A. Advisory Business Bengal Asset Management, LLC (“Bengal”) is an investment adviser with its principal place of business in Burlingame, California. Bengal was formed in April 2013, and it is a limited liability company organized in the State of Delaware. Bengal registered with the United States Securities and Exchange Commission (“SEC”) in April 2018. Tora Holdings, Inc. is the principal owner of Bengal through indirect ownership. as disclosed on Bengal’s Form ADV Part 1A. B. Advisory Services Bengal provides discretionary investment advice to its proprietary pooled investment vehicles (the “Funds”). The Funds are currently organized as a master-feeder structure with each of Bengal 2 Partners, L.P., a Delaware limited partnership (the “Onshore Fund”) and Bengal 2 Investors., a Cayman Islands unit trust (the “Offshore Fund,” and together with the Onshore Fund, the “Feeder Funds”) investing all or a portion of its assets in the Bengal 2 Fund, an exempted limited company incorporated under the laws of the Cayman Islands (the “Master Fund”). Bengal also provides investment advisory services or serves as trading adviser to other pooled investment vehicles (the “Managed Accounts”, and together with the Funds, the “Clients” and each a “Client”). Bengal does not limit its investment advice to certain types of investments. Please see Item 8 of this Brochure for a more detailed description of Bengal’s investment strategy, methods of analysis, the types of securities Bengal will generally invest in, and the material risks of loss. C. Tailored Advisory Services Bengal is granted broad investment authority with respect to the management of its Funds, subject

to such investment restrictions as may be set forth in the confidential private offering memorandum, limited partnership agreement (with respect to Clients formed as Delaware limited partnerships), memorandum and articles of association (with respect to Clients formed as Cayman Islands exempted companies or segregated portfolio companies), and other governing documents of each Client (collectively, the “Governing Documents”). There is no assurance that any Client’s investment objectives will be achieved. Bengal may enter into “side letters” or similar agreements with certain investors in the Clients granting the investor specific rights, economic terms, benefits, or privileges that are not made available to other investors. Investors may not impose restrictions on investing in certain securities and/or investments and/or certain types of securities and/or investments except as agreed to in the Governing Documents or in a side letter. Bengal manages the Managed Accounts according to strategies that are similar to those of the Funds or otherwise. However, as outlined in the Managed Accounts’ Governing Documents and with future additional managed accounts, Bengal will tailor its advisory services to the investment objectives and/or restrictions established by such Managed Account. D. Wrap Fee Programs Not applicable. Bengal does not participate in wrap fee programs. E. Client Assets Managed on a Discretionary Basis As of December 31, 2021, Bengal managed approximately $ 229,381,758 in regulatory assets under management, all of which was managed on a discretionary basis. Bengal does not manage any asset on a non-discretionary basis.