Description of Advisory Services: Spouting Rock Asset Management, LLC (“SRAM”) is based in Bryn Mawr, Pennsylvania and became registered as an investment adviser with the Commonwealth of Pennsylvania in September 2009. In November 2014, we filed for registration as an investment adviser with the SEC. SRAM is organized as a limited liability company under the laws of the State of Delaware. We are principally owned by Spouting Rock Financial Partners, LLC (“SRFP”). We are a boutique investment management firm currently offering professional portfolio management to individuals and institutions desiring investments in liquid alternative products. The advisory services offered by Spouting Rock generally include portfolio management and related investment management services. SRAM is the filing adviser for the umbrella registration of SRAM and SR Alternative Credit, LLC (the “Relying Adviser”). The Relying Adviser shares advisory and management personnel with SRAM, all of which are subject to SRAM’s compliance policies and procedures. SRAM conducts a single advisory business with the Relying Adviser. SRAM and the Relying Adviser are sometimes referred to herein collectively as “SRAM”, “we” or “us.” Please refer to the Schedule R - Relying Advisers section of the SRAM’s Form ADV Part 1A for additional information. Portfolio Management Services We offer discretionary and non-discretionary portfolio management services. We primarily manage client portfolios with full investment discretion with consideration of individual investors’ needs when recommending an investment strategy. If we are retained for portfolio management services, we will conduct a process to determine the investment objectives and other relevant information. We may also customize a portfolio based upon clients’ investment objectives. Alternative Return and Alternative Return & Income Strategies. Spouting Rock offers two investment strategies which focus on liquid alternative solutions for clients. These strategies focus on selecting and investing in open-ended ‘40 Act mutual funds that employ alternative investing strategies or focus on alternative asset classes. The strategies are thoughtfully curated portfolios implemented to meet investment objectives, are actively managed and diversified, consisting of roughly 8 to 12 mutual funds at any given time. Alternative Return seeks to achieve capital preservation by emphasizing absolute (positive) returns and low volatility across all market cycles. Alternative Return & Income seeks to diversify fixed income allocations by emphasizing yield and total returns with low volatility across all market cycles, while maintaining low effective duration (interest rate) risk. Small Cap Growth Strategy. The strategy takes a fundamental research-based approach, seeking to construct a focused yet diversified portfolio of smaller capitalization equites believed to be future compounders, companies undergoing demonstrated business improvements that should benefit from higher compound earnings growth and stock price appreciation. The strategy seeks produce a return in excess of the Bloomberg 2000 Growth benchmark over a market cycle. SMID Growth-Concentrated Strategy. The strategy takes a fundamental research-based approach, seeking to construct a concentrated yet diversified portfolio of smaller and mid- capitalization equites believed to be future compounders, companies undergoing demonstrated business improvements that should benefit from higher compound earnings growth and stock price appreciation. The strategy seeks produce a return in excess of the Bloomberg 2500 Growth benchmark over a market cycle. SMID Core Strategy. The strategy takes a fundamental research-based approach, seeking to construct a diversified portfolio of smaller and mid-capitalization equites believed to benefit from improved business fundamentals and stock price appreciation. The strategy seeks produce a return in excess of the Bloomberg 2500 benchmark over a market cycle. Global Small Cap. The strategy invests in emerging global leaders that are early in their growth cycle and provide the potential to generate strong returns over a long-term time horizon. the strategy utilizes a bottom-up approach to identify global small cap companies that we believe are at an inflection point and have compelling sustainable growth and return potential. We focus our research efforts on identifying opportunities among emerging and re- emerging small-cap growth companies globally. An experienced team and in-depth research allow us to focus on long-term outperformance and construct a portfolio of innovative global small cap companies. The strategy seeks produce a return in excess of the MSCI World Small Cap benchmark over a market cycle. Opportunistic All Cap Strategy. The strategy takes a fundamental research-based approach, seeking to construct a diversified portfolio of small, mid and large capitalization equites believed to benefit from improved business fundamentals and stock price appreciation. The strategy invests long in US equities mostly with the ability to short and use options. The goal is to construct a portfolio that will result in a strong risk-adjusted return profile. The strategy seeks produce a return in excess of the Bloomberg 3000 benchmark over a market cycle. SRAM currently provides discretionary investment advisory services related to the Opportunistic All Cap Strategy, including but not limited to managing and directing the investment and reinvestment of assets for the following Cayman master-feeder private investment fund:
• Victor Equity Fund, Ltd, a Cayman Islands company (Master)
• Victor Equity Fund, LP, a Delaware limited partnership (Feeder) SRAM neither tailors its advisory services to the individual needs of investors nor accepts investor-imposed investment restrictions with respect to the Private Funds above. When deemed appropriate for a large or strategic investor in the Opportunistic All Cap Strategy, SRAM may establish a Separately Managed Account (“SMA”) that may tailor its investment objectives to those of the specific investor and/or be subject to different terms and/or fees than those of the Funds. Such investment objectives, fee arrangements and terms are individually negotiated, and it should be noted that any such SMA relationships are generally subject to account minimums. Kingsland Long-Term Growth Strategy. The strategy is an asset allocation that is appropriate for those clients who seek long term capital appreciation and have a ten year or longer time horizon. This strategy is focused on companies that are early in their life cycle and whose growth characteristics offer appreciation potential that is much greater than most US equities. In identifying candidates, we seek companies that have scalable business models, management teams that empower employees through the development of strong corporate cultures, are leaders in their industry or are rapidly taking market share and are experiencing strong demand that leads to double digit revenue growth in all but the most severe economic environments. The strategy seeks produce a return in excess of the Bloomberg 2000 Growth benchmark over a market cycle. Kingsland Sustainable Growth Strategy. The strategy is an asset allocation that is appropriate for those clients that seek long term capital appreciation and have a 5 year or longer time horizon. This strategy focuses on companies that are experiencing strong growth but are more mature than those companies in the Kingsland Long Term Growth Strategy. In identifying candidates, we seek companies that have scalable business models, management teams that empower employees through the development of strong corporate cultures, are leaders in their industry or are rapidly taking market share and are experiencing strong demand that leads to revenue growth significantly greater than the economy as a whole. The strategy seeks produce a return in excess of the Bloomberg 3000 Growth benchmark over a market cycle. Kingsland Comprehensive Growth Strategy. The strategy is an asset allocation that is appropriate for those clients that seek long term capital appreciation and have a 7 year or longer time horizon. This strategy focuses on companies that are experiencing strong growth that is more sustainable than those companies in the Kingsland Long-Term Growth Strategy but are earlier in their life cycle than many securities in the Kingsland Sustainable Growth Strategy. We view this strategy as a combination of both the Kingsland Long-Term Growth Strategy and the Kingsland Sustainable Growth Strategy that does not include the earliest stage (that are present in the Long-Term Growth Strategy) or latest stage companies (that are present in the Sustainable Growth Strategy) in their life cycle. In identifying candidates, we seek companies that have scalable business models, management teams that empower employees through the development of strong corporate cultures, are leaders in their industry or are rapidly taking market share and are experiencing strong demand that leads to revenue growth significantly greater than the economy as a whole. The strategy seeks to produce returns in in excess of the Bloomberg 3000 Growth benchmark over a market cycle. Kingsland Balanced Strategy. The strategy is an asset allocation that is appropriate for those clients that seek both long term capital appreciation and have a need for current income. This strategy focuses on companies that are more mature in their lifecycle but are continuing to grow. The bond portion of the portfolio is designed to provide current income from mature corporations. In identifying candidates, we seek companies that have scalable business models, management teams that empower employees through the development of strong corporate cultures, are leaders in their industry or are rapidly taking market share and are experiencing solid demand that leads to revenue growth at least as strong as the economy as a whole. The strategy seeks to produce returns in in excess 50%/50% S&P 500 Index/Barclays US Aggregate Bond Index benchmark over a

market cycle. Longmark Strategy. The strategy takes a fundamental research-based approach to investing long in US equities with the ability to short and use options. The goal is to construct a portfolio with exposure to a concentrated yet diversified mix of equities that will result in a strong risk- adjusted return profile. The strategy seeks to achieve capital preservation by emphasizing security selection and excess returns with moderate beta/correlation and lower volatility than its benchmark (MSCI World NR Index) across all market cycles. SRAM currently provides discretionary investment advisory services related to the Longmark Strategy, including managing and directing the investment and reinvestment of assets for the following private investment fund:
• Longmark Partners, LP, a Delaware limited partnership SRAM neither tailors its advisory services to the individual needs of investors nor accepts investor-imposed investment restrictions with respect to the Private Funds above. When deemed appropriate for a large or strategic investor in the Longmark Strategy, SRAM may establish a Separately Managed Account (“SMA”) that may tailor its investment objectives to those of the specific investor and/or be subject to different terms and/or fees than those of the Funds. Such investment objectives, fee arrangements and terms are individually negotiated, and it should be noted that any such SMA relationships are generally subject to account minimums. Longfield Strategy. The strategy is comprised of 20 US equities derived from 13F analysis of what are believed to be high quality, alpha producing investment managers. The goal is to construct a portfolio with exposure to a concentrated yet diversified mix of equities that will result in a strong risk-adjusted return profile. The strategy seeks to produce excess returns to its benchmark (S&P 500 TR Index) over a market cycle. Stewart Asset Management (“SAM”) Strategy. The SAM Strategy, offered through SRAM, offers ongoing portfolio management services that includes but are not limited to:
• Investment strategy • Asset selection
• Asset allocation • Regular portfolio monitoring
• Risk tolerance The SAM Strategy seeks to allocate investment opportunities and transactions it identifies as being appropriate and prudent that might have a limited supply, among clients on a fair and equitable basis over time. The SAM Strategy generally limits its investment advice to U.S. securities. SAM may use other securities as well for diversification purposes as needed. SR Alternative Credit (“SRAC”) Strategy. This is a private credit strategy that focuses on generating yield for investors by executing senior secured asset-based lending transactions focused on deals from $10mm to $50mm with a maturity of 1-4 years. SRAC provides discretionary investment advisory services including, but not limited to, managing and directing the investment and reinvestment of assets for the following four (4) private investment funds:
• PFM Credit Recovery Fund I, LLC, a Delaware limited liability company (“PFM Credit Fund”)
• OHP II LP, a Delaware limited partnership
• OHP Ltd, a Cayman Islands company
• OHPC LP, a Delaware limited partnership Each of the private investment funds listed above may be referred to individually in this Brochure as a “Credit Fund” and together as the “Credit Funds.” The terms for each Credit Fund are disclosed in detail the relevant Credit Fund’s offering documents that are provided to prospective investors prior to investment. SRAC acts as the investment manager and/or managing member to each of the Credit Funds. SRAC primarily invests its clients’ assets directly, or indirectly through a participations (as applicable), in senior secured term loans, senior secured revolving loans, direct purchases of assets or other hybrid structures that generally replicate the risk and return profile of senior secured loans. SRAC may also invest in mezzanine or other non-senior debt structures. Additionally, SRAC may invest in indices and exchange-traded funds (“ETFs”) for hedging purposes and may also opportunistically invest in public equity securities, such as business development companies (“BDCs”), from time to time that, in the investment manager’s view, provide exposure to credit markets. When deemed appropriate SRAC may establish a Separately Managed Account (“SMA”) that may tailor its investment objectives to those of the specific investor and/or be subject to different terms and/or fees than those of the Funds. Such investment objectives, fee arrangements and terms are individually negotiated, and it should be noted that any such SMA relationships are generally subject to higher minimums. Where appropriate, the General Partner and the Investment Manager or their respective affiliates may offer co-investment opportunities to one or more (but not necessarily all) of the Investors or other persons, and the General Partner, the Investment Manager and their respective affiliates and persons or entities that they advise or sponsor also may participate in such co-investments (a “Co-Investment Opportunity”). In the event of a Co-Investment Opportunity: (i) no Investor will be required to participate in such Co-Investment Opportunity unless it so chooses and (ii) the sponsor of the relevant Co-Investment Opportunity will, in its sole discretion, determine the terms of such participation and whether, and in what amounts, an Investor or third-party will be permitted to participate in such Co-Investment Opportunity. Any Co-Investment Opportunity will not be part of the Fund and the terms of any Co- Investment Opportunity will not be governed by the terms of the Partnership Agreement. For the avoidance of doubt, any fees received by the General Partner, the Investment Manager or their respective affiliates will not offset or reduce the amount of the Management Fees otherwise payable to the Investment Manager. Highwood Strategy. This strategy is comprised of a diversified hedge fund portfolio that invests in other commingled limited partnerships (hedge funds). The goal is to construct a portfolio with a diverse mix of long/short equity strategies, resulting in a strong risk-adjusted return profile. The strategy seeks to achieve capital preservation by emphasizing risk- adjusted alpha generation, low beta/correlation and low volatility across all market cycles. SRAM currently provides discretionary investment advisory services related to the Highwood Strategy, including managing and directing the investment and reinvestment of assets for the following private investment fund:
• Highwood Capital Partners, LP, a Delaware limited partnership SRAM neither tailors its advisory services to the individual needs of investors nor accepts investor-imposed investment restrictions with respect to the Private Fund above. When deemed appropriate for a large or strategic investor in the Highwood Strategy, SRAM may establish a Separately Managed Account (“SMA”) that may tailor its investment objectives to those of the specific investor and/or be subject to different terms and/or fees than those of the Funds. Such investment objectives, fee arrangements and terms are individually negotiated, and it should be noted that any such SMA relationships are generally subject to significant account minimums. Pooled Investment Vehicles As of the date of this Brochure, SRAM provides investment advisory services, pursuant to the investment guidelines as set forth in the applicable offering memoranda of several private commingled funds, the “Private Funds”. The Private Funds include:
• Cayman Master-Feeder Funds:
• Victor Equity Fund LP, a Delaware limited partnership (“Victor LP”) and
• Victor Equity Fund Ltd. A Cayman Islands company (“Victor Ltd”)
• Spouting Rock I LP, Series A (Hazeltree Fund Service, Inc.) a Delaware limited partnership (“SR I, A”)
• Spouting Rock I LP, Series B, (Qarma Systemic Emerging Markets Equities Fund LP) a Delaware limited partnership (“SR I, B”)
• Longmark Partners LP, a Delaware limited partnership (“Longmark”)
• SRAC “Credit Funds”
• Highwood Capital Partners LP, a Delaware limited partnership (“Highwood”) SRAM utilizes sub-advisor Qarma Technology, Inc. for Private Funds, Qarma Systemic Emerging Markets Equities Fund LP, a Delaware limited partnership (“Qarma EM”) and Qarma USA Large Cap Fund, Ltd., a Cayman Islands Company (“Qarma LC”). Spouting Rock GP, LLC, a Delaware limited liability company (the “General Partner”) is the sole general partner to SR I, A, SR I B and Longmark Private Funds. SRAM is the sole General Partner of the Victor LP and serves as the investment manager to Highwood Capital Partners, LP. Highwood Capital Advisors LLC is the General Partner for Highwood Capital Partners, LP. SRAM may provide investment advisory services to other private funds in the future. SRAM tailors its Portfolio Management Services to the specific needs of each particular Private Fund by complying with the terms of each Private Fund’s governing documents or other limitations which the Private Fund may request. For more information, about our investment strategies, please see Item 8 (Methods of Analysis, Investment Strategies and Risks of Loss). Subject to an investment advisory agreement (“Advisory Agreement”) with us, a client may impose reasonable restrictions on the securities or types of securities held in the client’s account. Due to the potential conflict of interest with respect to the Fund, these restrictions may include a prohibition against investing in the Fund for a client’s account. The investment strategies discussed in this brochure may not be appropriate for all clients. We aim to only recommend those strategies that are believed to be suitable for a particular client. Wrap Fee Program We are neither a portfolio manager to nor a sponsor of any wrap fee program. Assets Under Management Our discretionary assets under management as of December 31, 2022 are approximately $410,637,422 and our non-discretionary assets under management are $44,335,397. Our assets under advisement are $500,225,322.