QUANTOR CAPITAL LLC

Quantor Capital, LLC 4900 Woodway Drive, Suite 1200 Houston, TX 77056 Telephone: 281-565-0355 www.quantorcapital.com April 2, 2026 FORM ADV PART 2A BROCHURE This brochure provides information about the qualifications and business practices of Quantor Capital, LLC. If you have any questions about the contents of this brochure, please contact us by telephone at 281-565- 0355 or by email at ops@quantorcapital.com. 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. information about Quantor Capital, LLC is available on the SEC's website at Additional www.adviserinfo.sec.gov by searching with our firm name or our CRD # 332629. Quantor Capital, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Item 2 Material Changes Since our previous Form ADV Part 2A dated March 10, 2025, we have made the following changes: • We have added two new investment strategies available to our SMA clients: the Quantor Global Market Portfolio Strategy and the Quantor Box Spread Strategy. Descriptions of these strategies and their associated risks are contained in Item 8 of this brochure. Minimum investment requirements are described in Item 7. Future Changes From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs. 2  Item 3 Table Of Contents Item 2 Material Changes ...................................................................................................................... 2 Item 3 Table Of Contents ...................................................................................................................... 3 Item 4 Advisory Business ..................................................................................................................... 4 Item 5 Fees and Compensation ............................................................................................................. 5 Item 6 Performance-Based Fees and Side-By-Side Management ............................................................ 6 Item 7 Types of Clients ......................................................................................................................... 6 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 6 Item 9 Disciplinary Information .......................................................................................................... 19 Item 10 Other Financial Industry Activities and Affiliations .................................................................. 19 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 20 Item 12 Brokerage Practices ............................................................................................................... 21 Item 13 Review of Accounts ............................................................................................................... 22 Item 14 Client Referrals and Other Compensation ............................................................................... 22 Item 15 Custody ................................................................................................................................. 23 Item 16 Investment Discretion ............................................................................................................ 23 Item 17 Voting Client Securities .......................................................................................................... 23 Item 18 Financial Information ............................................................................................................. 23 3  Item 4 Advisory Business Description of Services and Fees Quantor Capital, LLC is a registered investment adviser primarily based in Houston, Texas. We are organized as a limited liability company under the laws of the State of Texas. We have been providing investment advisory services since 2015, have been registered with the SEC since 2024 and have previously been registered with the State of Texas. Quantor has been registered with the Commodity Futures Trading Commission (the “CFTC”) as a commodity pool operator and commodity trading advisor since 2017. Julio A. Cacho-Diaz (CRD # 6579900) is a principal owner of the Adviser. We focus on providing investors with specific investment strategies through either a fund structure or separately managed accounts (“SMAs”). We do not offer investment planning or financial planning services and instead dedicate our efforts to developing unique investment strategies incorporating our proprietary investment methodology. The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Quantor Capital, LLC and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Scope of Services We specialize in quantitative investment strategies aimed at enhancing risk and return profiles by replicating benchmarks and employing derivatives and factors. We sometimes utilize exchange-traded funds (“ETFs”) to establish positions for the Funds and SMAs we manage. Each of our Funds trades according to our quantitative investment strategies and we offer SMAs that can shape those strategies to the needs of the particular SMA client. We do not accept client restrictions on the specific securities or types of securities or other instruments that may be traded for a client’s account to the extent that any such restrictions would restrict our quantitative strategies. We serve as the investment adviser and general partner to Quantor Core Fund, LP and the Quantor Diversified Global Assets Fund LP (respectively, the “Core Fund” and the “Global Assets Fund”; each, a “Fund” and together, the “Funds”), each of which is a private pooled investment vehicle in which our clients are solicited to invest. The Funds are offered to certain sophisticated investors, who meet certain requirements under applicable state and federal securities and commodities laws. Investors to whom the Funds are offered will receive a private placement memorandum and other offering documents with information relevant to an investor making a determination to invest in one of the Funds. We also offer three trading strategies to our SMA clients. In the future, we may offer additional investment strategies, and we may modify the investment strategies that we do offer from time to time. Please refer to Item 8 for a general description of our current trading strategies and their associated significant risks. In addition to the strategies described above, we offer two new investment strategies to our SMA clients: the Global Market Portfolio Strategy and the Box Spread Strategy. The Global Market Portfolio Strategy is a passively managed, globally diversified strategy designed to replicate the composition of the global investable market across all major asset classes. The Box Spread Strategy is a professionally managed synthetic borrowing strategy that provides portfolio liquidity through the use of S&P 500 Index options without requiring clients to sell appreciated securities. Each of these strategies is described in more detail in Item 8 below. 4  We do not participate in a “wrap fee” program. Our compensation consists of an asset-based management fee as described in Item 5 below. Client Base We service both institutional and individual investors, offering customized solutions to meet their investment objectives. Assets Under Management As of December 31, 2025, we manage a total of approximately $176.4 million in assets for clients, of which approximately $93.3 million are managed in a fund structure and approximately $83.1 million are managed in an SMA structure. All of the assets we manage are managed on a discretionary basis. Item 5 Fees and Compensation Our management fee for our services is based on a percentage of your assets under our management, either through a Fund or an SMA, and ranges between 0.20% and 1.50% per year. Our fees for the Funds we manage are described in more detail in the offering materials for the respective Fund and are not negotiable. Our annual management fee is billed and payable monthly in arrears based on the value of your account or your interest in a Fund, as the case may be, on the last day of the prior month. If the investment management or Fund subscription agreement is executed at any time other than the first day of a calendar month, our fees will apply on a pro rata basis, which means that the management fee is payable in proportion to the number of days in the month for which you are a client. Our management fee for SMA clients is negotiable, depending on individual client circumstances. We will deduct our fee directly from your account or the Fund’s account if you invest in one of our Funds through the qualified custodian holding your funds and securities. We will deduct our management fee only when the following requirements are met: • You provide our firm with written authorization (including through your subscription agreement for any of our Funds in which you invest) permitting the fees to be paid directly from your account held by the qualified custodian. • The qualified custodian agrees to send you a statement, at least quarterly, indicating all amounts dispersed from your account including the amount of the management fee paid directly to our firm. In the case of an SMA, you may terminate the portfolio management agreement upon written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the portfolio management agreement, which means you will incur management fees only in proportion to the number of days in the month for which you are a client. In the case of an investment in a Fund, you may redeem your investment as described in the offering memorandum for that Fund. We encourage you to reconcile the statement(s) you receive from the qualified custodian. If you find any inconsistent information in the statement(s) you receive from the qualified custodian, please call our main office number listed on the cover page of this brochure. 5  SMA Fees For some SMAs our fee is charged in addition to advisory fees charged by the primary advisor for your account. This will result in your fees being higher than what is indicated on your agreement with your primary advisor. That means that if you are currently paying an annual fee of 1% to your primary advisor, and they hire Quantor to be your asset manager for 0.25% then you will end up paying 1.25% in total fees. You should discuss whether there will be additional fees and the nature of those fees with your primary advisor when deciding whether to hire with Quantor as an asset manager. Additional Fees and Expenses Clients may incur additional costs such as custody fees and other fund-related expenses, including brokerage fees, which will be detailed in the respective Fund offering materials or SMA agreements. Investors in our Funds will be subject to their pro rata portion of those expenses of that Fund. Those invested in the Quantor Core Fund will also be charged an additional fee to pay for the cost of Bloomberg and Mathworks platforms. Both Bloomberg and Mathworks may be used in ways that benefit other clients of Quantor who will not be charged any fees for the use of these platforms. Item 6 Performance-Based Fees and Side-By-Side Management We do not utilize performance-based fees or participate in side-by-side management. Our fees are calculated as described in Item 5 above, and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your account. Item 7 Types of Clients The minimum investment requirements vary based on the specific Fund or SMA strategy and are disclosed in each Fund’s offering documents or in the applicable SMA agreement. For our Funds, the minimum investment is $250,000. We may waive the minimum account size in our discretion. Investors in the Funds are subject to eligibility restrictions imposed under Federal securities and commodities laws, including that each investor be an “accredited investor” as defined in Regulation D under the Securities Act of 1933, as amended, and as a “qualified eligible person” as defined in Regulation 4.7 under the Commodity Exchange Act, as amended. We offer three additional investment strategies for our SMA clients: the High- Income Strategy, the Dynamic Growth Strategy, and the Global 500 Strategy. The minimum investment for the High-Income Strategy is $1,000,000; for Dynamic Growth, $100,000; and for Global 500, $1,000,000. The minimum investment for the Global Market Portfolio is $500,000; and for the Box Strategy $500,000. Each of our Funds (the Core Fund and the Global Assets Fund) utilizes our Core Strategy (described in Item 8 below). We may offer additional funds and additional investment strategies in the future. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss We employ a quantitative investment methodology for each of our trading strategies, focused on replicating benchmarks and enhancing risk and return profiles through the strategic use of derivatives and factors. This approach is grounded in rigorous research and empirical values. 6  Our strategies involve market risk, liquidity risk, and the potential for loss, as well as other significant risks described below. Clients are advised that all investments carry risk, and past performance is not indicative of future results. Investment Strategies Core Strategy The Core Strategy invests in a diversified portfolio of all the world’s asset classes, including the largest companies worldwide (over 9,000 in total, including REITS); developed and emerging markets; sovereign bonds; global corporate bonds; and commodities. The Core Strategy seeks to track the performance of all the world’s major asset classes: global equities (including REITs), global bonds (government and corporate), and commodities. Given the uncertainties of the global economy, investors need ways to maximize diversification in their portfolios, or to reduce risk in assets like equities and real estate. The Core Strategy gives investors the ability to maximize their diversification needs while maintaining equity-type returns. The Core Strategy has a growth investment structure, which seeks to increase the risk/return profile of a global market portfolio of all asset classes by 3 - 4 times. Given the current interest rate environment, The Core Strategy is positioned to take advantage of possible central bank rate cuts possibly leading to higher bond prices. The target annualized volatility is 20%. Actual volatility can range a bit higher or lower due to the frequency of rebalancing. For context, the S&P 500 has averaged roughly around 15-20% volatility during the past 30 years. High Income Strategy Given the uncertainties of the U.S. equity markets, the High-Income Strategy attempts to provide investors with a more stable return stream by capping the unlimited upside of the S&P 500 in exchange for more consistent returns each and every month. The High-Income Strategy is exposed to 2 and 3 standard deviation moves only. We are protected from any moves higher than 3 standard deviations. For example, if the S&P 500 loses 50% in a month (for example, due to war, pandemic, severe financial recession, or similar events), the High-Income Strategy would have a limited 20% loss as compared to 50% losses in equities and most other equity-type investments. The High-Income Strategy shorts put spreads on the S&P 500 index while investing in T-Bills. The strategy aims to create more consistent returns over time in exchange for limited upside. Dynamic Growth Strategy The Dynamic Growth Strategy invests in the largest U.S. publicly traded companies and looks to enhance returns during market downturns by increasing overall exposure to these companies through the use of leverage when prices are lower. It then removes leverage when the market reaches a new high. In essence, it is a “buy the dip” strategy. The Dynamic Growth Strategy enhances returns by increasing investment exposure during market downturns and reducing exposure when the market recovers. By borrowing funds to invest more as the S&P 500 drops in value, investors can buy at lower prices, potentially benefiting from rebounds. When the market recovers and reaches a new high, the Strategy reduces leverage by paying off borrowed funds, locking in gains, and returning to a safer, deleveraged position. This approach aims to capitalize on market volatility while effectively managing risk. Leveraging during market drops can lead to higher returns but 7  also increases risk and volatility. The amplified exposure means greater potential gains and losses. Global 500 Strategy The Global 500 Strategy invests in the world’s largest and most influential companies across all sectors and regions. By investing in the top 500 publicly traded companies by market capitalization, this strategy attempts to provide a diversified, low-cost, and transparent way to participate in global economic growth and offers diversification to international companies outside the USA. It does so by investing directly in the top 500 companies globally, based on their market capitalization. This direct ownership offers to investors not only financial returns but also the rights to vote in shareholder meetings, giving them a say in corporate governance. By following the Efficient Market Hypothesis, the Global 500 Strategy captures the returns of these market giants without relying on costly active management. The portfolio is rebalanced annually to maintain alignment with the global market’s evolving landscape, ensuring it continues to reflect the most significant and influential companies. Global Market Portfolio Strategy The Global Market Portfolio Strategy is a passively managed investment strategy designed to replicate the composition of the global investable market across all major asset classes. The strategy seeks to hold equities, fixed income, and commodities in approximate proportion to their global market capitalizations. As of the date of this brochure, the world's investable asset classes are approximately sized as follows: global bonds represent approximately 61% of the global investable market, global equities represent approximately 29%, and commodities represent approximately 10%. These weights fluctuate with market conditions and are reviewed and updated periodically. The strategy is implemented using approximately ten low-cost, market-capitalization-weighted index funds and exchange-traded funds. We select funds based on breadth of market exposure, tracking efficiency, and cost, with the objective of minimizing total portfolio expenses. The Global Market Portfolio Strategy does not involve individual security selection, market timing, or active sector rotation. The strategy requires periodic rebalancing to maintain target allocations. We conduct rebalancing in a manner intended to minimize unnecessary tax consequences and transaction costs, particularly in taxable accounts, although rebalancing may nonetheless generate taxable events. The Global Market Portfolio Strategy is appropriate for long-term investors seeking broad global diversification at low cost. The strategy is not designed to outperform any specific market benchmark; it seeks to approximate the return of the global investable market over time. The theoretical basis for the Global Market Portfolio Strategy is grounded in modern portfolio theory and the Capital Asset Pricing Model, which together establish that the market-capitalization-weighted portfolio of all the world's investable assets is the most broadly diversified portfolio available and that investors are compensated over time for bearing systematic market risk rather than the idiosyncratic risk associated with concentrated positions. Box Spread Strategy The Box Spread Strategy is a professionally managed synthetic borrowing strategy designed to provide clients with portfolio liquidity without requiring the sale of appreciated securities. The strategy uses combinations of S&P 500 Index ("SPX") options executed on the Chicago Board Options Exchange ("CBOE") to create a defined, fixed-payoff options structure known as a "box spread." A box spread consists of four SPX index options — a bull call spread and a bear put spread — executed at 8  two strike prices with the same expiration date. Because SPX options are European-style and cash-settled, the payoff at expiration is predetermined regardless of the level of the S&P 500 Index at any time during the life of the position. The client receives a net credit at inception representing the loan proceeds and owes a known fixed settlement amount at expiration. All positions are cleared through the Options Clearing Corporation ("OCC"). The strategy is available in two structural formats. In the variable-term structure, the box spread is executed with a short-dated expiration, typically 30 to 45 days, and is rolled into a new position at or near expiration. This structure functions as a floating-rate synthetic loan whose borrowing cost reprices periodically to prevailing short-term market conditions. In the fixed-term structure, the box spread is executed with a longer-dated expiration — such as six months, one year, or longer — locking in the borrowing rate for the full duration of the position. Clients with a defined borrowing timeline who prefer rate certainty may find the fixed-term structure more appropriate. We manage the execution, monitoring, and rolling (where applicable) of all box spread positions on behalf of clients. Positions are maintained in a portfolio margin account at the client's custodian, currently Schwab or Fidelity, and the client's existing securities portfolio serves as collateral. No assets need to be sold or transferred to establish the strategy. SPX options are classified as Section 1256 contracts under the Internal Revenue Code. As a result, gains and losses on these positions are subject to mark-to-market accounting at year-end and are characterized as 60% long-term capital gain or loss and 40% short-term capital gain or loss, regardless of the actual holding period. For clients with realized capital gains, the losses generated by box spread positions may offset those gains, potentially reducing the effective after-tax cost of borrowing. The tax advantages associated with this strategy depend on the client's individual circumstances and the availability of capital gains to offset. The information provided herein is for general informational purposes only and does not constitute tax advice. Clients should consult a qualified tax professional before implementing this strategy. Significant Risks Investing in securities and derivatives involves risk of loss that investors in the Funds or our SMA clients should be prepared to bear. The following is a description of the most significant risks involved in our investment strategies. Not all of these risks will be equally relevant to each Fund that we manage or to each individual client SMA at any given time. Each of our strategies as implemented for any particular account that we manage, whether that of a Fund or an individual client, will be subject to the trading policies and trading restrictions found in the governing documents for that Fund or the management agreement for that individual client which could limit or otherwise affect the risks of the trading strategies described here. In this section and subsequent sections, we sometimes refer to our Funds and our individual clients together as “Clients.” The offering memorandum for each of our Funds contains an extensive discussion of the principal risks attributable to an investment in that Fund. Natural and Unavoidable Events. Global markets are interconnected and events like hurricanes, floods, earthquakes, forest fires, pandemics, and similar natural disturbances, war, terrorism or threats of terrorism, civil disorder, public health crises, and similar events that can be characterized as “Acts of God” have led, and may in the future lead, to increased short-term market volatility and may have adverse long- term and wide-spread effects on the world economies and markets generally. Clients may have exposure to countries and markets impacted by such events, which could result in material losses. Use of Margin. We are authorized to use margin (i.e., borrow money) to buy securities for our Clients. 9  There are no limitations on a Client’s ability to borrow, other than those imposed by law, although the governing documents or management agreement may impose restrictions on our use of margin for that Client. Borrowing money to purchase securities provides a Client with the advantages of leverage, but exposes it to capital risk and higher current expenses. Any gain in the value of securities purchased with borrowed money or income earned from these securities that exceeds interest paid on the amount borrowed would cause the net asset value of a Client’s account to increase faster than would otherwise be the case. Conversely, any decline in the value of the securities purchased would cause the net asset value of a Client’s account to decrease faster than would otherwise be the case. Highly Leveraged Trading; Volatile Markets; “Zero-Sum” Trading. A portion of our trading for our clients involves highly leveraged investment instruments. In addition, the market prices of investment instruments are highly volatile and materially affected by unpredictable factors. While volatility creates profit potential, volatility also directly affects the risks associated with trading. The combination of these two factors (leverage and volatility) can subject the value of a client’s investment portfolio to sharp fluctuations, both positive and negative in direction. The profitability of a client’s trading depends to a significant degree on our ability to forecast price movements correctly. If we fail to predict price movements correctly, substantial losses could result in a client’s account. We establish positions for our clients using investment instruments that involve a high degree of leverage. In addition, the Funds we manage enter into borrowing arrangements for purposes of leveraging investments. The more leverage we employ for a client, the more volatile the performance of a client’s account will be. Relatively small price movements may produce a large profit or loss. Quantor, in its sole discretion, determines the degree of leverage to employ in our trading operations for our clients. Futures trading is a “zero-sum” risk transfer activity. For every gain there is an equal and offsetting loss, rather than a participation over time in general economic growth. Short Sales. For some of our strategies, such as the High Income Strategy, we may engage in “short sales” (i.e., the sale of a security that a Client does not own in the hope of purchasing the same security at a later date at a lower price) in which there is no limit to the amount of potential loss. A Client will incur a loss as a result of a short sale if the price of the security increases between the date of the short sale and the date on which the Client covers its short position (i.e., purchases the security in the open market). The Client will realize a gain if the security declines in price between these dates by an amount sufficient to offset net expenses of the short sale. A short sale involves the theoretically unlimited risk of loss occasioned by an increase in the market price of the security that is the subject of the short sale. Legislative and Regulatory Risk and Restrictions on Short Sales. Market movements with respect to securities and other investments may significantly affect the value of a Client’s investments. In addition, legislative bodies globally have introduced and enacted forms of legislation that could potentially negatively impact a Client’s operations, and the investing activities and risk profiles of a Client by placing restrictions, barriers to entry and increased burdens on us or the Client. Legislative risk is the risk that potential legislation could have an adverse impact on the operations of a Client and the markets in which that Client operates. For example, the SEC, other regulators and self-regulatory organizations and exchanges are authorized to intervene, directly and by regulation, in certain markets, and have in the past and may in the future restrict or prohibit market practices, such as the short-selling of certain stocks. The length of such prohibitions and types of investments prohibited vary from country to country and may significantly affect the value of a Client’s holdings. The restrictions and reporting requirements that are currently in place and any regulation that may be enacted, including but not limited to those related to short selling, may prevent a Client from successfully implementing its investment strategy and provide 10  transparency to other participants in the marketplace as to a Client’s positions, thereby potentially having a detrimental impact on the Client’s returns. Also, certain regulatory and legislative initiatives could result in material changes to the terms and conditions of financial instruments that could significantly impact their valuation. A Client is also subject to the risk of the failure of any exchanges on which its positions trade or of the exchanges’ clearinghouses. Over the past decade, financial regulators have increased regulation and will likely continue to increase regulation in the near future. The effect of any regulatory change on a Client could be substantial and adverse, and such regulation may impair the Client’s ability successfully to execute its investment strategies and may increase the costs of a Fund’s operations. Derivatives. For some of our strategies, such as Core and High Income, we employ derivative financial instruments (“derivatives”). Derivatives include, without limitation, futures, options, interest rate swaps, forward currency contracts and credit derivatives such as credit default swaps. Engaging in over-the- counter derivatives transactions subjects a Client to a variety of risks including (1) counterparty risk; (2) interest rate risk; (3) basis risk; (4) settlement risk; (5) legal risk; (6) operational risk; and (7) market risk. Counterparty risk is the risk that a Client’s counterparty might default on its obligation to pay or perform generally on its obligations. Interest rate risk is the general risk associated with movements in interest rates. Basis risk is the risk associated with the relative movements in two (related) rates or prices. Settlement risk is the risk that a settlement in a transfer system does not take place as expected. Legal risk is the risk that a transaction proves unenforceable in law or because it has been inadequately documented. Operational risk is the risk of unexpected losses arising from deficiencies in a firm’s management information, support and control systems and procedures. Market risk is the risk of potential adverse changes in the value of financial instruments resulting from changes in market prices, such as interest, commodity and currency rate movements. Under the authority granted to the CFTC in the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), the CFTC has determined that certain swaps and OTC derivatives (such as certain interest rate swaps and credit derivatives on broad-based indices) must be cleared at a regulated clearing house and traded on a regulated exchange. Swaps and other transactions in OTC derivatives that are not presently subject to such mandatory trading and clearing requirements, however, will be subject to the risks described herein as well as other risks, as there is no exchange market on which to close out an open position. These risks include increased difficulties in liquidating an existing position, assessing the value of a position or assessing the exposure to risk. In addition, Clients maintain trading relationships with counterparties that include domestic and foreign broker-dealers and financial institutions; these relationships could result in concentration of counterparty risk. Futures. Futures markets are highly volatile and a high degree of leverage is typical of a futures trading account. As a result, a relatively small price movement in a futures contract may result in substantial losses to the investor. The CFTC and futures exchanges have established limits referred to as “speculative position limits” on the maximum net long or net short position which any person or group of persons may hold or control in particular futures and options on futures and swaps that perform a significant price discovery function. Most commodity exchanges also limit fluctuations in futures contract prices during a single day by regulations referred to as “daily price fluctuation limits” or “daily limits.” Such regulations could prevent a Client from promptly liquidating unfavorable positions and thus subject the Fund to substantial losses. In March 2021, the CFTC adopted new rules to clarify and streamline the position limits imposed on trading. We aggregate all of the positions held by all accounts owned or controlled by Quantor and its affiliates, including the Clients’ accounts, for the purpose of determining compliance with position limits. It is possible that the trading instructions for a Client may have to be modified and that positions held by a 11  Client may have to be liquidated in order to avoid exceeding such limits. Such modification or liquidation, if required, could adversely affect the operations and profitability of a Client’s account. Options. Quantor may arrange for certain Clients to engage in the trading of fixed income options, foreign exchange options, equity options, options on volatility and commodity options, including options on physical commodities. Such trading involves risks substantially similar to those in trading margined securities or commodity futures contracts, in that options may be used for speculative purposes and may be highly leveraged. Specific market movements of the securities, commodities or futures contracts underlying an option cannot accurately be predicted. The purchaser of an option is subject to the risk of capital loss equal to the entire purchase price of the option. The writer of an option is subject to the risk of capital loss equal to the difference between the premium received for the option and the price of the security, commodity or futures contract underlying the option which the writer must purchase or deliver upon the contingent exercise of the option. Foreign Exchanges and Currency Conversions. We may invest in securities and commodity contracts on exchanges located outside the United States. Trading on such exchanges is not regulated by any U.S. regulator and may, therefore, be subject to more risks than trading on U.S. exchanges. Other considerations include exchange control regulations, reduced and less reliable information about issuers and markets, different accounting standards, illiquidity of securities and markets, higher brokerage commissions and custody fees, local economic or political instability and greater market risk in general. In addition, dividends paid by non-U.S. issuers may be subject to withholding and other non-U.S. taxes that may decrease the net return on these investments. Moreover, unless a Client hedges itself against fluctuations in the exchange rates between its home currency and the currencies in which trading is done on such exchanges, any potential profits could be eliminated, and losses could be incurred as a result of adverse changes in exchange rates. Finally, a Client may have to convert assets in its accounts into other currencies in order to meet margin requirements. In such cases, Quantor will not attempt to hedge the Client against fluctuations in the exchange rates. Such hedging may or may not be successful. As a result of fluctuations in exchange rates and hedging transactions, the performance of Clients’ accounts may vary from one another. Equity Risk. Quantor is authorized to trade in cash equities for the Funds. Unlike debt securities, equity securities represent an ownership interest in an issuer rather than a right to receive a specified future payment. This makes equity securities more sensitive than debt securities to changes in an issuer’s earnings and overall financial condition; as a result, equity securities are generally more volatile than debt securities. Equity securities may lose value as a result of changes relating to the issuers of those securities, such as management performance, financial leverage, or changes in the actual or anticipated earnings of a company, or as a result of actual or perceived market conditions that are not specific to an issuer. Even when the securities markets are generally performing strongly, there can be no assurance that equity securities held by an investor will increase in value. Because the rights of all of an issuer’s creditors are senior to those of holders of equity securities, shareholders are least likely to receive any value if an issuer files for bankruptcy. High Yield Securities. Quantor may, for a Client’s account, purchase “high yield” bonds and preferred securities that are rated in the lower rating categories by the various credit rating agencies (or in comparable nonrated securities). Securities in the lower rating categories are subject to greater risk of loss of principal and interest than higher-rated securities and are generally considered to be predominately speculative with respect to the issuers’ capacity to pay interest and repay principal. They are also generally considered to be subject to greater risk than securities with higher ratings in the case of deterioration of general economic conditions. Because investors generally perceive that there are 12  greater risks associated with the lower-rated securities, the yields and prices of such securities tend to fluctuate more than those of higher-rated securities. The market for lower-rated securities is thinner and less active than that for higher-rated securities, which can adversely affect the prices at which these securities can be sold. In addition, adverse publicity and investor perceptions about lower-rated securities, whether or not based on fundamental analysis, may contribute to a decrease in the value and liquidity of such lower-rated securities. Prime Brokers. Securities and cash held in customers’ accounts at prime brokers that are U.S. registered broker-dealers will not be available to the non-customer creditors of the prime broker. Nonetheless, if the prime broker becomes insolvent and there were not sufficient customer assets to pay all customers in full, then the securities and cash held in customers’ accounts at the prime broker would be distributed pro rata among customers. Different results may occur in the event that a U.S. prime broker sub-custodies its assets with a foreign sub-custodian outside the United States. Different results, including loss of U. S. regulatory protections, also may occur in the event that the customer of a U. S. prime broker permitted the prime broker to (i) re-hypothecate or lend its assets, or (ii) transfer its assets to a prime broker or other entity that is not a U.S. registered broker-dealer. If assets are held by a prime broker that is not a U.S. registered broker-dealer, the U.S. regulatory protections do not apply. In certain jurisdictions, with authority from the customer, such assets may be borrowed, lent or otherwise used by the prime broker for its own purposes. In the event of the insolvency of the prime broker, customers may rank as unsecured creditors and may not be able to recover equivalent assets in full. Investment in Emerging Countries and Markets. Investment in non-U. S. securities and markets, particularly those of companies in emerging countries and markets, may be subject to different and greater risks than purely U. S. investment because of a variety of factors, including currency controls and the fluctuation of currency exchange rates, changes in governmental administration or economic or monetary policy in the United States and abroad or changed circumstances in dealings between nations. Other factors may include high rates of inflation and the potential for substantial depreciation in the value of local currencies. In fact, substantial short-term volatility in these markets and significant declines are not uncommon. Restrictions on currency trading that may be imposed by emerging countries will have an adverse effect on the value of the securities of companies that trade or operate in such countries. In many cases, the economies of emerging countries are heavily dependent upon international trade and, accordingly, have been and are likely to continue to be adversely affected by trade barriers, exchange controls, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which emerging countries trade. These economies also may have been and may continue to be adversely affected by economic conditions in the countries with which they trade. There may be less publicly available information about non-U.S. issuers than about U. S. issuers, and certain non-U.S. issuers are not subject to uniform accounting, auditing and financial reporting standards and requirements comparable to those for U. S. issuers. Securities of some non-U.S. issuers are less liquid and more volatile than securities of comparable U. S. issuers and non-U. S. brokerage commissions are generally higher than in the United States. Non-U. S. securities markets may also be less liquid and more volatile than those in the United States. In addition, currencies of some non-U.S. countries are also less liquid and more volatile than currencies of larger nations. There also is generally less governmental supervision and regulation of non-U.S. securities markets, brokers and securities issuers than in the United States. Illiquidity of Securities and Markets in Emerging Countries. Securities in which a Client invests may include those that are either listed on one or more stock exchanges or traded over the counter, as well as those 13  that are not publicly traded. In the case of securities that are listed or traded on organized exchanges or other markets, there may be less market liquidity than would typically be available for companies of comparable size that are traded in the securities markets of developed countries. This reduced liquidity may diminish the Client’s ability to act on investment information and research in both buying and selling securities. In addition, it may limit the size of investments and increase the cost of transacting in such markets. Securities that are not publicly traded may be resold in privately negotiated transactions, but they may be less liquid than publicly-traded securities and the prices realized upon their resale may be less than those that could be realized if the securities were publicly-traded. Furthermore, companies whose securities are not publicly-traded may be in early stages of development, which may involve substantial business and financial risks. Such companies may not be subject to the disclosure and other investor protection requirements that may apply in the case of publicly-traded securities. If such securities are required to be registered under the securities laws of one or more jurisdictions before being sold, the expenses of such registration may be chargeable against the proceeds of the sale. Political and Legal Factors. We may invest according to our strategies in emerging countries where there is a high potential return on invested capital but also a high degree of either political or economic risk, or both, or where existing regulations may impede repatriation of investment capital or earnings. In such cases, the potential return may be offset, or more than offset, as a result of adverse political or other developments. In that regard, it is generally the case that investments in any emerging country could be affected by factors not present in the United States, including nationalization, expropriation without just compensation, exchange controls, confiscatory taxation, political changes, governmental regulation, social, political or diplomatic instability (including military or other internal political coups, insurrections and wars) and potential difficulties in enforcing contractual obligations. In addition, the legal systems in emerging countries are often not as sophisticated as those in the United States or other developed nations and it may be difficult to predict with any degree of assurance the resolution of legal questions presented in adjudications or other governmental proceedings. In addition, the availability of judicial and other remedies may, as a practical matter as well as a legal matter, be far more restricted than in the United States or other developed countries. These factors may adversely affect the companies in which a Client invests as well as the enforceability of the rights of the Client as a security holder in such companies. Investment and Repatriation Restrictions. Some emerging countries have laws and regulations that preclude direct foreign investment in the securities of their companies. In certain emerging countries, however, indirect foreign investment in the securities of companies listed and traded on the stock exchanges in those countries is permitted through investment funds that have been specifically authorized. A Client may invest in these investment funds and, in such a case, the Client will bear its proportionate share of the expenses of the investment fund. In addition, in some emerging countries prior governmental approval for foreign investments may be required under certain circumstances. Moreover, the extent of foreign investment in domestic companies may be limited. Foreign ownership limitations also may be imposed by the charters of individual companies in emerging countries to prevent, among other concerns, violation of foreign investment limitations. Repatriation of investment income, capital and the proceeds of sales by foreign investors may require governmental registration or approval in some emerging countries. The Client could be adversely affected 14  by delays in or a refusal to grant any required governmental registration or approval for such repatriation or by withholding taxes imposed by emerging countries on interest or dividends paid on securities purchased by the Fund or gains from the disposition of such securities. Cyber Risks. Quantor, like most other market participants, relies on its computer systems and the internet to conduct its trading, financial and business operations and activities. Those operations and activities may be the subject of malicious attack or Quantor’s computer systems or computer networks in which Quantor participates may fail and Quantor’s data and computer systems (as well as the personal data of Quantor’s clients and investors) may be lost, stolen, or otherwise damaged or compromised. Quantor is subject to stringent regulation of its digital operations and its use of investors’ personal data and mandated protection of that data by various government authorities in the US and the European Union (including the European Union’s General Data Protection Regulation with respect to personal data obtained by Quantor from limited partners or potential investors domiciled in the European Union), and Quantor deploys significant security systems and resources to safeguard the data of investors and the Quantor’s own data and computer systems. However, there can be no assurance that Quantor, despite its substantial efforts, will not be the victim of an attack or of a system failure (whether in the Quantor’s own systems, those of its service providers, or the computer networks through which Quantor conducts its business) in the future. In the event of a data breach affecting clients’ personal data, Quantor will notify its clients as required in applicable regulations. Frequent Trading and Execution Risk. We may engage in strategies involving the rapid execution of trades, a high volume of trades, complex trades, difficult to execute trades, use of negotiated terms with counterparties such as in the use of derivatives and the execution of trades involving less common or novel instruments. In each case, we seek best execution and have trained our execution and operational staff devoted to executing, settling and clearing such trades. However, in light of the high volumes, complexity and global diversity involved, some slippage, errors and miscommunications with brokers and counterparties are inevitable and may result in losses to a Client. Such losses may be caused by the Client’s brokers and counterparties or by Quantor or by that of a combination of the broker or counterparty and Quantor. We may attempt to recover losses from brokers or counterparties but are not required to do so. Quantor is not liable to a Client for losses caused by brokers or counterparties, by its own negligence or by that of a combination of the broker or counterparty and itself. Quantor will be liable to a Client for acts that constitute willful malfeasance or gross negligence, in the event that Quantor failed to act in good faith in the reasonable belief that such actions were in, or not opposed to, the best interests of the Client or if Quantor is liable to the Client for damages under the securities laws of the United States or of an individual state. Interests in our Funds are only available for subscription by investors who understand that they and the Fund are waiving potential claims for damages arising from the operation of the Fund, including damages resulting from Quantor’s own negligence, and who expect some execution losses to the Fund, and who acknowledge such matters in the Funds’ governing documents. Limitation on Liability and Indemnification. Under the exculpatory provisions of the investment management agreements with our Clients, Quantor, its principals and affiliates, and their partners, directors, officers and employees are not liable to (i) an individual client or (ii) a Fund or any of its shareholders, members or limited partners, except by reason of acts or omissions constituting willful malfeasance, gross negligence, and for not having acted in good faith in the reasonable belief that such actions were in, or not opposed to, the best interests of the individual client or the Fund, as the case may be. Each of our Clients has agreed to indemnify Quantor, its principals and affiliates, and their partners, directors, officers and employees against any loss, liability, damage, cost or expense resulting from any 15  claim, action or proceeding relating to the business or activities undertaken by them on behalf of the Client or actions taken or omitted to be taken by Client in its capacity as investment manager for the Client, provided that the conduct of such person did not constitute willful malfeasance or gross negligence and that the person acted in good faith and in a manner reasonably believed to be in, or not opposed to, the best interests of the Client. Management of Proprietary and Other Customer Accounts by Quantor and Its Affiliates. Please see Item 11 of this brochure for a discussion of certain conflicts of interest associated with our management of proprietary accounts. Our customer accounts consist of those of our Funds as well as those of our individual clients. The investment methods and strategies that we use in managing various customer accounts as well as our proprietary accounts may be the same or different. When we use the same strategy for multiple customer accounts, such accounts may nonetheless yield different results based on factors including the timing of trades and size of accounts, as well as hedging or portfolio adjustment trading or both undertaken in one account and not the other. Quantor may engage in proprietary trading that involves taking positions in any market (including single stock futures or cash equities) that are opposite those taken for clients trading the Diversified Program; Quantor instructs the executing broker that such proprietary trades are executed only after the positions are established for client accounts and so Quantor believes that such proprietary trades do not have a material effect on trades initiated in the Diversified Program for Quantor’s clients. Substantial Fees and Expenses. Each Fund’s operating expenses, which include, among other items, trading and investment expenses, costs related to principal transactions, interest expense, dividend expense and dividend withholding, as well as administrative, legal and accounting expenses, (and which expenses may also be borne by our individual clients in some circumstances) are expected to equal a significant percentage of a Client’s assets under management with us each year. These expenses are in addition to the Management Fees charged to a Fund Client, and the amounts of each expense are reflected in the Fund’s annual report available from the Fund’s administrator or in an individual client’s annual account statement. T Business Continuity Plan. As required by SEC regulations, Quantor maintains and regularly updates its Business Continuity Plan, which is intended to enable Quantor to continue operating in the event of an unforeseen disruption to its activities resulting from a wide variety of events, including not limited to failure or computer systems (whether Quantor’s own or those systems on which it relies), natural or political disasters, civil disorder, war, pandemics, market impairment or failure or other similar events. Despite our best continuing efforts, our Business Continuity Plan may not address the particular galaxy of circumstances in a situation that may arise, and our normal operation may be disrupted as a result. Our Other Activities. We currently manage and intend to manage accounts for other Clients (both Funds and individuals) in the future. Orders for various accounts may occur contemporaneously. We are not subject to any specific limit as to the number of accounts that we may manage. The performance of a Client’s investments could be adversely affected by the manner in which particular orders are entered for all such accounts; although we use our reasonable best efforts to allocate orders among all of our Clients on an equitable basis over the long-term. Taxes. Each Fund’s governing documents contain disclosure of various tax considerations associated with an investment in that Fund. These disclosures are for the purpose of providing general information only, are not intended to be a substitute for the advice of an investor’s own tax and legal advisors, and should not be interpreted as legal or tax advice. Investors in our Funds are advised to consult their own tax advisors and counsel with respect to their particular tax position before investing in a Fund. No advance 16  tax ruling has been sought in connection with the operations of the Funds or the investment in interests in the Funds and there is no assurance that United States tax authorities will agree with the statements described in the Funds’ private offering documents. In selecting investments for the Funds, consideration may be given to an instrument’s tax treatment under U.S. law. We may establish positions in exchange traded instruments, rather than derivative contracts on the same underlying security or other asset, in order to minimize the potential tax liability of a Fund’s U.S. taxable investors, a majority of which may be principals, officers or employees of Quantor. While consideration may be given to the U. S. tax consequences of various investments, we will not establish a position unless we determine that establishing the position is in the overall best interests of the relevant Fund. Foreign Taxes. A Fund may invest in securities of entities engaged in business, organized or resident in foreign countries. Many foreign sovereigns impose a withholding tax on payments of interest, dividends and capital gains to investors residing in other countries and not otherwise subject to tax by that sovereign. Accounting for Uncertainty in Income Taxes. The Financial Accounting Standards Board (“FASB”) has released Accounting Standard Codification 740 (“ASC 740”), which prescribes the minimum recognition threshold that a tax position is required to meet before being recognized in an entity’s financial statements. It also provides guidance on de-recognition, measurement, classification and interest and penalties with respect to tax positions. A prospective investor in one of our Funds should be aware that, among other things, ASC 740 could have a material adverse effect on the periodic calculations of the Net Asset Value of the Funds, including reducing the Net Asset Value of the Funds to reflect reserves for income taxes that may be payable in respect of then current or prior periods or both by a Fund. This could cause benefits or detriments to certain shareholders, depending upon the timing of their entry to, and exit from, a Fund. Global Market Portfolio Strategy — Passive Strategy and Tracking Risk. The Global Market Portfolio Strategy does not employ active management and will not respond to market conditions in a manner designed to mitigate losses. The portfolio will decline in value along with the markets it tracks during periods of broad market stress. Because the strategy is implemented through index funds and ETFs rather than direct holdings in every global security, tracking error may cause performance to deviate from the theoretical weights of the global market. Fund expenses, trading costs, and index construction methodology may contribute to this deviation. Global Market Portfolio Strategy — International, Currency, and Emerging Market Risk. A significant portion of the strategy's allocation is invested in non-U.S. markets, including emerging markets. As described in the existing risk disclosures in this Item 8, such investments may be subject to political instability, currency risk, less developed regulatory frameworks, and greater volatility than U.S. investments. Changes in exchange rates between foreign currencies and the U.S. dollar may adversely affect the value of the portfolio. Global Market Portfolio Strategy — Fixed Income and Commodity Risk. The strategy's fixed income allocation is subject to interest rate risk, credit risk, and duration risk. Rising interest rates may materially reduce the value of bond holdings. The strategy's commodity allocation is subject to supply and demand dynamics, geopolitical events, weather, and regulatory changes. Commodity prices can be highly volatile and their inclusion in the portfolio may increase overall portfolio volatility during certain market environments. Box Spread Strategy — Margin Risk. Box spread positions are maintained in a portfolio margin account. If the market value of the client's collateral securities declines, the client may be subject to a margin call requiring the deposit of additional assets or the forced liquidation of securities at potentially unfavorable 17  prices. This risk is similar to the margin risk described elsewhere in this Item 8. Clients should maintain adequate margin cushion at all times. We monitor margin levels but cannot guarantee that margin calls will be avoided. Box Spread Strategy — Options Complexity and Execution Risk. Box spreads are complex options structures. Although the payoff of a properly executed SPX box spread is theoretically fixed at expiration, errors in execution or operational failures could produce unintended outcomes. Clients should understand the mechanics of SPX options before entering into this strategy. As described in this Item 8 generally, we seek best execution but some slippage, errors, and miscommunications with brokers and counterparties are possible and may result in losses. Box Spread Strategy — Rate Variability. In the variable-term structure, the borrowing rate resets at each roll to prevailing market rates. If short-term rates rise materially, the cost of borrowing will increase accordingly. There is no cap on the rate at which a position may be rolled. Clients who are sensitive to rate changes may prefer the fixed-term structure. Box Spread Strategy — Liquidity Risk. While SPX options are among the most liquid options contracts available, market conditions may affect our ability to execute or roll box spread positions at anticipated rates. Widening bid-ask spreads in the options market may increase the effective borrowing cost relative to indicative rates at the time of the client's decision to enter into the strategy. Box Spread Strategy — Tax Risk. The potential tax advantages described in this brochure assume the client has sufficient realized or recognizable capital gains to offset the Section 1256 losses generated by the box spread positions. Clients without capital gains to offset will still incur the full pre-tax borrowing cost without the benefit of an offsetting tax reduction. Tax laws are subject to change, and there is no guarantee that the current tax treatment of Section 1256 contracts will remain in effect. We do not provide tax advice. Clients should consult a qualified tax professional before implementing this strategy. Box Spread Strategy — Account Eligibility Risk. Execution of box spreads requires an options-approved brokerage account with portfolio margin. If a client ceases to meet the custodian's eligibility requirements for portfolio margin, existing positions may need to be liquidated, potentially at an unfavorable time. Clients should be aware of and maintain compliance with their custodian's portfolio margin eligibility requirements. Box Spread Strategy — Minimum Position Size. Each SPX box spread has a notional settlement value of approximately $100,000 per 1,000-point spread. Clients with borrowing needs smaller than this threshold may have limited flexibility in position sizing, which may affect the efficiency and practicality of the strategy. Risk Management Quantor’s risk management is broken down into several categories. In terms of market risk, Quantor’s allocation to different markets and sectors is inherently geared towards overall risk mitigation of the positions. Quantor measures market risk by individual market, by sector, and by the total portfolio. We generally limit the risk associated with each position as a percentage of the total amount that we could lose relative to the entire portfolio at the point of initiation. We size our individual positions relative to recent market volatility. The higher the volatility, the lower the number of contracts needed to satisfy the targeted risk position for the market. We recognize that correlations often exist between groups of similar markets (sectors) and further limit exposure to these groups of markets. Furthermore, we continually back test our systems and models to check their validity to present market conditions. We have technology that ensures that accurate market data are fed into the 18  systems. Our databases have data validation checks and cleaning methodologies in place that limit data errors to the bare minimum. At the operational level, Quantor maintains staff to support the back and middle office and administrative functions and also uses a third party back-office service provider that together are responsible for reviewing all data received from the brokers or futures commission merchants (“FCMs”) to ensure all trades have been recorded properly, reconciling any discrepancies noted, and resolving all issues with clients and brokers and FCMs. This service provider and Quantor’s back office staff also prepare the monthly fund accounting for accounts and the monthly statements for the investors. The back office also reviews performance at the account level in case there are any notable outliers and to confirm that like accounts have similar performance. Item 9 Disciplinary Information We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our advisory business or the integrity of our management. We do not have any required disclosures under this item. Item 10 Other Financial Industry Activities and Affiliations Other Registrations We are registered as a commodity pool operator and commodity trading advisor (NFA ID#0503326) with the Commodity Futures Trading Commission and are a member of the National Futures Association, and Julio A. Cacho Diaz, Juan Carlos Herrera, Coleman B. Conkling, and Charles Chanaratsopon are registered with the CFTC as our principals. Inscription Capital Quantor serves as a subadvisor to certain client accounts managed by Inscription Capital, LLC (“Inscription”). Julio Cacho Diaz, Juan Carlos Herrera, and Cole Conkling all serve as investment adviser representatives, at Inscription, in addition to being managing directors of Quantor Capital. These individuals and other employees of the firm maintain personal investment accounts at Inscription. This creates an economic incentive to recommend that clients of Inscription hire Quantor as sub-advisors for the account. In some cases, the IAR may have discretionary authority to hire Quantor without asking clients permission first. Advisors employed at Quantor generally receive a higher portion of advisory fees collected for Quantor, compared to those collected for Inscription. Quantor’s IAR ensure that all recommendations are made consistently with our fiduciary obligations to our clients whether made in their capacity as and IAR of Quantor or Inscription. Additionally, as detailed in Item 5, Quantor Capital’s fees are charged in addition to those charged by Inscription. This presents a conflict of interest, since those individuals who are IARs at both Inscription and Quantor make more in total fees when they have you use Quantor as an asset manager. This conflict of interest is mitigated by disclosing the extra fees in writing to you. Several employees of Quantor Capital also keep their personal investment accounts at Inscription. This creates a conflict of interest as these employees may be incentivized to trade their own accounts or clients of Inscription first. Quantor Capital has policies and procedures in place to mitigate this conflict. 19  Grupo Bursatil Mexicano Quantor’s Managing Member, Co-Chief Executive Officer, and President Juan Carlos Herrera, devotes a substantial majority of his professional time to activities as Chief Wealth Officer of Grupo Bursatil Mexicano (“GBM”), a Mexican financial group providing brokerage, asset management, private banking, investment banking, and investment management services. There is a conflict of interest since Mr. Herrera has less time to devote to clients of Quantor Capital than an another advisor might. Additionally, there is a conflict of interest given the potential overlap between the firms. Quantor mitigates these conflicts by annually reviewing arrangements Mr. Herrera has with GBM and ensuring that no trading or client information is passed between the two firms. There is currently no formal agreement nor any shared clients between the two firms. Private Investment Companies We serve as the investment adviser and general partner to Quantor Core Fund, LP and the Quantor Diversified Global Assets Fund LP, each of which is a private pooled investment vehicle in which our clients are solicited to invest. The Funds are offered to certain sophisticated investors, who meet certain requirements under applicable state and federal securities and commodities laws. Investors to whom the Funds are offered will receive a private placement memorandum and other offering documents. You should refer to the offering documents for a complete description of the fees, investment objectives, risks and other relevant information associated with investing in each of the Funds. Persons affiliated with our firm may have made an investment in the Funds and have an incentive to recommend the Funds over other investments because we receive fees from the Funds. All of our recommendations are made consistently with our fiduciary obligations to our clients and investors in our Funds. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for persons associated with our firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm are expected to adhere strictly to these guidelines. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this brochure. Participation or Interest in Client Transactions As described in Item 10 above, we serve as the general partner to the Funds, each of which is a private pooled investment vehicle in which you may be solicited to invest. Our firm, or persons associated with our firm, may have significant investments in the Fund. If you are an investor in the Fund, refer to the Fund's offering documents for detailed disclosures regarding the Fund. Additionally, individuals associated with our firm may buy or sell - for their personal account(s) - investment products identical to 20  those purchased by the Fund. This practice may create a conflict of interest because we have the ability to trade ahead of the Fund and potentially receive more favorable prices than the Fund will receive. To address this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over the Fund in the purchase or sale of securities. Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in which you are already invested. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To address this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Item 12 Brokerage Practices When recommending or selecting broker-dealers for our clients, we primarily consider a broker’s ability to provide best execution, access to markets, and the quality of a broker’s research services. We seek to obtain the best available prices for our clients’ transactions. We also consider the quality of the services provided by the recommended broker-dealers, custodians and FCMs, including the value of the firms' reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In recognition of the value of the services the recommended broker-dealers, custodians and FCMs provide, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Research and Other Soft Dollar Benefits and Brokerage for Client Referrals We do not receive “soft dollar” benefits or participate in “soft dollar” arrangements with any of our broker-dealers. We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. We engage in order aggregation for our clients’ trades where we have the opportunity to do so. Directed Brokerage We routinely recommend that you direct our firm to execute transactions through particular broker- dealers and/or custodians. As such, we may be unable to achieve the most favorable execution of your transactions and you may pay higher brokerage commissions than you might otherwise pay through another broker-dealer that offers the same types of services. Not all advisers require their clients to direct brokerage. In limited circumstances, and at our discretion, some clients may instruct our firm to use one or more particular brokers for the transactions in their accounts. If you choose to direct our firm to use a particular broker, you should understand that this might prevent our firm from aggregating trades with other client accounts or from effectively negotiating brokerage commissions on your behalf. This practice may also prevent our firm from obtaining favorable net price and execution. Thus, when directing brokerage business, you should consider whether the commission expenses, execution, clearance, and settlement capabilities that you will obtain through your broker are adequately favorable in comparison to those that we would otherwise obtain for you. Order Aggregation and Block Trades 21  Transactions for each client generally will be effected independently, unless we decide to purchase or sell the same securities for several clients at approximately the same time. We may, but are not obligated to, combine, or aggregate, multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as "block trading"). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion regarding factual and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs on any given day. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. Item 13 Review of Accounts We monitor and review each Fund’s account on a daily basis for out-trades, performance review relative to other similarly-traded accounts and other accounting practices. Our account review and risk management process features the allocation to different markets and sectors and is inherently geared toward overall risk mitigation of positions. We • • measure market risk by individual security, by sector, and by the total portfolio. We generally limit the risk associated with each position as a percentage of the total amount that we could lose relative to the entire portfolio at the point of initiation; recognize that correlations often exist between groups of similar markets (sectors) and further limit exposure to these groups of markets; • • back test our systems and models to check their validity to present market conditions; • utilize technology that ensures that accurate market data are fed into the systems. Databases have data validation checks and cleaning methodologies in place that limit data errors to the bare minimum; and review all data received from brokers to ensure all trades have been recorded properly, reconciling any discrepancies noted, and resolving all issues between a Fund and its brokers. Our COO, working with the Funds’ administrator, prepares monthly fund accounting for accounts and quarterly account statements that are distributed to our clients by the administrator. Our COO reviews performance at the account level in case there are any notable outliers and to confirm that like accounts have similar performance. We utilize outside legal counsel, where needed, to help with some of our middle office and administrative activities. Each of our Funds’ investors receives quarterly written reports on his or her accounts that contain information about the Fund’s net asset value, and the Fund’s investors receive an annual report of the Fund’s financial condition, which is audited by an independent public accounting firm. Investors in our Funds also receive periodic written communications from us discussing our investment views and strategies and the performance of the Funds. Item 14 Client Referrals and Other Compensation We do not receive any compensation or economic benefits from any third party in connection with providing investment advice to you. Any arrangements we have with third parties for client referrals will 22  be fully-disclosed to our clients. Where those arrangements exist, they are structured to avoid conflicts of interest. Item 15 Custody Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our management fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. You should reconcile the information reflected on the custodian's statement. If you have a question regarding your account statement, or if you did not receive a statement from your custodian, please contact us directly at the telephone number on the cover page of this brochure. Private Investment Companies As noted in Item 10 above, we serve as the general partner of the Funds, each of which is a private pooled investment vehicle in which our clients are solicited to invest. In our capacity as general partner to each of the Funds, we are imputed to have “custody” over each Fund’s assets by applicable SEC regulations. Also as required by SEC regulations, each Fund’s assets are physically held by a “qualified custodian” as described above and we provide each investor in each Fund with audited annual financial statements prepared by an independent public accountant licensed by the Public Company Accounting Oversight Board . If you are a Fund investor and have questions regarding the financial statements or if you did not receive a copy, contact us directly at the telephone number on the cover page of this brochure. Item 16 Investment Discretion We typically exercise full investment discretion over our client accounts and we make all investment decisions for those accounts in accordance with our investment strategy as agreed with an SMA client or as described in the offering materials for our Funds. With respect to SMA clients, we may agree to accept reasonable restrictions on our discretion, subject to the terms of the individual investment management agreement with that client on a case-by-case basis. Item 17 Voting Client Securities We have established proxy voting policies for the securities held in your account that we control. Those policies prioritize the best financial interests of our clients. We vote proxies in accordance with our internal guidelines intended to maximize the value of client investments. Please contact us at the telephone number on the cover of this brochure to obtain information about how we have voted proxies for your account or to obtain a copy of our proxy voting policies and procedures. We do not accept instructions from clients as to how to vote in a particular proxy solicitation. Item 18 Financial Information Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. We have not filed a bankruptcy petition at any time in the past ten years. 23