Item 4A Standard General was founded in 2007 and became registered with the SEC as an investment adviser on December 9, 2009. Standard General provides discretionary investment advisory services including, but not limited to, managing and directing the investment and reinvestment of assets for pooled investment vehicles organized as private investment funds and single-investor funds (each a “Fund” and together the “Funds”). An affiliate of Standard General, Standard General GP LLC, is the general partner or manager (the “General Partner”) of most of the Funds that are organized as limited partnerships or limited liability companies. In addition, SG Special Situations GP, LLC, an affiliate of the General Partner, serves as the general partner of a closed-ended Fund (“SGSSGP LLC”). Standard General’s principal owner is Standard General Holdings L.P., an entity that is controlled by Soohyung Kim (as Chief Executive Officer) and owned (indirectly) by Soohyung Kim and other Standard General partners, employees and former employees. Standard General provides discretionary investment advisory services including, but not limited to, managing and directing the investment and reinvestment of assets for the Funds. Standard General seeks to maximize returns by opportunistically employing a variety of strategies within the broad securities markets. The Funds have extensive flexibility in the instruments in which they may invest and the investment techniques they may use to achieve the investment objective. Such investments may involve a significant degree of risk of capital loss. A key principle of Standard General’s investment program is a reliance on intensive primary research and fundamental analysis. In reviewing each potential investment or position, Standard General adheres to a disciplined assessment process. This rigorous process includes both quantitative and qualitative analysis of a company’s business, industry trends, competitive position and financial performance, among other items, as well as the valuation of its assets, an evaluation of the company’s management team, and an assessment of any legal or other contingent risks. Standard General approaches investing in public securities of companies as would a potential owner buying a private business. In Standard General’s approach, companies are reduced down to streams of cash flows, and these cash flows are valued

by their prospects and volatility. Once the valuation analysis is complete, Standard General looks broadly across capital structures (broadly defined as secured loans, bonds and equities) as well as across both public and private companies to consider the market signals from each distinct asset class. Standard General looks for securities that are absolutely or relatively mis-priced by the market and looks to construct positions that can profit as these valuation discrepancies normalize. Standard General’s investment philosophy also emphasizes event discipline. Standard General looks to position the Funds in those discrepancies that it expects to close out within a year due to identified catalysts. While many of these catalysts are passive (events that Standard General cannot impact), Standard General is always looking for opportunities to work with other securities holders or companies themselves to create catalysts that will correct those mis-pricings. Standard General does not generally tailor its advisory services to the individual needs of investors in the Funds (“Investors”), nor does it accept Investor-imposed investment restrictions. As noted above, when deemed appropriate for a large or strategic investor, Standard General may create a Fund based on the preferences of a single investor or may manage a separately managed account. Standard General, in its sole discretion, may enter (and has previously entered) into agreements (“side letters”) with one or more Investors (including but not limited to large, strategic and/or affiliated Investors), concerning an Investor’s investment in one or more of the Funds, whereby such Investors are provided with terms and conditions that are more favorable than those applicable to the other Investors in the Funds. Side letters may address various terms, including but not limited to fees, reporting, lock-ups, capacity and/or withdrawal/redemption rights. The other Investors generally have no recourse against the Funds or Standard General in the event that certain Investors receive additional or different rights, terms or other benefits as a result of such side letters. In addition, future Investors may receive more favorable terms after the date of this Brochure. Standard General does not participate in wrap fee programs. As of December 31, 2023, Standard General manages $710,540,000 of client gross assets on a discretionary basis.