CAPITAL CREEK PARTNERS, LLC

Item 1 – Cover Page Capital Creek Partners, LLC 1608 W. 5th St, Suite 200 Austin, Texas 78703 www.capitalcreek.com March 31, 2025 This brochure provides information about the qualifications and business practices of Capital Creek Partners, LLC (“CCP” or the “Firm”). If you have any questions about the contents of this brochure, please contact us at 512.316.3397 and/or IR@capitalcreek.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. information about Capital Creek also is available on the SEC’s website at Additional www.adviserinfo.sec.gov.  Item 2 – Material Changes There have been no material changes to this Brochure from the previous annual update. We routinely make updates throughout the Brochure to improve and clarify the description of our business practices, and compliance policies and procedures, as well as to respond to evolving industry best practices. Although these changes may not be material, please review this Brochure carefully and in its entirety. Investors should also read the governing documents applicable to their current or prospective investments. 2  Item 3 – Table of Contents Item 1 – Cover Page ..............................................................................................................................1 Item 2 – Material Changes .....................................................................................................................2 Item 3 – Table of Contents ....................................................................................................................3 Item 4 – Advisory Business.....................................................................................................................4 Item 6 – Performance Based Fees ...........................................................................................................8 Item 7 – Types of Clients ........................................................................................................................9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .....................................................9 Item 9 – Disciplinary Action ................................................................................................................. 17 Item 10 – Other Financial Industry Activities and Affiliations ................................................................. 17 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 18 Item 12 – Brokerage Practices .............................................................................................................. 18 Item 13 – Review of Accounts .............................................................................................................. 20 Item 14 – Client Referrals and Other Compensation .............................................................................. 20 Item 15 – Custody ............................................................................................................................... 21 Item 16 – Investment Discretion .......................................................................................................... 21 Item 17 – Voting Client Securities ......................................................................................................... 21 Item 18 – Financial Information ........................................................................................................... 22 Item 19 – Requirements for State-Registered Advisers .......................................................................... 22 3  Item 4 – Advisory Business Capital Creek Partners, LLC (“CCP” or the “Firm”) is a private wealth management investment firm. The Firm was founded in 2019 and its principal owners are Robert Gauntt, Michael Miller, and Mark Shoberg. CCP provides broad investment advisory services to approximately twenty families and family office clients comprised of individuals and their related entities, including trusts and estates, as well as charitable organizations, foundations, and other clients (“Clients” or “Managed Account Clients”). CCP provides individualized strategic advice and wealth management over diversified asset classes, including both public and private investments. The Firm typically engages unaffiliated sub-advisors to manage portions of Clients’ assets and/or give Clients access to private funds advised by third-party managers and other alternative assets through sponsored investment vehicles. CCP conducts initial and ongoing due diligence on such sub-advisors and managers and negotiates fees, among other terms, to be paid by Clients. From time to time, when appropriate, CCP will recommend private investments, such as direct private placements or joint venture investments, not offered through sponsored investment vehicles (“Direct Private Investment”). CCP also recommends individual exchange traded funds, equities, fixed income securities, or digital assets for Client portfolios. CCP’s services are based on the individual needs of its Clients and investment recommendations are tailored to each Client’s goals. Clients may impose reasonable restrictions in the written investment management agreement or at any time by providing written instructions to the Firm. CCP sponsors pooled investment vehicles (“Private Funds”) that are limited partnerships comprised of asset class specific, third-party managed underlying private investments and/or private funds (“Portfolio Funds”). The Private Funds are utilized by Managed Account Clients to gain access to CCP’s investment ideas and managers that may otherwise require higher subscription or commitments than appropriate for their diversification needs. Managed Account Clients may invest directly in the Portfolio Funds based on the client’s unique suitability, diversification, and Portfolio Funds’ subscription minimum. In addition, non- Managed Account Clients are permitted to invest in the Private Funds alongside Managed Account Clients. CCP also sponsors pooled investment vehicles that serve as an investment platform to provide access to private markets investments (“Access Funds” and together with the Private Funds, the “CCP Funds”) either in specific sectors, such as venture capital, private equity, real estate, energy, natural resources and infrastructure, and credit (each a “Series”), or as part of an asset allocation portfolio. Investors in the Access Funds elect to make a capital commitment to one or more of the Series in accordance with their own customized allocation or investment percentages, or in accordance with the standard model of allocation or investment percentages as part of an asset allocation portfolio set forth by CCP. Each Series participates in its own portfolio of investments and generally invests through its own intermediate entities. Please review Item 8 and Item 12 below for more information about CCP’s allocation policy related to the Access Funds. The CCP Funds are private pooled investment vehicles, which are exempt from registration under the Investment Company Act of 1940, as amended, and exempt from registration under the Securities Act of 1933, as amended. The Firm has full discretionary authority with respect to investment decisions of the CCP Funds, and its advice with respect to the CCP Funds is tailored according to the investment objectives, guidelines, and requirements as set forth in each CCP Fund’s respective offering memorandum and advisory agreement (the “Governing Documents”). Responsibility for managing each CCP Fund, including all day-to-day operations and investment activities, has been delegated to the Firm by the CCP Fund’s general partner (each, a “General Partner”). 4  In conjunction with wealth management services, CCP may provide other services, including, without limitation, comprehensive reporting services incorporating a majority of Client assets and liabilities, regardless of custodian or asset manager. Such services may include broad-based balance sheet and cash flow analysis and reporting; budgeting and forecasting; tax and insurance analysis; charitable and estate gift planning; and other family office services. As of December 31, 2024, CCP managed $323,050,933 of client regulatory assets on a discretionary basis, and $919,801,221 of client regulatory assets on a non-discretionary basis. Item 5 – Fees and Compensation Managed Account Advisory Fees CCP charges an investment management fee (“Managed Account Management Fee”), generally equal to a percentage of managed assets, ranging from 0.25% to 1.00%. Fees are generally lower for Managed Account Clients with higher amounts of assets under management and have been negotiated depending on several factors unique to each Managed Account Client, including the Managed Account Client’s needs, nature and complexity of the services required, and types of assets. Certain Managed Account Clients have negotiated alternative fee structures, which include flat fees, tiered fees, fees based on committed or invested capital and/or performance fees, which is described in more detail in the following section. Managed Account Management Fees and expenses applicable to each Managed Account Client are set forth in detail in Client investment management agreements. In accordance with each investment management agreement, fees are deducted directly from Client custodial accounts or invoiced. Fees are typically charged quarterly in arrears, based on the average month-end net asset brokerage account value or net asset capital statement value balance during the prior quarter. To the extent a Client terminates the advisory relationship, the Client will be charged the pro-rata amount of fees rendered to the point of termination. Client investments in unregistered private fund investments may consist of both redeemable (e.g., hedge funds) and nonredeemable interests (e.g., private equity funds, direct private placements, or real estate joint ventures). Fees paid by the Clients are based on valuations of underlying investments as reported by the third-party managers and/or private funds, and in accordance with the terms and conditions of the respective governing agreement of the investment vehicle. Valuations are typically recorded at the net asset value reported by the private fund manager/sponsor, which generally equals the Client’s proportional share of net asset value reported by the sponsor of the private fund. The frequency of valuations may vary, particularly for unregistered non-redeemable private funds, which may be reported on a quarterly basis. In such situations, CCP will roll forward the most recently available valuations for fee billing purposes, taking into consideration factors such as, fund specific redemption restrictions, related capital account transactions, events that occurred during the quarter, and current market conditions which may affect the value of specific investment. As further disclosed in Item 8 below, there is a risk when relying on third party managers to value investments that are not readily marketable. Additionally, there is a risk that the time lag between valuation date and when CCP receives the valuations could negatively (or favorably) affect management fees that CCP invoices. To mitigate this risk, CCP has implemented operational due diligence policies and procedures that, among other things, assess third- party managers’ valuation policies. 5  Private Fund Investment Management Fees The General Partner receives an investment management fee from each Private Fund (“Private Fund Management Fee”) that is payable quarterly in advance, and as further described in the applicable Fund Governing Documents. Private Fund Management Fees range from 0.50% to 1.00% based on committed capital during the investment period. Thereafter, the Private Fund Management Fee is calculated off invested capital. The Private Fund Management Fee may be reduced or waived at the discretion of the General Partner. Access Fund Investment Management Fees The General Partner receives an investment management fee from each series in the Access Funds (“Access Fund Management Fee”) that is payable quarterly in advance, and as further described in the applicable Access Fund Governing Documents. Management fees for Series A interests are 1%, Series B .5% and Series C .25% based on capital commitments to the respective Series interests until either the 3rd anniversary of the initial closing date of the fund or net asset value attributable to the respective Series, thereafter. Access Fund Management Fees may be reduced or waived at the discretion of the General Partner. For Managed Account Clients that invest in the CCP Funds, the Firm deducts the respective CCP Fund Management Fee from the Managed Account Management Fee calculation to avoid “double fees.” To the extent a Managed Account Client’s commitment into a CCP Fund does not qualify for an investment management fee rate at or below the Managed Accounts’ investment management agreement stated rate, the Firm will reduce or waive a portion of such Managed Account Management Fee. For example, if a Managed Account Client invests in a CCP Fund, the Managed Account Client would pay the CCP Fund Management Fee quarterly in advance pursuant to the respective CCP Fund governing documents, and the Managed Account Management Fee would be paid in arrears pursuant to the investment management agreement. However, CCP will then deduct the respective CCP Fund Management Fee from the Managed Account Client’s fee calculation to avoid double billing. When taking into consideration the life of the Portfolio Fund investments, the Firm believes that it can be beneficial from an overall management fee perspective for Managed Account Clients to invest through the CCP Funds because the CCP Funds do not calculate management fees based on unrealized net asset valuations. As example, when CCP Funds appreciate in excess of CCP Fund level fees and expenses (CCP Fund expenses are discussed in more detail below), the investor fee basis remains based on committed capital, or if after the investment period, invested capital. However, if the Portfolio Fund’s net asset values are below committed capital or invested capital, then Managed Account Clients would pay higher collective management fees than had they invested (and were otherwise eligible) directly with the Portfolio Funds. Some of the CCP Funds pay a performance fee or carried interest fee. See Item 6 below for more information regarding performance fees. Managed Account Client Advisory Expenses Managed Account Clients may incur operational and transaction fees, costs and expenses imposed by custodians, brokers, prime brokers and other third parties. Clients invested in third-party managed pooled investment vehicles which include mutual funds, ETFs, private investment funds, such as, private equity or venture capital funds, and other similar pooled investments or third-party separately managed accounts will also incur fees and expenses associated with an investment in the vehicle or account which may include organizational fees, management fees, performance allocations and other costs and 6  expenses to third party managers. Additionally, Clients may also incur wire transfer fees and trustee fees by their custodians. Pursuant to Clients’ investment management agreements, Clients may be invoiced to reimburse CCP for certain expenses relating to the identification, selection, and acquisition (whether or not consummated) of investments, including, without limitation, attorney’s fees, due diligence and similar costs, travel (which may include non-commercial travel) and other expenses of other investment related service providers. Any expense reimbursements will be allocated in a fair and equitable fashion based on anticipated participation or other appropriate methodology. Private Fund Expenses As further set forth in the Governing Documents, each Private Fund is responsible for its own organizational, operational, and investment expenses including, but not limited to: all out-of-pocket third-party costs and expenses (including, without limitation, legal, accounting and administrative costs and expenses) incurred by or arising out of the operation and activities of the CCP Funds, the general partners or any of their affiliates on behalf of the CCP Funds, including, without limitation, costs and expenses incurred in respect of (a) offering of interests (including, without limitation, reasonable travel expenses and any legal or accounting fees and disbursements incurred in connection with the offering of interests), (b) accounting or audit compliance, (c) taxes and tax compliance, (d) filings and registration fees with respect to the CCP Funds, (e) litigation and insurance costs, (f) any indemnification obligation with respect to claims, (g) administration, including preparation of financial statements and reports and costs of holding any meetings of members or any advisory committees, (h) any loans, lines of credit, or other indebtedness incurred on behalf of the CCP Funds, including interest payments and other servicing fees and expenses attributable thereto, and (i) other extraordinary costs and expenses incurred with respect to the CCP Funds Access Fund Expenses As further set forth in the Governing Documents, each Access Fund is responsible for its own organizational, operational, and investment expenses including, but not limited to: (i) all legal, accounting and other professional fees and expenses and out-of-pocket costs incurred in connection with the offering of Access Fund interests; (ii) all expenses associated with the management of each Series or incurred in connection with the purchase, retention or sale by such Series of actual or proposed portfolio investments, whether or not consummated (e.g., the Management Fee, research, data subscriptions for portfolio analytics and oversight), expenses relating to Direct Private Investments (e.g., travel expenses, manager assessment, and oversight expenses), brokerage commissions and fees, underwriting commissions and discounts, unaffiliated manager fees and expenses, investment banker fees, and similar expenses and other trading and investment costs; (iii) legal expenses of such Series and regulatory and compliance expenses directly related to such Series (including such Series’ reasonable share of CCP’s reporting obligations directly related to such Series); (iv) all fees and expenses relating to administration, custody, appraisal, valuation, bookkeeping, accounting (including preparation of Schedules K-1 and tax returns), audit, performance and other reporting, printing, and similar services, functions or requirements, including fees and expenses of the service providers to such Series, including such Series’ “partnership representative”; (v) all income, transfer, stamp and other taxes and charges (including interest and penalties), all fees and other governmental charges levied against such Series and all expenses incurred in connection with any tax audit, investigation, settlement or review of such Series as determined by the respective general partner in its sole discretion; (vi) interest charges and costs incurred in connection with any credit facilities; (vii) extraordinary expenses (including litigation) and all indemnification and insurance expenses (including, without limitation and to the extent not prohibited by law, all costs of insurance to insure the general partner, the Firm and/or any other indemnified party 7  against certain liabilities, including liabilities for any breach or alleged breach of any applicable fiduciary responsibilities); (viii) all expenses of liquidating such Series; and (ix) all other expenses related to or incidental to, or in support of, the ongoing operation of such Series or the issuance of Interests therein (including, without limitation, the costs of printing and distributing offering materials, subscription materials, reports and notices and governmental and self-regulatory agency filing fees, costs, and expenses). Any costs and expenses common to a particular Series and any other Series or other entities or accounts managed by the Firm or its affiliates (“Other Series/Funds”) and any costs or expenses of the Partnership not attributable to one or more particular Series will be allocated among such entities in such manner as the Firm determines is fair and equitable. CCP generally expects to allocate investment- related expenses to a Series and Other Series/Funds pro rata based on their respective participations in the relevant investment. To the extent other operating expenses relate to both a Series and Other Series/Funds, CCP generally expects to allocate such expenses to each entity on a pro rata basis based on each entity’s respective aggregate net asset value, gross asset value or capital commitments or based on the relative benefits that each account received in respect of the expense. Management fees received by the Firm’s General Partner do not include investment management fees, carried interest, and expenses for underlying investment managers (i.e., Portfolio Funds). Such fees and expenses, as well as any withholding taxes payable and required to be withheld by issuers, their agents or others will reduce the assets held in (and gross return experienced by) relevant CCP Fund accounts. Other Managed Account Services As previously discussed, CCP will provide other services, including, without limitation, comprehensive reporting services incorporating a majority of Managed Account Client assets and liabilities, regardless of custodian or asset manager. Such services may include broad-based balance sheet and cash flow analysis and reporting; budgeting and forecasting; alternative investment review; charitable and estate gift planning; and other family office services. Fees for family office services are typically charged as a flat annual fee paid quarterly. Neither CCP nor its supervised persons accept compensation for the sale of securities or other investment products. Item 6 – Performance Based Fees As noted in Item 5, the Firm charges performance-based fees to certain Managed Account Clients and certain CCP Funds. Performance-based fees create an incentive for CCP to recommend investments that could be riskier or more speculative than those that would be recommended under a different compensation arrangement. Such compensation arrangements also create an incentive to favor higher fee-paying Clients over other Clients in the allocation of investment opportunities. CCP has investment allocation procedures designed to allocate investment opportunities among its Clients in a fair and equitable manner and to prevent this conflict from influencing the allocation of investment opportunities among Clients. See “Brokerage Practices” below for a description of how the Firm allocates investment opportunities. 8  Item 7 – Types of Clients CCP provides wealth management services primarily to ultra-high net worth individuals and their families, including related entities such as family limited partnerships and limited liability companies, trusts and foundations. The Firm does not have a stated minimum to open an account, however Clients typically have at least $50 million of investable assets under management. The Firm also offers investment advisory services to private pooled investment vehicles. Details concerning the CCP Funds’ investment criteria are set forth in the Governing Documents. Minimum investment commitment required to invest in the CCP Funds range from no minimum to $250,000, and the General Partner may reduce or waive any commitment minimums in its sole discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for any Client CCP seeks to employ a disciplined and rigorous due diligence process to assess and implement potential investment opportunities and strategies. CCP has designated investment professionals (the “Investment Committee”) to oversee its due diligence efforts, including, but not limited to conducting and documenting any research, risks, and overall suitability/support investment recommendations. CCP takes a holistic and diversified approach to managing Client portfolios, taking into account, among other things, a given Client’s assets, income, liquidity requirements, risk tolerance, and investment horizon. Investment strategies and investment recommendations are further tailored over time based on Clients’ changing needs and appetite for risk. CCP’s asset allocation and security selection are based on fundamental analysis of securities and investment products as well as the Firm’s view on macro-economic trends. In addition, Clients are invested in third-party investment managers, pooled investment vehicles, or direct private placement investments. CCP conducts independent review of, but may rely upon, the investment materials and other reports produced by those third-party investment managers or sponsors. Investment and operational due diligence are performed initially and periodically thereafter to evaluate third-party managers and sponsored investments. The Firm seeks to invest the CCP Funds through underlying managers across select asset classes, industries, and geographies. The Firm seeks to build relatively concentrated portfolios of underlying managers and funds within the risk/return parameters of the relevant CCP Fund. Investing in securities involves the risk of loss that Clients should be prepared to bear. There is no guarantee or representation made that CCP’s investment program will be successful, that a client will achieve targeted returns or that there will be any return of capital invested. Investment results may vary substantially over time. CCP’s methods of attempting to minimize such risks may not accurately predict future risk exposures. Risk management techniques are based in part on the observation of historical market behavior, which may not predict market divergences that are larger than historical indicators. Also, information used to manage risks may not be accurate, complete, or current, and such information may be misinterpreted. Investing and trading activities risk the loss of capital. Clients are advised to review CCP Fund and underlying governing documents for full details on investment, operational and other actual and potential 9  risks. This Brochure is not intended to address every potential risk, and certain risks described below may only apply to certain Clients or CCP Funds. Some of these risks may include, but are not limited to: • Investment and Trading Risks. Clients may be invested in securities and other financial instruments using strategies and investment techniques with significant risk characteristics. These include risks arising from the volatility of financial markets. The performance of any investment may depend on a number of factors, including conditions in regional and local economies, conditions in the securities markets generally, performance of companies in particular industries or regions and political and technological developments. • Investment Selection. In making its investment recommendations, CCP often relies on information and data provided and prepared by third parties. Although CCP intends to evaluate the accuracy and importance of such information and data, the Firm will not always be in a position to confirm the completeness, genuineness, or accuracy of such information and data. • General Economic and Market Conditions. A Client’s performance may be affected by general economic and market conditions and factors that impact the investments, such as interest or currency rates, availability of credit, inflation rates, real or perceived adverse economic conditions, economic uncertainty, changes in laws, and national, and international political developments. These fluctuations may be temporary or may last for extended periods. Unexpected volatility or illiquidity could impair a portfolio’s profitability or result in losses. • Foreign Trade Policy. If the U.S. federal government continues to make significant changes in U.S. trade policy, including imposing tariffs on certain goods and raw materials imported into the United States, such actions may trigger retaliatory actions by the affected countries, resulting in “trade wars,” which may cause increased costs for goods and raw materials imported into the United States, or in trading partners limiting their trade with businesses in the United States, either of which may have material adverse effects on a portfolio company’s business and operations. Such “trade wars” may cause significant losses for Funds and/or one or more portfolio investments. • Epidemics/Pandemics. Certain countries have been susceptible to epidemics, most recently Covid- 19, which may be designated as pandemics by world health authorities. The outbreak of such epidemics, together with any resulting restrictions on travel or quarantines imposed, has had and may continue to have a negative impact on the economy and business activity globally (including in the countries in which Funds invest), and thereby can adversely affect the performance of Fund investments. Furthermore, the rapid development of epidemics could preclude prediction as to their ultimate adverse impact on economic and market conditions, and, as a result, can present material uncertainty and risk with respect to the performance of Fund investments. • Inflation: Some countries, including the United States, currently and may in the future experience substantial rates of inflation, which may have negative effects on the economies and securities markets of their economies. Governmental efforts to curb inflation (such as price controls) may involve drastic economic measures affecting the level of economic activities. There can be no assurance that the relevant governments will be able to exercise effective control over inflation rates or that a high rate of inflation will not have a materially adverse effect on investments. • Force Majeure Risk: Investments may be affected by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts 10  of God, fire, flood, earthquakes, outbreaks of an infectious disease, pandemic or any other serious public health concern, war, terrorism, and labor strikes). Some force majeure events may adversely affect the ability of a party (including an investment or a counterparty) to perform its obligations until it is able to remedy the event. Certain force majeure events (such as war or an outbreak of an infectious disease) could have a broader negative impact on the world economy and international business activity generally. In particular, increased tensions between Russia and Ukraine have resulted in a Russian invasion of Ukraine. Such hostilities could not only have a severe adverse effect on the region, but also have significant negative impacts on the U.S. and/or global economy. These tensions, and any related events, could have a significant impact on performance and the value of an investment. loss or gain of key employees • Equity Markets and Stock Price Volatility. U.S. and foreign equities markets have experienced tumultuous times in the past reflected in highly volatile market prices for listed securities. Certain factors may have a significant impact on the market price of securities and, consequently, may adversely affect a Client’s portfolio, such as general economic data, interest and currency rate fluctuations, announcements of technological innovations, developments in patent or other proprietary rights, public concern or perception of issues relating to the safety of products developed by a company, announcements of collaborative partners, issues relating to government regulation, in research and/or operations, fluctuations in companies’ operating results, future sales of common stock, analysts’ comments, including changes in recommendations, and general market conditions. CCP may invest Clients in securities which may be more volatile and carry more risk than some other forms of investments. Security prices in general may decline over short or even extended periods of time and such declines may be significant. • Limited or No Liquidity. CCP may invest Client assets in privately offered pooled investment vehicles with limited liability such as private equity and venture capital funds. Interests in these vehicles are not freely transferable and generally have limited, or no, withdrawal rights. CCP may also invest Client assets in illiquid assets such as real estate that could be difficult to sell or transfer in certain market environments. • Private Funds and Other Alternative Assets. Investing in alternative assets managed by third- parties, such as hedge funds and other private investment funds can be: (i) highly speculative with investments in complex instruments and structures including derivatives and structured products; (ii) illiquid with limited withdrawal or redemption rights; (iii) leveraged; (iv) subject to significant volatility; (v) subject to long holding periods; (vi) less transparent than public investments; (vii) subject to significant restrictions on transfers; (viii) affected by complex tax considerations; and (ix) in the case of private equity funds, affected by capital call default risk. In addition to the above, investors in these strategies will be subject to fees and expenses which will reduce profits or increase losses. Each Managed Account Client and CCP Fund’s performance will be highly dependent upon the expertise and abilities of the third-party investment manager or Portfolio Fund selected or recommended by the Firm. Third-Party investment managers may or may not have extensive track records. • Artificial Intelligence and Machine Learning Developments. While the Firm may under certain circumstances restrict certain uses of third-party and open source AI tools, such as ChatGPT, the Firm’s employees and Client portfolio companies will under certain circumstances use these tools, which pose additional risks relating to the protection of the Firm’s and such portfolio companies’ proprietary data, including the potential exposure of the Firm or such portfolio 11  companies’ confidential information to unauthorized recipients and the misuse of the Firm or third-party intellectual property, which could adversely affect the Firm, a Client or its portfolio companies. Additionally, AI tools may produce inaccurate, misleading or incomplete responses that could lead to errors in CCP and its employees’ and consultants’ decision-making, portfolio management or other business activities, which could have a negative impact on the Firm or on the performance of a Client. As the use and availability of AI tools has grown, the U.S. Congress and a number of U.S. federal and state agencies have been examining the AI tools and their use in a variety of industries, including financial services. These agencies have issued proposed or adopted a variety of rules and other guidance regarding the use of AI. AI similarly faces an uncertain regulatory landscape in many foreign jurisdictions. Ongoing and future regulatory actions with respect to AI generally or AI’s use in any industry in particular may alter, perhaps to a materially adverse extent, the ability of the Firm, a Client or its portfolio companies to utilize AI in the manner is has to-date, and may have an adverse impact on the ability of CCP, a Client or its portfolio companies to continue to operate as intended. • Digital Assets. Digital assets, which are also often referred to as “crypto assets”, are assets issued and transferred using distributed ledger or blockchain technology and are digital representations of value, but do not have legal tender status. Investments in digital assets include, but are not limited to, the following risks: o Volatility: The prices of digital assets are completely derived by market forces of supply and demand, and digital assets are more volatile than traditional currencies and financial assets, such as stocks and bonds, and market movements can be difficult to predict. o Regulatory: Digital assets could be banned or highly regulated by governments, which could deter investors from buying or holding digital assets. o Cybersecurity: Digital asset exchanges and wallets have been hacked and digital assets have been stolen. This is a significant risk with which clients must be comfortable. • Cybersecurity Risk. As the use of technology has grown, there are ongoing cybersecurity risks that make the Firm susceptible to operational and financial risks associated with cybersecurity. To the extent that the Firm is subject to a cyber-attack or other unauthorized access is gained to its systems, the Firm may be subject to substantial losses in the form of theft, loss, misuse, improper release, or unauthorized access to confidential or restricted data related to the Firm and its Clients. While the Firm has developed measures that are designed to reduce the risks associated with cybersecurity, there are inherent limitations in such measures and there is no guarantee those measures will be effective, particularly because the Firm does not directly control the cybersecurity measures of service providers, financial intermediaries, and portfolio investments. • Valuation. Clients typically will invest in investments that are not readily marketable. Such investments generally will be carried at the values provided to CCP by the portfolio managers of the underlying portfolio funds pursuant to valuation procedures set forth in the organizational documents of the relevant portfolio funds. These valuation procedures may be subjective in nature, may not conform to any industry standard (if any such industry standards exist) and may not reflect actual values at which investments in portfolio funds are ultimately realized. In addition, CCP is permitted to establish the fair value of Clients’ investments pursuant to its valuation policy. There can be no assurance that the fair value of such investments will be fully realizable upon their ultimate disposition. Because of the inherent uncertainty of the estimated values of unrealized gains and losses, the fair value may differ significantly from the realized value upon liquidation of such investments, and the differences could be material which would affect 12  management fee calculations. • Additional Fees and Expenses. When investing in pooled investment vehicles such as mutual funds, ETFs, private equity and venture capital funds, Clients will bear additional expenses including management fees and in certain cases, performance allocations or carried interest charged by the vehicle’s investment adviser. The risk of owning pooled investment vehicles generally reflects the risks of owning the underlying securities or other instruments in the pooled investment vehicle. • Recycling of Capital. The Firm has the right to recall (or “recycle”) certain distributed amounts, including in respect of returned fees and expenses and returned capital, in accordance with the CCP Funds’ Governing Documents. Accordingly, during the term of a CCP Fund, an investor may be required to make capital contributions in excess of its commitment. Any such reinvestment would limit early distributions to investors, and to the extent such recalled or retained amounts are reinvested, an investor will remain subject to the investment and other risks associated with such investments. As a result, reinvestment could increase the risk of investing in a CCP Fund. Additional investments resulting from recycling have the potential to increase investment returns to investors (and reduce the effective burden of management fees assessed on the basis of commitments during a CCP Fund’s investment period) to the extent such investments are profitable. However, there can be no assurance that any such investment will have a positive return. Further, any such additional investments will have the effect of increasing the management fee borne by investors following the investment period, and as a result the Adviser may face a conflict of interest with respect to such additional investments insofar as it is incented to deploy recycled capital in additional investments when it might not otherwise have done so. • Banking Counterparty Risk: CCP relies upon third-party banks or other custodians to hold and safeguard client assets and provide credit facilities that may be used to pay fund expenses and purchase new investments. While CCP carefully selects and monitors its custodians, there is no guarantee that such custodians will not experience financial difficulties or otherwise fail, which could prevent CCP from accessing client funds, or securities. • Allocation Risk. CCP will recommend capacity constrained investment opportunities. The Access Funds (and affiliated entities) will have the opportunity to invest in at least 80% of a deal before any excess opportunity is offered to Managed Account Clients not already invested in the Access Funds. If an investment opportunity is capacity constrained, CCP will use an allocation waterfall as described in its allocation policies and procedures and allocate the opportunity in a fair and equitable manner in its good faith determination. This may eliminate or reduce the participation in such investments by certain Managed Account Clients that are not investors in the Access Funds that they would otherwise be eligible to invest in. If the Access Funds are unable to participate in an investment due to factors such as capital constraints or exposure restrictions, CCP will consider the investment for all other eligible clients and allocate the investment offering in a fair and equitable manner. For more details about the Firm’s allocated policy, see Item 12 below. Access Fund Strategy Risks • Private Equity. The Private Equity Series will invest in buyouts directly or indirectly through Portfolio Funds. Leveraged buyouts are conducted when a company borrows a significant amount of capital (from loans and bonds) to acquire another company in full or in part, typically because it believes it can extract value by holding and managing such company for a period of time and 13  exiting the company after value has been created. Debt and equity investments in companies in connection with acquisitions, buyouts and recapitalizations pose risks associated with change in control transactions. Change in control transactions often present a number of uncertainties. Companies undergoing change in control transactions often face challenges retaining key employees and maintaining relationships with customers and suppliers. If the Portfolio Investments experience one or more of these problems, the Private Equity Series may not realize the value that it expects in connection with its investments, which would likely harm the Private Equity Series and thus ultimately the Private Equity Series’ operating results and financial condition. Leveraged buyouts involve the acquisition of a company using a significant amount of financing and depend on the availability and terms of any borrowings that are required or desirable with respect to the investments. For example, from time to time the market for private equity transactions has been adversely affected by a decrease in the availability of senior or subordinated financings for transactions. A decrease in the availability of financing (or an increase in the interest cost) for leveraged transactions, whether due to adverse changes in economic or financial market conditions or a decreased appetite for risk by lenders, would impair the Private Equity Series’ ability to consummate these transactions and would adversely affect the Private Equity Series’ returns. The ability to achieve attractive rates of return from a buy-out transaction depends in part on the ability to access sufficient sources of indebtedness at attractive rates. A decrease in the availability of financing or an increase in either interest rates or risk spreads demanded by leverage providers, whether due to adverse changes in economic or financial market conditions or a decreased appetite for risk by lenders, could make it more expensive to finance investments on acquisition and throughout the term of the investments and could make it more difficult to compete for new investments with other potential buyers who have a lower cost of capital. Additionally, a decrease in the availability of financing (or an increase in the interest cost) for leveraged transactions, whether due to adverse changes in economic or financial market conditions or a decreased appetite for risk by lenders, would impair the ability to consummate these transactions and would indirectly affect returns. • Venture. The Venture Series will invest, directly or indirectly through Portfolio Funds, in newly- formed or pre-revenue portfolio companies at early points in their life cycles. These “early stage” or “seed” investments can create value inherent in particular companies or situations that can be realized only with substantial effort or expense. Often the success of the investment will depend not only on the efforts of its management team, but also upon actions of other key individuals, or extraneous factors including political or economic developments over which CCP or relevant Portfolio Manager, as applicable, has little or no control. Many early-stage companies face significant competition from other firms, both established and start-up, with greater financial resources, more extensive development, manufacturing, marketing and service capabilities and a larger number of qualified managerial and technical personnel. In all such cases, the Venture Series will be subject to the risks associated with the underlying businesses engaged in by portfolio companies. Early-stage investments are typically made in firms that are seeking to develop and bring to market new, unproven ideas or technology. This endeavor is subject to a number of risks, including, but not limited to: failure to develop or perfect the idea as planned; obsolescence; patent infringement and similar claims that prevent the idea or technology from being used or licensed; lack of market acceptance; and loss of key personnel. These companies are typically dependent on the abilities of key individuals, including founding entrepreneurs, owners or employees with critical technological skills or ownership of important patents or other intellectual property, and marketing and financial professionals. The growth and development of early-stage companies may depend on the regular injection of additional capital and financing beyond that which the Venture Series or relevant Portfolio Fund is prepared or able to invest; 14  such financing may not be available from other sources. Venture stage companies are typically thinly staffed and may lack the internal resources or procedures and controls to detect and prevent accounting errors, or more serious losses caused by the misconduct or negligence of officers, employees or agents. The very significant returns that have been earned in a small portion of venture capital investments have in large part resulted from the completion of highly successful initial public offerings or acquisitions that have permitted the venture investors to sell their equity interests at multiples of original cost. There can, of course, be no assurance that, at the time a given venture investment matures, the public securities markets will support an initial public offering to permit such returns or that the venture-backed company’s fundamentals will warrant such returns. • Real Estate. The Real Estate Series will invest in real estate, directly or indirectly through Portfolio Funds. Investments in real estate, whether direct or indirect, are generally subject to numerous risks, including the financial condition of tenants, increases in supply of competitive space, changes in local economies which reduce demand, changes in land use regulation which may facilitate increases in supply of competitive properties or render redevelopment of a property more expensive or uneconomic, changes in real property taxation, increases in operating expenses, changes in laws and regulations relating to real estate, including building, fire and life safety codes, and other factors. Certain of the Real Estate Series’ direct or indirect investments may utilize real estate debt strategies that make or acquire real estate loans, including commercial and institutional, or otherwise provide similar financing. Commercial and institutional real estate loans generally are made to the companies that own the underlying real estate and secured by the underlying property (and such loans additionally may be secured by a guarantee from the principals or owners of the company that owns the property), which often results in a lower loan-to-value than residential real estate loans or mortgages. The Firm believes that commercial and institutional real estate, as income-producing property, presents an attractive investment opportunity. Investments in real estate and real estate-related entities are subject to various risks, including, for example, adverse changes in national and international economic and geopolitical conditions, local market conditions and the financial conditions of tenants; changes in the number of buyers and sellers of properties; increases in the availability of supply of property relative to demand; changes in availability of financing; increases in interest rates, real estate tax rates, energy prices, and other operating expenses; changes in environmental laws and regulations, zoning laws and other governmental rules and policies; changes in the relative popularity of properties; risks due to dependence on cash flow; risks and operating problems arising out of the presence of certain construction materials, as well as acts of God, uninsurable losses and other factors which are beyond the control of the Real Estate Series or its Portfolio Funds. In addition, real estate is subject to long-term cyclical trends that give rise to significant volatility in real estate values. All of these factors could reduce or extinguish anticipated returns of capital to the Real Estate Series. • ENRI. The ENRI Series will invest in energy, natural resources and infrastructure, directly or indirectly through Portfolio Funds. Investments in ENRI, whether direct or indirect, are generally subject to numerous risks, including the financial condition of operating companies, volatility in crude oil, fuel, energy and commodity prices, changes in local economies which reduce demand, changes in energy regulation which may facilitate increases in competitive opportunities and render development more expensive or uneconomic, increases in operating expenses, changes in environmental, health and safety laws and regulations, permitting, including expanded laws, regulations and permit requirements, and other factors. Certain of the ENRI Series’ direct or indirect investments may involve risks such as truck accidents, equipment defects, malfunctions 15  and failures. Additionally, the operations are subject to risk associated with releases of oil and other materials. The operation of the facilities involves additional risks of fire and explosion. Any of these risks could potentially result in injury or death of employees and others, a need to shut down or reduce operation of facilities, increased operating expense and exposure to liability for pollution and other environmental damage, and property damage or destruction. If substantial liabilities in excess of any applicable insurance are incurred, the Portfolio Companies or Portfolio Funds, and the results of its operations and financial condition, could be adversely affected. Investments in ENRI and ENRI-related entities are subject to various risks, including, for example, adverse changes in national and international economic and geopolitical conditions, local market conditions and the financial conditions of operating companies; changes in availability of financing; increases in interest rates, energy prices, and other operating expenses; changes in environmental laws and regulations, including numerous regulatory, environmental, political, and legal uncertainties, the permitting process, complying with laws, unavailability or increased cost of or tariffs on materials, labor disruptions, labor availability, environmental hazards, protests, third-party legal actions, accidents, weather, as well as acts of God, uninsurable losses and other factors which are beyond the control of the ENR Series or its Portfolio Funds. In addition, energy is subject to long-term cyclical trends that give rise to significant volatility. All of these factors could reduce or extinguish anticipated returns of capital to the ENRI Series. Changes in laws, rules or regulations increasing liability for environmental conditions, restricting discharges, or otherwise affecting the use and operation, may result in significant unanticipated expenditures. The industry is subject to environmental regulation implemented or imposed by a variety of federal, state and municipal laws and regulations. Among other things, environmental legislation provides for restrictions and prohibitions on spills and discharges, as well as emissions of various substances produced in association with operations. Legislation also requires that facility sites be operated, maintained, abandoned and reclaimed in such a way that would satisfy applicable regulatory authorities. Compliance with such legislation can require significant expenditures and a breach could result in the imposition of fines and penalties, some of which could be material. Environmental legislation is evolving and may result in stricter standards and enforcement, larger fines and liability, as well as potentially increased capital expenditures and operating costs. The presence or discharge of pollutants in or into the air, soil or water may give rise to liabilities to governments and third parties and may require the Portfolio Company to incur costs to remedy such presence or discharge. • Credit. Certain of the Credit Series’ Portfolio Funds may provide credit to leveraged or mismanaged entities or may acquire non-performing loans or other distressed debt and preferred equity investments. While these investments may provide an opportunity for significant capital appreciation, they also have an enhanced degree of risk. These investments may have a greater than normal risk of future defaults, delinquencies, bankruptcies or fraud losses and may be particularly sensitive to recessions, downturns in general economic and business conditions and increased interest rates. There can be no assurance that these investments will perform, the borrowers will pay as expected, or, if defaulted, that the underlying assets will be able to be foreclosed upon and liquidated in a cost-effective manner. In addition to the risks of borrower default, the Partnership will be subject to a variety of risks in connection with such investments including risks arising from mismanagement or a decline in the value of collateral, contested foreclosures, bankruptcy of the debtor, claims of lender liability or violations of usury laws, and the imposition of common law or statutory restrictions on the Portfolio Fund’s exercise of contractual remedies for defaults on such investments. The Portfolio Funds’ investments may be in subordinated mezzanine loans and other junior participation interests and preferred equity interests in a direct or indirect property-owning entity. These investments will be subordinated to 16  the senior obligations of the property or issuer, either contractually or structurally. Greater credit risks usually are attached to these subordinated investments than to a borrower’s first mortgage or other senior obligations because, among other reasons, these investments may not be protected by financial or other covenants and may have limited liquidity. Adverse changes in a borrower’s or an issuer’s financial condition and/or in general economic conditions may impair the ability of the borrower or issuer to make payments on the subordinated securities, which are made, generally, only after payments are made on senior investments. Accordingly, such subordinated investments may go into default and suffer losses prior to the borrower’s or issuer’s senior obligations. In the event of a borrower default under a loan held by an Portfolio Fund, the Portfolio Fund may in certain cases be entitled to foreclose upon the property securing the Portfolio Fund’s loan. A foreclosure action or other lender remedies may be subject to delays and additional expenses if defenses or counterclaims are interposed and may require several years to complete. Moreover, a non-collusive, regularly conducted foreclosure sale may be challenged as a fraudulent conveyance, regardless of the parties’ intent, if a court determines that the sale was for less than fair consideration and such sale occurred when the borrower was insolvent and within one year (or within the applicable state statute of limitations if the trustee in bankruptcy elects to proceed under state fraudulent conveyance laws) of the filing of bankruptcy. Similarly, a suit against a borrower on a note may take several years and generally is a remedy alternative to foreclosure so that the Portfolio Fund may be precluded from pursuing both foreclosure and an action on a note simultaneously. Debt investments are typically secured, directly or indirectly, by either a mortgage on real property or by a pledge and assignment of a direct or indirect ownership interest in the property-owning entity. There is a risk that any such collateral may decline in value. Each loan or preferred equity investment that is secured directly or indirectly by real property also is subject to the risk of loss from casualty, natural disasters or other catastrophes, or condemnation for any other reason. • Non-U.S. Investments. Each Series may invest in securities of non-U.S. issuers. Non-U.S. investments involve certain special risks, including (i) political or economic instability; (ii) the unpredictability of international trade patterns; (iii) the possibility of non-U.S. governmental actions such as expropriation, nationalization or confiscatory taxation; (iv) the imposition or modification of currency controls; (v) price volatility; (vi) the imposition of withholding taxes on dividends, interest and gains; and (vii) different bankruptcy laws and practice. As compared to U.S. entities, non-U.S. entities generally disclose less financial and other information publicly and are subject to less stringent and less uniform accounting, auditing, and financial reporting standards. Also, it may be more difficult to obtain and enforce legal judgments against non-U.S. entities than against U.S. entities. Item 9 – Disciplinary Action There are no legal or disciplinary events that CCP or its management have been involved in. Item 10 – Other Financial Industry Activities and Affiliations As previously mentioned, CCP is affiliated with the general partners of the CCP Funds, each of which is an investment adviser subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”). These affiliated investment advisers operate as a single advisory business together with CCP and serve as general partners of the CCP Funds and share common owners, officers, partners, and employees or persons occupying similar positions. 17  CCP works in partnership with Clients to oversee and support the investment process. The Firm strategically leverages the power of a shared platform to provide cost-effective and robust offerings to its clients. Certain “anchor clients” may participate in reduced fees, minority equity in CCP, and CCP board representation. CCP believes that a collaborative and shared resources platform enables improved economics, terms, and deal-flow opportunities for all Clients. However, there may be instances where conflicts arise such as when CCP has an inherent conflict of interest to recommend the investments introduced by a Client to others. The Firm has adopted and implemented written compliance policies and procedures that are designed to mitigate conflicts of interest. In addition, where such conflicts exist, CCP seeks to further mitigate such conflict through added disclosure of potential conflicts to participating Clients. CCP principals have General Partner interests and/or hold advisory board roles with third-party private fund managers or other investment advisers. These relationships create a conflict of interest if CCP were to recommend an investment sponsored by such third-party managers to a Client because it could benefit the employee. CCP seeks to mitigate this conflict through its Investment Committee Review and Approval policies and procedures, which require 70 percent of the committee members’ approval, and upfront disclosure to Clients of any conflict or involvement with the sponsor. In addition, as discussed in Item 11 below, all employees are subject to reporting, including pre-clearance, for limited offerings and outside business activities, under CCP’s Code of Ethics policies and procedures. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading CCP has adopted a code of ethics (the “Code”) pursuant to Rule 204A-1 of the Advisers Act. The Code applies to all CCP directors, officers, employees, and any other person who provides services on behalf of CCP and is subject to its supervision and control. The Code requires that CCP’s business be conducted in accordance with the highest ethical and legal standards and focuses on the misuse of confidential information, personal securities trading and outside business activities. A copy of the Code is available to any Client or prospective Client upon request, by contacting CCP using the contact details listed above. CCP and related persons may purchase the same securities/investments for personal accounts that CCP recommends to Clients. The Firm believes that this often aligns CCP’s interests with its Clients. However, this also creates a potential conflict of interest. To mitigate this conflict, CCP has adopted policies and procedures for personal transactions and insider trading policies, which include among other things pre- clearance, reporting, and review of certain transactions. More specifically, for alternative investment recommendations, CCP’s policies and procedures require personal transactions alongside Client investments to be disclosed to each non-discretionary Managed Account Client investment approval process. For avoidance of doubt, Clients will have priority of any investments that have limited capacity as determined by the Investment Committee. For personal trades in public securities, while infrequent, CCP’s related persons will only make such purchases under the same terms as Clients after Client orders for the same securities have been completed. CCP also monitors the prices of these securities to ensure that CCP and its related persons do not benefit from trading after its Clients in the same securities. Item 12 – Brokerage Practices Ordinarily, Clients will invest with third-party managers and in portfolio funds directly and without the involvement of any financial intermediary such as a broker-dealer. As such, commissions are not ordinarily directly payable in connection with such investments. However, CCP may, on occasion, recommend the 18  purchase or sale of securities for Clients which will involve the services of an unaffiliated broker-dealer. To the limited extent that CCP engages in transactions other than investments in third-party managers and portfolio funds, CCP may recommend the financial intermediaries to be used in connection with such transactions. In making its decisions regarding the allocation of brokerage transactions, CCP seeks to obtain best execution, taking into account the following factors: (i) the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); (ii) the operational efficiency with which transactions are effected (such as prompt and accurate confirmation and delivery), taking into account the size of the order and difficulty of execution; (iii) the financial strength, integrity and stability of the broker-dealer; and (iv) the competitiveness of commission rates in comparison with other broker-dealers satisfying CCP’s other selection criteria. CCP does not receive research or other products or services from a broker-dealer based in connection with Clients’ securities transactions. Although CCP generally seeks competitive commission rates and commission equivalents, it may not necessarily pay the lowest commission or equivalent. Transactions may involve specialized services on the part of a broker-dealer, which may justify higher commissions and equivalents than would be the case for more routine services. CCP will recommend that Managed Account Clients establish a brokerage account(s) with Fidelity for custody and brokerage services. However, certain legacy clients or investments may be custodied at other custodians. CCP has evaluated Fidelity and believes that it provides Managed Account Clients with a blend of execution services, research, low commission costs, and professionalism that help the Firm meet its fiduciary obligations. CCP does not receive any economic benefits from client referrals. Although CCP may recommend that Managed Account Clients establish accounts with Fidelity, it is the client’s decision to custody assets with Fidelity. To mitigate potential conflicts, CCP conducts periodic best execution reviews that include an assessment of the pricing and services received from Fidelity. Certain Managed Account Clients who direct that CCP use particular brokers will be advised that such a direction of brokerage may result in their receiving less favorable execution in certain transactions, or in paying higher transaction costs. Although it is the Firm’s policy to always seek best execution for Client trades, in such a directed brokerage arrangement, the Firm may not be free to seek the best price and execution by placing transactions with other brokers. Accordingly, Clients should consider whether a directed brokerage arrangement may result in disadvantages to the Client that are not outweighed by the value of custodial and other services provided by that broker. CCP does not maintain a formal soft dollar arrangement with any broker-dealers. However, certain brokers do provide CCP with access to institutional services, including research, not typically available to retail customers. CCP does not feel that this creates a material conflict of interest but does periodically evaluate its Clients’ brokerage relationships for potential preferential treatment or other improprieties. For avoidance of doubt, CCP does not consider the receipt of institutional research in selecting or recommending (if applicable) broker-dealers whether it or a related person receives Client referrals from a broker-dealer or third-party. Clients’ accounts receive individualized advice and non-discretionary accounts ultimately decide their investments and timing of transactions. Nonetheless, when appropriate, CCP may, but is not obligated to, seek to aggregate multiple sale and purchase orders for shares of the same securities purchased for Clients’ portfolios if, in CCP’s reasonable judgment, such aggregation will result in an overall economic benefit to the Clients. CCP will consider when making such determination whether the Clients are benefited by relatively better purchase or sales prices, lower commission or other transaction expenses and beneficial timing of transactions or a combination of these and other factors. When aggregate sale and purchase orders occur, CCP will seek to allocate the executions among the participating Client 19  accounts in a manner believed by CCP to be fair and equitable for all accounts involved. CCP attempts to minimize trade errors by promptly reconciling confirmations with trade tickets, and by reviewing past trade errors to understand the internal control breakdown that may have caused such errors. From time to time, CCP may make an error in submitting a trade order on a Client’s behalf. When this occurs, CCP will seek to correct the error promptly in a way that mitigates losses. CCP will bear all costs associated with correcting any error. Gains associated with any trade error shall be retained by the affected client(s). The Firm will generally not net gains and losses associated with multiple errors related to separate investment decisions but gains and losses stemming from an interrelated set of errors may generally be netted. As disused in Item 8, pursuant to the Governing Documents, CCP will allocate limited capacity investments to the Access Funds before allocating them to other CCP clients. CCP maintains allocation procedures to allocate opportunities among Managed Account Clients and CCP Funds in the fairest way, taking into account the respective Clients’ best interests. For Managed Account Clients that are non-discretionary, it is then up to such Clients to decide whether to proceed with such an investment (including whether to invest in a CCP Fund), and if so, how much capital to allocate to such an investment. Due to the finite nature of most private investment opportunities, it is possible that CCP Fund and Managed Account Client demand will either exceed or fail to meet the proposed supply of any given investment opportunity. This could present investment allocation challenges, which CCP would attempt to resolve in an equitable fashion. CCP will take into consideration one or more of the following factors: (i) whether any Client helped identify or brought the opportunity to CCP’s attention and any conditions/restrictions such Client may impose upon CCP’s ability to offer the opportunity to other Clients; (ii) the ability of a Client to commit to invest in a short period of time, in light of the timing constraints applicable to such investment; (iii) the ability of a Client to commit to a significant portion of such opportunity; (iv) the size of a Client’s capital available for deployment; (v) whether and to what extent a Client has previously accepted prior direct private equity opportunities; (vii) with respect to co-investment opportunities, whether a Managed Account Client or CCP Fund has an existing account with an underlying manager or sponsor offering the co-investment; or (viii) such other factors as CCP deems relevant. Item 13 – Review of Accounts CCP formally reviews Client accounts no less than on a quarterly basis; provided that CCP may review Client accounts more frequently, particularly if there are major market or economic events, a life event for a Client or upon Client request. CCP also provides Clients with portfolio reporting through a third-party portfolio management software platform that automates data aggregations from numerous custodians and underlying sponsors. Clients are urged to compare the account statements received directly from the custodians to the reports provided by CCP. In addition, CCP furnishes each investor in the CCP Funds with: (i) annual audited financial statements prepared in accordance with U.S. generally accepted accounting principles (GAAP); and (ii) quarterly statements which include net asset value of the investor’s interest in the relevant CCP Fund. Item 14 – Client Referrals and Other Compensation CCP will not and does not intend to engage third parties for Client referrals in exchange for compensation. CCP has entered into an arrangement with a third-party placement agent (“Placement Agent”) whereby 20  CCP compensates such Placement Agent for referring investors to certain CCP Funds. A portion of the management fees received from any referred investors (“Solicitation Fee”) is shared with the Placement Agent. To the extent required by applicable law or CCP’s internal procedures, CCO will only enter into an arrangement if the investor is aware of the fee arrangement and the arrangement is in compliance with applicable rules and regulations. The Solicitation Fee is paid pursuant to a written agreement retained by CCP and the Placement Agent and material compensation terms and any other conflicts, as applicable, are disclosed to investors. Any such Placement Agents soliciting third-party investors in the U.S. will be registered as broker-dealers with the SEC and Placement Agents soliciting third-party investors outside of the U.S. will be registered with a non-U.S. regulatory body to the extent such registration is required in the applicable non-U.S. jurisdiction. Item 15 – Custody CCP may access certain Clients’ funds through its ability to debit advisory fees. In these cases, CCP is considered to have custody of Client assets under Rule 206(4)-2 under the Advisers Act (the “Custody Rule”). Account custodians send statements directly to the account owners and Clients should carefully review these statements, comparing them to any account information provided by CCP. CCP meets the Advisers Act definition of having custody over the CCP Funds. For example, the Firm or its affiliates are general partners or managers of the CCP Funds and are deemed to have custody. To comply with the Custody Rule and to provide meaningful protection to investors, the CCP Funds are subject to an annual financial statement audit by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board (“PCAOB”). The audited financial statements are prepared in accordance with generally accepted accounting principles (“GAAP”) and are distributed to investors within 180 days of a CCP Fund’s fiscal year end. CCP is deemed to have custody under the Custody Rule of certain Managed Account Client assets as a result of standing letters of authorization in place from such clients that allow CCP to direct the client’s custodian to send client funds based on the standing letters of authorization. Item 16 – Investment Discretion CCP does not have discretionary authority to manage securities accounts on behalf of Clients. While CCP makes investment recommendations to Clients, the Client makes the ultimate investment decision. CCP does have discretionary authority as General Partner to the CCP Funds. Item 17 – Voting Client Securities Clients specifically retain proxy voting authority in investment management agreements. Upon request, Client’s may consult on shareholder matters prior to voting proxies. Clients may request a copy of CCP’s proxy voting policies and procedures by contacting the Firm. While CCP, as General Partner(s) to the CCP Funds, has authority to vote proxies, in practice, this is expected to be infrequent as the underlying managers to the CCP Funds will vote such proxies. In the event that CCP receives a proxy vote or other investor consent on behalf of the Portfolio Funds, CCP has procedures to monitor for potential conflicts of interest and vote in accordance with its fiduciary duty responsibilities. 21  Item 18 – Financial Information CCP is not required to provide financial information in this Brochure because the Firm does not: (i) require or solicit prepayment of more than $1,200 in fees six months or more in advance; (ii) is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to its clients; and (iii) has not been the subject of a bankruptcy petition. Item 19 – Requirements for State-Registered Advisers Not Applicable. 22