RGNCM is a quantitative trading advisor that employs a short-term, primarily contrarian strategy to trade the world’s largest and most liquid markets. For trading programs offered to investors, trading is done in equity, fixed income, foreign exchange and commodity markets, subject to the particular objectives of the trading program. Founded in 1993, RGNCM’s scientific trading philosophy takes inspiration from the field of computational neuroscience. Our investment objective is to provide above-average, risk-adjusted returns on capital in all market environments, but particularly in choppy, volatile and emotional market conditions. RGNCM has been registered with the SEC as an investment adviser since 2006, has been registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity pool operator and commodity trading advisor since 1993, and is a member of the National Futures Association (“NFA”). Such registrations and memberships do not imply that the SEC, CFTC or the NFA have endorsed RGNCM qualifications to provide advisory services. Roy G. Niederhoffer is the founder, sole owner and sole director of RGNCM. As of December 31, 2023, RGNCM managed approximately $810 million. Regulatory Assets Under Management, as defined by the SEC, was approximately $36,500,000 on December 31, 2023. All assets are managed on a discretionary basis. RGNCM serves as the investment manager to several private funds, and as the trading advisor or sub- adviser to several separately managed accounts (each, an “SMA”). As further discussed in Item 8, RGNCM currently has three trading programs: (1) Macro Diversified Program; (2) Smart Alpha Program; and (3) Emerald Program. These trading programs have different investment objectives. The Macro Diversified Program’s investment objective is to achieve attractive risk-adjusted returns while also providing low or negative correlation to traditional and alternative investments. RGNCM seeks to attain this objective via trading in cash and spot currencies, futures contracts, forward contracts, swaps, equities, options on the foregoing and other derivative and financial instruments on regulated and over- the-counter United States and non-United States exchanges and markets. The Smart Alpha Program’s investment objectives are (1) stable absolute returns regardless of market environment, with zero correlation to fixed income, equities and hedge funds; and (2) consistent downside protection for portfolios containing global bonds, global equities, hedge funds, and commodity trading advisors. RGNCM seeks to attain these objectives via trading in cash and spot currencies, futures contracts, forward contracts and swaps, options on the foregoing and other derivative and financial instruments on regulated and over-the-counter United States and non-United States exchanges and markets. The Emerald Program’s investment objectives and strategies are a hybrid of the Macro Diversified Program and the Smart Alpha Program. This program was specially designed for the owner of one managed account. RGNCM places no permanent limits on the exchanges or markets on which it trades, but concentrates its trading in markets that offer high liquidity. Due to the differing strategies of the Macro Diversified Program, the Smart Alpha Program and the Emerald Program, the Smart Alpha Program and Emerald Program trade fewer instruments than the Macro Diversified

Program. RGNCM provides investment advisory services to the following three private funds that employ the Smart Alpha Program:
• Roy G. Niederhoffer Smart Alpha Fund 2X, Ltd. (“Smart Alpha Fund Offshore”);
• Roy G. Niederhoffer Smart Alpha Fund 2X (Onshore) L.P. (“Smart Alpha Fund Onshore”);
• Roy G. Niederhoffer Smart Alpha Master Fund, Ltd. (“Smart Alpha Master Fund”); and Another private fund for which RGNCM provided investment advisory services, and that employed the Smart Alpha Program, was KLS Niederhoffer Smart Alpha UCITS Fund, a subfund of Kepler Liquid Strategies ICAV (“Smart Alpha UCIT Fund”). Effective March 2024, the Smart Alpha UCIT Fund stopped trading and all investors were redeemed (the “UCIT Closure”). Consequently, any discussion in this brochure of the period beginning after the UCIT Closure will not include the Smart Alpha UCITS Fund. RGNCM provides investment advisory services to the following three private funds that employ the Macro Diversified Program:
• R. G. Niederhoffer Macro Diversified Fund, Ltd. (“Macro Diversified Fund Offshore”);
• R. G. Niederhoffer Macro Diversified L.P. (“Macro Diversified Fund Onshore”); and
• Roy G. Niederhoffer Macro Diversified Master Fund, Ltd. (“Macro Diversified Master Fund”). RGNCM also provides investment advisory services to SMAs. The six SMAs as of December 31, 2023 are: (1) an SMA via a Bermuda entity established by a European Union financial institution, which trades the Macro Diversified Program; (2) an SMA established by a European Union financial institution, which trades the Macro Diversified Program; (3) an SMA via a Cayman Islands entity established by a European Union financial institution, which trades the Smart Alpha Program; (4) an SMA established by a United States based hedge fund, which trades the Smart Alpha Program; (5) an SMA established by a United States based registered investment company, which trades the Emerald Program; and (6) an SMA established by a United States based registered investment company, which trades the Smart Alpha Program. In this Brochure, the following definitions will be used:
• “Feeder Funds” means the Smart Alpha Fund Offshore, Smart Alpha Fund Onshore, Macro Diversified Fund Offshore and Macro Diversified Fund Onshore;
• “Master Funds” means Smart Alpha Master Fund and Macro Diversified Master Fund;
• “Funds” means the Feeder Funds and Master Funds;
• “Funds/SMAs” means the Funds and the SMAs; and
• “Advisory Clients” means the Funds, the SMAs, the investors in the Funds and the investors in the SMAs. Each Feeder Fund invests substantially all of its assets into a corresponding Master Fund. Specifically, Smart Alpha Fund Offshore and Smart Alpha Fund Onshore invest in Smart Alpha Master Fund, and Macro Diversified Fund Offshore and Macro Diversified Fund Onshore invest in Macro Diversified Master Fund. Other than the Profit Allocation shares in the Master Funds held by RGNCM, the only investors in the Master Funds are the Feeder Funds. The SMAs do not invest their assets into a Master Fund; rather, they make their investments directly. The Funds and SMAs utilize the trading programs of RGNCM. While RGNCM does not tailor its advisory services for the individual needs of investors in the Funds, it does tailor advisory services for the needs of the owners of the SMAs. RGNCM does not participate in any wrap fee programs.