A. Description of the Advisory Firm VELA Investment Management, LLC (hereinafter “VELA”) is a Limited Liability Company organized in the State of Delaware. The firm was formed in November 2019. VELA has 15 owners with Roderick Hadley Dillon, Jr. as its principal owner. VELA became a SEC registered investment adviser in June 2020. Jason will provide updated language. B. Types of Advisory Services Portfolio Management Services VELA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. VELA creates an Investment Policy Statement for each client, which outlines the client’s current situation to aid in the selection of portfolio securities to meet a client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring VELA evaluates the current investments of each client. VELA will request discretionary authority from clients to select securities and execute securities transactions without permission from the client prior to each transaction. VELA manages the investment strategies described in Item 8.a. These investment strategies may be part of a client’s investment program or may be a clients only investment. If a client decides to utilize one or more of VELA’s separately managed account strategies, the client’s Investment Policy Statement will include the description of the strategies chosen. VELA makes investment decisions in accordance with the fiduciary duties owed to its clients and without consideration of VELA’s economic, investment or other financial interests. To meet its fiduciary obligations, VELA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, VELA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is VELA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. We are fiduciaries under the Investment Advisers Act of 1940 when providing advisory services to you. In addition, when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title 1 of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We are required to act in your best interest and not put our interests ahead of yours. In addition, we must:
• Meet a professional standard of care when making investment recommendations
• Never put our financial interests ahead of yours when making recommendations
• Avoid misleading statements about conflicts of interest, fees and investments
• Follow policies and procedures designed to ensure that

we give advice to you that is in your best interest
• Charge no more than is reasonable for our services
• Give you basic information about conflicts of interest We benefit financially from the rollover of your assets from a retirement account to an account that we manage because your assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Services Limited to Specific Types of Investments VELA generally limits its investment advice to mutual funds, including its own open-end mutual fund family, the VELA Funds, fixed income securities, equities, options, derivatives and ETFs. However, VELA may also use other securities to help diversify a client portfolio when applicable. Stifel, Nicolaus & Company, Incorporated Connect Program VELA is an investment adviser in the Stifel, Nicolaus & Company, Incorporated (Stifel)’s Connect program. A Stifel Financial Advisor provides its clients with investment advisory services on a non-discretionary basis and assists its clients in the selection of an investment management, such as VELA, to manage the client’s Connect account on a discretionary basis, in accordance with the terms of a separate investment advisory agreement between the client and VELA. In each case, the Stifel Financial Advisor will assist the client in establishing and maintaining a relationship with VELA. In the Connect Program VELA will have trading authority over your account. For Client’s in the Connect Program, Stifel will provide you with disclosures regarding the Connect Program. You should carefully review those disclosures. Connect Program clients to whom VELA provides discretionary investment management services have a minimum account size of $250,000 and an annual investment management fee of .50%. C. Client Tailored Services and Client Imposed Restrictions VELA will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be carried out by VELA on behalf of the client. VELA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. VELA allows clients to impose reasonable restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. VELA is an investment manager for the Stifel Connect program. E. Assets Under Management VELA’s regulatory assets under management, as defined in Form ADV Part 1, are as follows: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 397,813,678 $ 78,325 12/31/23 VELA’s assets under management include mutual funds, separately managed accounts and wealth management accounts as of 12/31/23 are $ 391,221,4480.