may be unclear or subject to change. Structured notes can generate income or capital gains that may be treated differently under tax laws, creating potential complexities and risks for the Partnership and its investors. The Partnership may incur additional costs or liabilities in complying with tax regulations related to structured note investments • Counterparty Risk. In addition to issuer credit risk, structured notes expose the Partnership to counterparty risk through the derivative components embedded in the note. If the counterparty to the derivative transaction defaults, the structured note's value could decline significantly. • Potential Conflicts of Interest. The issuer of structured notes may also act as the counterparty for derivatives or provide pricing and liquidity support for the note. This dual role can create conflicts of interest, as the issuer's interests may not align with those of the Partnership. The Partnership's reliance on the issuer for pricing and liquidity could increase the risk of biased or unfavorable terms. Investment in Joint Ventures and Other Entities. The Partnership and the Underlying Funds may make investments through joint ventures or other entities. Such investments may involve 20  risks not present in direct investments, including, for example, the outcomes of collaborative decision-making varying (adversely) from those which the Investment Manager or a Portfolio Manager would have reached itself, the possibility that a co-venturer or partner might become bankrupt, or might have interests, objectives, rights or remedies which are different from or may conflict with those of the Partnership or the Underlying Fund. Furthermore, if such co- venturer or partner defaults on its funding obligations, it may be difficult for the Partnership or the applicable Underlying Fund to make up the shortfall. The Partnership or an Underlying Fund may be required to make additional contributions to replace such shortfall, reducing the diversification of the Partnership’s or an Underlying Fund’s portfolio investments. The Partnership or an Underlying Fund may also be liable for the conduct of its coventurers or partners. In addition, in negotiating an investment through joint ventures or other similar arrangements, the Partnership or an Underlying Fund may have to agree to less favorable terms (e.g., bearing a disproportionate share of expenses) than might be present in direct investments. . The Partnership may seek to establish relationships to obtain prime Counterparty Risk brokerage and other services that permit the Partnership to trade in any variety of markets or asset classes over time. However, there can be no assurance that the Partnership will be able to establish or maintain such relationships. An inability to establish or maintain such relationships could limit the Partnership's trading activities, create losses, preclude the Partnership from engaging in certain transactions or prevent the Partnership from trading at optimal rates and terms. Moreover, a disruption in the prime brokerage or other services provided by any such relationships could have a significant impact on the Partnership's business due to the Partnership's reliance on such counterparties. Litigation Risk. The Underlying Funds and/or the Partnership could become involved in investor, insider trading or other litigation as a result of its investment activities, which could adversely affect the Underlying Funds or the Partnership. Increase in Managed Assets. The Portfolio Managers may experience a major increase in the assets they manage, which may impair the ability of their strategies and operations to perform as expected. This could result in losses to the Underlying Funds and therefore indirectly to the Partnership and the Limited Partners. In addition, the Portfolio Managers may not be able to accept the Partnership’s full desired allocation to their Underlying Fund, which may require the Partnership to change its strategy or allocation targets. Investment Program ” above. Nonetheless, Discretion of the Portfolio Managers. The Underlying Funds will seek to engage in the investment activities that have been discussed in “ the Underlying Funds’ portfolio may be altered at any time by the Portfolio Managers and without the approval of any investors. Although the Underlying Funds will seek to spread capital among a number of investments, there can be no assurance that the Portfolio 21  Managers will not decide in their sole discretion that it may be better for the Underlying Funds to concentrate their resources in a limited number of investments. Moreover, because the Portfolio Managers will be unaffiliated with one another, multiple Portfolio Managers may determine to concentrate their resources in the same investments, which could adversely affect the Partnership if such investments perform poorly or result in economically offsetting positions. The General Partner may not know whether Underlying Funds hold similar or offsetting positions and will not attempt to manage or avoid such positions. Allocation Changes. The Underlying Funds may from time to time change their current asset allocations among investments. The Partnership’s success will depend on the investment selection and allocation abilities of the Portfolio Managers of the Underlying Funds. . Diversification Risks. The Partnership has a broad investment mandate and some of its underlying investments may have different or even conflicting characteristics related to investment objectives, time horizons and the like. While diversification is typically considered a sound investment strategy to minimize downside risk, it also means that the Partnership may pursue a broader investment strategy that has a lower rate of return than a more narrowly defined investment strategy that may have a higher rate of return but also a higher risk of loss. Systemic risk is the risk of broad financial system stress or collapse triggered . Systemic Risk by the default of one or more financial institutions, which results in a series of defaults by other interdependent financial institutions. Financial intermediaries, such as clearing houses, banks, securities firms and exchanges with which the Partnership interacts, as well as the Partnership, are all subject to systemic risk. A systemic failure could have material adverse consequences on the Partnership and its investments. The Partnership may be subject to Assumption of Business, Terrorism and Catastrophe Risks the risk of loss arising from exposure that it may incur, indirectly, due to the occurrence of various events, including, without limitation, hurricanes, earthquakes and other natural disasters, terrorism and other catastrophic events. These risks of loss can be substantial and could have a material adverse effect on the Partnership and its investments. Limited Information. Before making any investments on behalf of the Partnership, the Investment Manager will conduct due diligence that it deems reasonable and appropriate based on the facts and circumstances applicable to each investment. When conducting due diligence, the Investment Manager may be required to evaluate important and complex business, financial, tax, accounting and legal issues. When conducting due diligence and making an assessment regarding an investment, the Investment Manager will rely on the resources reasonably available to it, which in some circumstances whether or not known to the Investment Manager at the time, may not be sufficient, accurate, complete or reliable. Due diligence may not reveal or highlight matters that could have a material adverse effect on the 22  value of an investment. Further, there can be no assurance that such an investigation will result in an investment being successful. Significant Positions in Securities; Regulatory Requirements. Although the Partnership does not expect to acquire a significant stake in any issuer of securities (as measured as a percentage of the issuer's outstanding shares), if the Partnership's stake exceeds certain percentage or value limits, the Partnership may be subject to regulation and regulatory oversight that may impose notification and filing requirements or other administrative burdens on the Partnership and the Investment Manager. Any such requirements may impose additional costs on the Partnership and may delay the acquisition or disposition of the securities or the Partnership's ability to respond in a timely manner to changes in the markets with respect to such securities. . In addition, there are risks involved in dealing with the custodians or brokers Custody Risk who settle Partnership trades. It is expected that all securities and other assets deposited with custodians or brokers will be clearly identified as being assets of the Partnership and hence the Partnership should not be exposed to a credit risk with regard to such parties. However, it may not always be possible to achieve this segregation and there may be practical or time problems associated with enforcing the Partnership’s rights to its assets in the case of an insolvency of any such party. Institutions, such as brokerage firms or banks, may hold certain of the Partnership's assets in “street name.” Bankruptcy or fraud at one of these institutions, in particular, the Partnership's prime broker which would hold the majority of the Partnership's assets, could impair the operational capabilities or the capital position of the Partnership. Management Risks Dependence on Management. The Partnership’s business will be significantly dependent on the General Partner’s and Investment Manager’s management team. The Partnership’s success HFG Opportunity Fund LP, Investment Program–Investment Team” will be particularly dependent upon the continued service of the personnel identified under “ . Other individuals might become principals of the Investment Manager (and play a role in managing the Partnership) after the date of this Memorandum. The loss of any one of these individuals could have a material adverse effect on the operating results and financial condition of the Partnership. Control by Management. Limited Partners will have very limited rights and power to take part in the management of the Partnership. All prospective investors must be willing to entrust all aspects of the operation and management of the Partnership to the Investment Manager and the General Partner. 23 Dependence on Portfolio Managers. Since a substantial portion of the Partnership’s investments may be in the Underlying Funds, the Portfolio Managers of such Underlying Funds may be indirectly making many of the investment decisions with respect to such investments. The Partnership’s performance may depend significantly upon the skill,  judgment, and expertise of the Portfolio Managers. Accordingly, no person should invest in the Partnership unless he is willing to entrust all aspects of the investment management of the Partnership to the General Partner, Investment Manager or indirectly to the Portfolio Managers, who will have considerable discretion in the types of investment strategies that the Underlying Funds will focus on, and the types of securities in which the Underlying Funds will invest. . Ownership of the General Partner. The General Partner is an affiliate of PPB Capital Partners. While Bellatore and PPB Capital Partners share mutual goals and intentions with respect to the Partnership, it is possible that they may disagree over certain matters affecting the General Partner and the Partnership. In such event, the General Partner’s and the Partnership’s operations may become inefficient or be interrupted. There can be no assurance as to the likelihood or outcome of any such disagreements. Any such disagreement could potentially result in the early termination of the Partnership or disposition of Portfolio Investments at an inopportune juncture The Partnership is also dependent upon its Dependence on Certain Third Parties counterparties and certain third-party service providers, such as the Administrator. Errors are inherent in the business and operations of any business, and although the Investment Manager will adopt measures to prevent and detect errors by, and misconduct of, counterparties and third-party service providers, and transact with counterparties and third- party service providers it believes to be reliable, such measures may not be effective in all cases. Errors or misconduct could have a material adverse effect on the Partnership and the Limited Partners' investments therein. . The Partnership depends on the Investment Manager to Systems and Operational Risks develop and implement appropriate systems for the Partnership's activities. The Partnership relies heavily and on a daily basis on financial, accounting and other data processing systems to manage the affairs of the Partnership. In addition, the Partnership relies on information systems to store sensitive information about the Partnership, the Investment Manager, the General Partner, their affiliates and the Limited Partners. Certain of the Partnership's and the Investment Manager's activities will be dependent upon systems operated by third parties, including the Administrator and other service providers, and the Investment Manager may not be in a position to verify the risks or reliability of such third-party systems. In addition, despite the security measures established by the Investment Manager and third parties to safeguard the information in these systems, such systems may be vulnerable to attacks by hackers or breached due to employee error, malfeasance or other disruptions. Any such breach could compromise these systems and result in theft, loss or public dissemination of the information stored therein. Disruptions in the Partnership's operations or breach of the Partnership's information systems may cause the Partnership to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention 24  or reputational damage. Any of the foregoing failures or disruptions could have a material adverse effect on the Partnership and the Limited Partners' investments therein. Fund Structure Risk Withdrawals. Except as specifically set forth in the Partnership Agreement, the Partnership does not permit Partners to make withdrawals from their Capital Accounts. . Transferability of Interests. There are severe restrictions on transfers of Interests. The prior written consent of the General Partner is required for a transfer of Interests. Because of the restrictions on withdrawals and transfers, an investment in the Partnership is a relatively illiquid investment and involves a high degree of risk. A subscription for Interests should be considered only by persons financially able to maintain their investment and who can accept a loss of all of their investment. Substantially all decisions with respect to the No Participation by Limited Partners management of the Partnership are made exclusively by the General Partner and the Investment Manager or their designees. Limited Partners have no right or power to take part in the management of the Partnership. . Institutional Risk. The Partnership and/or the Underlying Funds could incur major losses due to the financial difficulty of the brokerage firm, bank, or other custodian with which the Partnership and/or the Underlying Funds deposit their assets. Partnership investments in Underlying Funds Limited Partner in the Underlying Funds present certain unique risks to investors. For example, a smaller limited partner investing in an Underlying Fund may be materially affected by the actions of a larger limited partner investing in the same Underlying Fund. Expenses or liabilities of an Underlying Fund (or its Portfolio Manager) arising from any legal action or proceeding against the Underlying Fund would be borne by the Underlying Fund, and creditors of the Underlying Fund may enforce claims against all assets of the Partnership invested in the applicable Underlying Fund. In addition, different tax considerations applicable to the Partnership and other limited partners in an Underlying Fund may cause conflicts between them and result in adverse tax consequences for the Partnership. Layering of Fees and Expenses. The allocation of the Partnership’s assets to Underlying Funds will increase the fees and expenses payable by the Partnership because the Portfolio Managers charge their own fees and expenses, which are in addition to the GP Fee, the Management Fee, and expenses charged by the Partnership. Each Portfolio Manager may charge its investors a management fee which will be in addition to the Management Fee charged by the Investment Manager and the Partnership will have to pay such fees, directly or indirectly. If such management fees are charged, they will reduce the net return realized by 25  the Partnership on its investment in such Underlying Fund. The general partner of each Underlying Fund (or an affiliate thereof), which is generally an affiliate of the Portfolio Manager, may also be entitled to receive a performance allocation, performance fee, or carried interest (collectively, “Incentive Compensation”). Because an Underlying Fund’s general partner earns Incentive Compensation based on the performance of its Underlying Fund, such general partner may earn Incentive Compensation during periods when the overall Partnership depreciates or stays flat. In addition, certain Underlying Fund general partners may be entitled to Incentive Compensation equal to a percentage of the amount by which performance of an Underlying Fund exceeds the performance of a particular preferred return, benchmark or hurdle rate, including during periods when both an Underlying Fund and its benchmark have depreciated. If an Underlying Fund’s general partner is entitled to Incentive Compensation, such Incentive Compensation will reduce the net return realized by the Partnership on its investment in the Underlying Fund. In addition, Portfolio Managers may take greater risks when their compensation (or their affiliated general partner’s compensation) is based on profits, particularly when they do not share in the loss of invested capital. Lack of Diversification. While the Investment Manager intends to provide exposure to a diversified pool of Portfolio Investments within the scope of the Partnership’s investment program, there is no guarantee that either (i) a sufficient number of suitable investments will be found or (ii) ample capital will be raised to make all desired investments. As such, the assets of the Partnership may be heavily concentrated in one more Portfolio Investments. In addition, different Underlying Funds may each invest in the same type of investments or in the same geographical areas causing the Partnership to have an undue concentration of its assets in one particular type of investment or geographical area. In addition, the diversification policies of the Underlying Funds may differ and vary from time to time and, consequently, they may not maintain the anticipated level of diversification. The diversification policy of the Partnership may change, in which event Limited Partners may not achieve the degree of diversification among strategies that they anticipated. Valuation. The Partnership and the General Partner will generally rely on the valuations provided by the Portfolio Managers for the purposes of calculating the Fair Value of the Partnership’s assets invested in Underlying Funds and preparing financial reports. There is no assurance that such valuations will be correct or that such information will be received in a timely manner. The Underlying Funds will invest in certain assets which do not have a readily ascertainable market price. Such assets will nevertheless generally be valued by the Portfolio Managers, which valuation generally will be conclusive with respect to the Partnership, even though Portfolio Managers will generally face a conflict of interest in valuing such securities because the value of the securities will affect their compensation. 26  Liability for Return of Distributions. If the Partnership is otherwise unable to meet its liabilities and obligations to a Portfolio Investments, the Limited Partners may under applicable law be required to return cash distributions previously received by them to the extent that such distributions are deemed to constitute a return of their contributed capital or are deemed to have been wrongfully paid to them. In addition, a Limited Partner may be liable under applicable federal and state bankruptcy laws to return a distribution made during the Partnership's insolvency or within a certain period of time prior thereto. Reserves. Under certain circumstances, the Partnership or an Underlying Fund may find it necessary to establish a reserve for contingent liabilities or withhold a portion of distributions to investors, in which case the reserved portion would remain at the risk of the Partnership's or such Underlying Fund’s activities. Material, Nonpublic Information. From time to time, certain personnel of a Portfolio Manager or its affiliates may come into possession of material, nonpublic information that would limit the related Underlying Fund’s ability to buy and sell investments. The Underlying Fund’s investment flexibility may be constrained as a consequence of the Portfolio Manager’s inability to take certain actions because of such information. The Underlying Fund may experience losses if it is unable to sell an investment held by it because certain personnel of its Portfolio Manager have obtained material, nonpublic information about such investment. . In the event of the early termination of the Partnership, the Partnership Early Termination would have to distribute to the Limited Partners their pro rata interests in the assets of the Partnership. Certain assets held directly or indirectly by the Partnership may be highly illiquid and might have little or no marketable value. It is possible that at the time of such sale or distribution, certain securities held by the Partnership would be worth less than the initial cost of such securities, resulting in a loss to the Limited Partners. Effect of Substantial Withdrawals. Substantial withdrawals could be triggered by a number of events, including, without limitation, unsatisfactory performance, events in the markets or other significant change in personnel or management of the Investment Manager, resignation of the Investment Manager as the investment manager of the Partnership, legal or regulatory issues that investors perceive to have a bearing on the Partnership or the Investment Manager, or other events. Actions taken to meet substantial withdrawal requests from the Partnership (as well as similar actions taken simultaneously by investors in any other accounts managed by the Investment Manager) could result in prices of securities held by the Partnership decreasing and in Partnership expenses increasing (e.g., transaction costs and the costs of terminating agreements). The overall value of the Partnership also may decrease because the liquidation value of certain assets may be materially less than their cost or mark- to-market value. The Partnership may be forced to sell its more liquid positions, which may cause an imbalance in the portfolio that could have a material adverse effect on the remaining 27  Limited Partners. Substantial withdrawals could also significantly restrict the Partnership's ability to obtain financing needed for its investment strategies, which would have a further material adverse effect on the Partnership's performance. In addition, if the Partnership and any other account managed by the Investment Manager were to incur substantial losses or were subject to an unusually high level of withdrawals, the revenues of the Investment Manager may decline substantially. Such losses and/or withdrawals may hamper the Investment Manager's ability to (i) retain employees, (ii) provide the same level of service to the Partnership as it has in the past, and (iii) continue operations. The Partnership, the General Partner and the Investment Manager generally will not disclose to Limited Partners the amount of pending withdrawals or withdrawal requests and are under no obligation to make any such disclosure. Suspensions of Withdrawals. The General Partner, in its sole and absolute discretion when it deems appropriate, in whole or in part, may suspend the determination of the net asset value of the Partnership and/or the right or obligation to withdraw the limited partnership interests and/or extend the period for payment on withdrawal proceeds. This could significantly impact a Limited Partner’s ability to withdraw capital from the Partnership, and investors must be prepared to bear an investment in the Partnership for an indefinite period of time. Investor Concentration. At any one point in time, the majority of assets that employ the Partnership’s strategy may be indirectly held by a few Limited Partners. Although the Partnership has certain mechanisms designed to facilitate orderly withdrawals (including, without limitation, notice periods and provisions imposing restrictions on the amounts and dates of withdrawals), substantial withdrawals by these Limited Partners within a short period of time could require the Investment Manager to liquidate positions more rapidly than would otherwise be desirable, which could adversely affect the value of the assets of the Partnership. The resulting reduction in the assets of the Partnership could make it more difficult to generate a positive rate of return or to recoup losses due to a reduced equity base. Subscription Monies. Where a subscription for limited partnership interests is accepted, the limited partnership interests will be treated as having been issued with effect from the relevant subscription date notwithstanding that the subscriber for those limited partnership interests may not be entered in the Partnership's books and records until after the relevant subscription date. The subscription monies paid by a subscriber for limited partnership interests will accordingly be subject to investment risk in the Partnership from the relevant subscription date. Potential Conflicts of Interest. The General Partner and the Investment Manager. The General Partner and the Investment Manager and their respective members, officers, employees and affiliates engage in a wide variety of investment activities and will continue to do so in the future, including conducting 28  investment activities for their own accounts and for other entities and accounts, including Advisory Client accounts and Affiliated Funds. Such other entities or accounts may have investment objectives or may implement investment strategies similar to those of the Partnership. In addition, the General Partner and the Investment Manager and their members, officers, employees, and affiliates may have investments in their own names and in certain of the entities, including Affiliated Funds, managed by the General Partner or the Investment Manager. As a result of the foregoing, each of the General Partner and the Investment Manager and their members, officers, directors, employees, and affiliates may have conflicts of interest in allocating their time, activity, and investment opportunities between the Partnership and other entities. Each of the General Partner, Investment Manager, and their respective members, officers, employees and affiliates may give advice or take action with respect to such other entities or accounts that differs from the advice given with respect to the Partnership’s investments. In the event of any potential conflicts of interest due to any other investment or business relationship, each of the General Partner and the Investment Manager and their members will act in the manner which they in good faith believe to be in the best interests of the Partnership. If a conflict of interest does arise, such conflict should be resolved in a fair and equitable manner. Tax Considerations Possible Adverse Tax Consequences. The tax consequences arising from an investment in the Partnership are highly complex and highly dependable on various factors such as a potential investor’s specific circumstances. Accordingly, prospective investors should consult their own tax and other advisors as to the advisability and tax consequences to their particular circumstances of an investment in the Partnership (see below under “ ”). In particular, all prospective investors should be aware that they may owe taxes annually on the Partnership’s income and realized gains. Due to differences in the timing of the recognition of income for the Partnership’s investments (including income from the Portfolio Investments) and cash distributions to the Partners, a Partner’s tax liability for a year may in certain circumstances exceed such Partner’s cash distributions for such year. The foregoing risk factors do not purport to be a complete explanation of all of the risks involved in the offering or an investment in the partnership. Please refer to the Private Placement Memorandum for a full list of risk factors and conflicts of interest. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. All investments include inherent risks of loss of principal and are affected by many factors which may be out of our control and could not be reasonably foreseen. As investment markets can fluctuate substantially, we will do our best to make security selections that, in line with the investment objective which you set, will fulfill your objective over the long term. We cannot guarantee any level of performance over any time horizon, nor can we ensure that you will not experience a loss of your assets either in whole or in part. 29  Prospective Limited Partners should know that an investment in the Fund involves a significant amount of risk, which could include the possible loss of the entire investment. Prospective Limited Partners should carefully consider the risk factors discussed in the Private Placement Memorandum. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Bellatore or the integrity of Bellatore’s management. Bellatore has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Bellatore has agreements with various unaffiliated broker-dealers (referred to as “Selling Agreements”) stating the terms under which those broker-dealers authorize their registered representatives to refer potential clients to Bellatore or offer the Bellatore programs identified in Item 4 above to their clients. In most cases, these Selling Agreements provide for the payment of all fees pertaining to Bellatore’s accounts directly to the cooperating broker-dealers. In addition, Bellatore may pay such broker-dealers up to ten basis points (0.10%) of its advisory fees to compensate those broker-dealers’ for ongoing due diligence and compliance relating to Bellatore’s asset management programs. Bellatore may also pay broker-dealers additional compensation to participate in selected marketing programs. Bellatore occasionally sponsors educational seminars for selected Financial Advisors. Invitations are issued at Bellatore’s discretion. Such special educational sessions provide an opportunity to introduce leading Financial Advisors to one another, to solicit ideas from the participants about sales and marketing opportunities, and to provide advanced technical and investment education. These learning opportunities are sponsored and may be paid for by Bellatore at no additional cost to the attending Financial Advisor or his/her clients. Bellatore may pay for all, or a part of the travel and other expenses of each selected Financial Advisor associated with attendance at such educational seminars. Bellatore may provide other services intended to assist and develop Financial Advisors’ businesses, including consulting, publications, and conferences on practice management, information technology, and marketing. Those services may be 30  provided directly or through a firm that has partnered with Bellatore to provide such services at cost, at a discounted price or at no cost to the Financial Advisor. Bellatore retains the discretion to negotiate prices for these services, and whether or not to charge the Financial Advisor. As such, a conflict of interest may arise if Financial Advisors partner with Bellatore based upon the receipt of these additional services rather than the services that the Financial Advisors provide to their clients. Bellatore Financial, Inc. and HFG Wealth Management, LLC, a registered investment adviser, are affiliated through common ownership. Mr. Harvey is also a principal owner of Bellatore Holdings, Inc. (formerly Bella Fund Holdings), which is a shareholder of Bellatore Financial Inc., as stated in Item 4 of this brochure. Mr. Harvey is a member of Sable Ventures, LLC and Sable Assets, LLC. Mr. Harvey is licensed to sell insurance to clients and may recommend insurance products on a fee-only basis. He maintains license arrangements with several insurance companies as necessary to meet the needs of clients and operates as an independent agent without any special arrangement with any particular insurance company. When the client and the representative of Bellatore agree that a client has an insurance need, the representative will typically earn the normal fees associated with the insurance products. Mr. Harvey receives compensation for the sale of variable annuities, indexed universal life policies, survivorship universal life policies term insurance and life policies. The policy of Bellatore is to disclose to the client any fee that will be earned on the sale of insurance prior to completing the transaction. To the extent that Bellatore’s financial planning process results in the recommendation of insurance products, provision of such products may entail a conflict of interest with Bellatore clients as there exists an incentive for a Bellatore representative to potentially recommend insurance products based on the compensation received, rather than based on the client’s needs. Bellatore manages this conflict of interest by monitoring the suitability of such products as a portion of the client’s investment needs, by utilizing insurance products only where it is in the client’s best interest, and after consultation, which includes the disclosure of such potential conflicts in accordance with our fiduciary duty as the client’s adviser. The client always has the right to decide to act on an insurance recommendation made by Mr. Harvey, and if they do decide to purchase, they are free to purchase from any insurance agent of their choice. HFG Opportunity Fund LP HFG Opportunity Fund LP, is a Delaware limited partnership (the “Fund”). The Fund’s investment objective is to seek to generate long-term capital appreciation and attractive risk- adjusted returns through careful selection of a diversified portfolio of public and private Portfolio Investments, including private funds (“Underlying Funds”). The Partnership aims to 31  achieve its objective by employing a flexible, opportunistic investment approach across multiple asset classes, including public and private debt, public and private equity, and alternative investments. PPB HFGO Mgt LLC, a Delaware limited liability company, is the co - general partner of the Fund (the “PPB General Partner”); and Bellatore Financial, Inc., a Delaware corporation, is the investment manager of the Fund (the “Investment Manager”). Mr. Harvey is the Chief Executive Officer and an Investment Advisory Representative of HFG Wealth Management, LLC. Mr. Harvey is the Chief Executive Officer of Bellatore Financial, Inc., which is the Investment Manager of HFG Opportunity Fund LP. Mr. Harvey is one of the members of HFG Opportunity Fund LP’s Investment team. These activities create a conflict of interest which provides an incentive for Mr. Harvey to recommend qualified investors to the Fund, which results in compensation for Mr. Harvey, either directly or indirectly. The Firm addresses its fiduciary duty by maintaining oversight of Mr. Harvey’s securities activities and outside business activities. Mr. Pizzutello is the Chief Investment Officer and an Investment Advisory Representative of HFG Wealth Management, LLC. Mr. Pizzutello is the Chief Compliance Officer of Bellatore Financial, Inc., which is the Investment Manager of HFG Opportunity Fund LP. Mr. Pizzutello is one of the members of HFG Opportunity Fund LP’s Investment team. These activities create a conflict of interest which provides an incentive for Mr. Pizzutello to recommend qualified investors to the Fund, which results in compensation for Mr. Pizzutello, either directly or indirectly. The Firm addresses its fiduciary duty by maintaining oversight of Mr. Pizzutello’s securities activities and outside business activities. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Bellatore has adopted a Code of Ethics (the “Code”) for its officers, directors and employees that includes:  General principles of business conduct for all employees;  Restrictions on investment transactions in which Bellatore’s officers, directors and certain other persons have a beneficial interest to avoid any actual or potential conflict or abuse of their fiduciary position. The Code permits personnel subject to the Code to invest in securities, but contains several restrictions and procedures designed to eliminate conflicts of interest including, but not limited to: (a) quarterly reporting of personal securities transactions and annual reporting of securities holdings; (b) a prohibition against acquiring securities in a private placement, limited offering or initial public offering without first obtaining preclearance from the Chief Compliance Officer; (c) procedures whereby the Chief Compliance Officer monitors and reviews all 32  reports required under the Code, including quarterly statements containing personal securities transactions.  A policy statement on insider trading that provides generally that no officer, director or employee of Bellatore (a) may buy or sell a security either for themselves or others while in possession of material non-public information about the company, or (b) communicate material non-public information to others who have no official need to know. This policy statement provides guidance about what is material non-public information, lists common examples of situations in which Firm personnel could obtain that information, and describes Bellatore’s procedures regarding securities maintained on any “restricted lists” established by the Firm.  A policy governing gifts, payments and entertainment, which includes an approval process for specific categories of gifts and entertainment provided to Bellatore employees.  A policy governing an employee’s outside business activities, including outside employment, service as a director or in a similar capacity and fiduciary appointments.  A policy governing the protection of confidential client information and employee responsibilities in securing client-related information. The policy also includes the Firm’s Privacy Policy.  A policy stating that it is the Firm’s practice that employees report illegal activities or activities that violate the Code or the Firm’s written policies and procedures. The Code is based upon the principle that Bellatore and its employees owe a fiduciary duty to Bellatore’s clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (a) serving their own personal interests ahead of clients, (b) taking inappropriate advantage of their position with the Firm and (c) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. The Firm recognizes that its name and reputation continues to be a direct reflection of the conduct of each employee. Compliance with the Code involves more than acting with honesty and good faith alone. It means that the employees of Bellatore have an affirmative duty of utmost good faith to act solely in the best interests of the Firm’s clients. A copy of Bellatore's Code of Ethics will be provided to clients upon request. No Principal or Agency Cross Transactions 33 It is Bellatore’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts. Bellatore will also not cross trade between client accounts.  Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Item 12 – Brokerage Practices Financial Advisors and the Firm’s clients must actively choose the custodian and broker- dealer for their account(s). The Firm currently has relationships with Charles Schwab & Co. and Charles Schwab, all of which are independent brokerage firms that are unaffiliated with Bellatore. Bellatore may confer with the Financial Advisor or the client on a particular choice of broker- dealer prior to entering into an agreement for Bellatore’s services. Bellatore weighs various factors in determining whether a particular broker-dealer is appropriate for a client account, such as the ease with which Bellatore can conduct day-to-day administration of accounts with such broker-dealer; the ease with which clients can open accounts, obtain information and execute trades with such broker-dealer; and the reasonableness of commissions. In considering the reasonableness of commissions, Bellatore takes into account the commissions relative to other available broker-dealers that Bellatore has relationships with, and evaluates the services provided by the proposed broker-dealer. In addition to the other custodians mentioned above, Bellatore may recommend/require that clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc., member FINRA/SIPC/NFA (“Schwab”), or the Charles Schwab Institutional program., member FINRA/SIPC to maintain custody of clients’ assets and to effect trades for their accounts. Although Bellatore may recommend/require that clients establish accounts at Schwab, it is the client’s decision to custody assets with this firm. Bellatore is independently owned and operated and not affiliated with Schwab. Charles Schwab provides Bellatore with access to custody of securities, trade execution, clearance and settlement of transactions, which may or may not be available to retail investors. Many of these services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a specified minimum of the advisor’s client assets are maintained in accounts at these broker-dealer custodians. These services are 34  not contingent upon Bellatore committing to any specific amount of business (assets in custody or trading commissions). These firms’ brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. There is no direct link between Bellatore’s use and participation in a custodian’s program and the investment advice Bellatore gives to its clients, although Bellatore receives economic benefits through its participation in various programs offered by these custodians that are not typically available to retail investors. For Bellatore client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab Advisor Services Institutional also make available to Bellatore other products and services that benefit Bellatore but may not directly benefit its clients’ accounts. Many of these products and services may be used to service all or some substantial number of Bellatore’s accounts, including accounts not maintained at Schwab. Schwab products and services that assist Bellatore in managing and administering clients’ accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of Bellatore’s fees from its clients’ accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Schwab Advisor Service Institutional also offer other services intended to help Bellatore manage and further develop its business enterprise. These services may include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. Schwab may make available, arrange and/or pay third-party vendors for the types of services rendered to Bellatore. Schwab Advisor Services Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to Bellatore. Schwab Advisor Services Institutional may also provide other benefits such as educational events or occasional business entertainment of Bellatore personnel. In evaluating whether to recommend or require that clients custody their assets at Schwab, Bellatore may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers and not solely on the nature, cost 35  or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Item 13 – Review of Accounts UMAP Bellatore provides Financial Advisors with tools to help determine client asset allocations and helps implement the Financial Advisor’s recommended asset allocation program for their clients. After a discussion with the client, the Financial Advisor may submit a model portfolio to Bellatore that corresponds to the level of risk and investment objectives of the client. Bellatore will calculate rates of return and risk metrics used to plan for a client’s personal goals. Bellatore periodically monitors, reviews and repositions assets, if necessary, to bring a client’s current asset allocation closer to the target allocations, unless the client, through his or her Financial Advisor, has requested otherwise. Rebalances may also occur when the Financial Advisor and/or client gives instructions to change the client’s target allocations or make additions to or withdrawals from the client’s account(s). Bellatore’s Investment Committee helps determine the inventory of funds to use and general guidelines for the percentages for each level of client risk. Through regular discussions with Bellatore’s investment personnel, the Investment Committee members discuss current market conditions, create and debate research efforts and review the firm's investment philosophy and investment processes. Bellatore encourages Financial Advisors to contact their clients on a regular basis and to notify Bellatore of any changes to a client’s instructions or investment objectives. In addition, Bellatore makes written inquiries at least every twelve (12) months regarding changes in any client’s financial situation, needs or investment objectives. Financial Advisors are encouraged to meet with their clients more frequently in order to determine if a client’s investment goals and objectives have changed. The custodian of each account provides statements to the client at least quarterly and Bellatore provides supplemental quarterly reports for accounts. CAM Program and Altius Program 36  The Bellatore investment team is responsible for managing the CAM Program and Altius Program model portfolios and for monitoring the various investment products and portfolio managers included in the program. The team uses both quantitative and qualitative criteria to evaluate investment products and portfolio managers on an ongoing basis. Quantitative criteria include investment style, relative risk, expenses, and performance. Qualitative criteria include an evaluation of the organization, its investment management team, and its investment process. The Firm’s Investment Committee is responsible for overseeing the decisions of the investment team. The Investment Committee meets on a regular basis to review the team’s selection of investments and portfolio managers and to approve any proposed changes in product offerings or investment strategies. When selecting investments for the portfolios, the Investment Committee focuses on selecting funds with seven business days or less of a short- term trading restriction. This focus significantly reduces the probability of incurring a short- term trading fee without compromising the quality of the mutual funds. At least quarterly, clients receive written statements of account transactions from the client’s custodian. Clients also receive quarterly statements from Bellatore indicating, among other things, the valuation of their program assets. Item 14 – Client Referrals and Other Compensation Bellatore may compensate third parties for client referrals and may maintain “solicitation agreements.” Typically, Bellatore may have an arrangement with a broker-dealer firm to compensate the firm for ongoing compliance and oversight, advisor education of our services, participation in advisor educational events and access to advisors associated with the broker- dealer firm. Additionally, Bellatore may engage certain third-party consultants to provide client introductions to the firm for a recurring fee. As required under Rule 206(4)-3 under the Advisers Act, such third-party solicitors obtain disclosure statements from prospective clients and Bellatore ensures that it complies with the rule’s provisions. Bellatore considers a number of factors in selecting brokers and custodians at which to locate (or recommend location of) its client accounts, including, but not limited to, execution capability, experience and financial stability, reputation and the quality of services provided. When using the services of Charles Schwab Institutional (“Charles Schwab”) as the broker and custodian for certain of its current and future client accounts, Bellatore takes into consideration its arrangement with Charles Schwab as to obtaining price discounts for Charles Schwab’s automatic portfolio rebalancing service for advisors known as “iRebal” and also provides discounts for third-party portfolio accounting and trade processing solutions that Bellatore uses, such as Orion Advisor Services. 37  The standard iRebal annual license fee applicable to Bellatore is $26,000. That fee is subject to specified reductions (and even complete waiver) if specified amounts of client taxable assets are either already on the Charles Schwab platform or are committed to be placed on it. Specified taxable client assets either maintained on or committed to the Charles Schwab platform will bring fee reductions of up to $26,000 per year for each of as many as three years or more. The non-taxable assets excluded from the maintenance and commitment levels described above are those that constitute “plan assets” of plans subject to Title 1 of the Employee Retirement Income Security Act of 1974, amended, or of plans as defined in Section 4975 of the Internal Revenue Code (which include IRAs). If Bellatore does not maintain the relevant level of taxable assets on the Charles Schwab platform, Bellatore may be required to make a penalty fee payment to Charles Schwab calculated on the basis of the shortfall. Additionally, Bellatore has special arrangements in place with some of the third party custodians with which it has relationships to receive benefits from those custodians. Please see our answer to Item 12 above regarding the benefits Bellatore may receive in exchange for having client assets held at certain custodians, such as Schwab. Item 15 – Custody Clients should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains client’s investment assets. Bellatore urges you to carefully review such statements and compare such official custodial records to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Bellatore is deemed to have custody because of HFG Opportunity Fund, LP as disclosed in sections “Advisory Business,” and “Other Financial Industry Activities and Affiliations. This private investment company is audited annually, and the investors receive financials within 180 days of the fiscal year-end. Item 16 – Investment Discretion 38  With the exception of certain UMAP accounts, Bellatore usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining amounts, Bellatore observes the investment policies, limitations and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to Bellatore in writing. Item 17 – Voting Client Securities As a matter of firm policy and practice, Bellatore does not have any authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Bellatore may provide advice to clients regarding the clients’ voting of proxies. Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about Bellatore’s financial condition. Bellatore has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 39