VSR Capital Management LP ("VSR"), doing business as Lavelle Capital ("Lavelle"), is a Delaware limited partnership that was formed on August 25, 2021. VSR's general partner is VSR Capital LLC, a Delaware limited liability company that was also formed on that date. Sanjeev Rao is VSR's Managing Partner and controls VSR, Lavelle and VSR Capital LLC. As of December 31, 2023, we provide continuous management services for $267,417,882 in client assets on a discretionary basis.
Services Offered VSR offers investment management and other services. VSR also may form or manage one or more private investment funds (each, an "SPV") in the future that make specific investments on behalf of its clients and other investors in private companies, private investment funds or other types of investments.
The scope of VSR's advisory services varies depending on the specific arrangement with each client. The range of investment advisory services VSR provides includes one or more of the following (this is not an exclusive list and our arrangements differ materially among our clients).
Investment Management Services VSR generally provides investment management services on a discretionary basis. If granted discretionary authorization to make trades in client accounts, VSR effects transactions without the client's prior consent. From time-to-time VSR may engage, or recommend that clients engage, third party investment management firms ("Independent Managers") to manage assets in the form of separately managed accounts or through private investment funds. Fees for third party managers are in addition to any fees charged by VSR.
To tailor its services to the individual needs of each individually managed account, VSR:
•Manages each such account based on the client's financial situation and investment objectives and in accordance with any restrictions that the client imposes on managing the account.
•At least annually, contacts each client (either in person or by telephone) to ask about any changes in the client's financial situation or investment objectives and whether the client desires to impose or modify any restrictions on managing the account.
•Notifies each client annually in writing to contact VSR if there are any changes in the client's financial situation or investment objectives, or if the client desires to impose or modify any restrictions on managing the account.
•VSR makes itself reasonably available to clients for consultation. Other Services VSR will provide additional services from time to time as clients request. Additional services may include, but are not limited to, facilitating family governance, special projects, comprehensive risk management, overseeing

the establishment and administration of closely held client entities such as trusts and foundations, execution of planning strategies, estate pre-administration, and oversight of clients' legal and tax advisors.
4 IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•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 or provide investment advice, because the 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.
Special Purpose Vehicles ("SPVs") SPV investors generally may not withdraw any capital from an SPV, except as otherwise provided in an SPV's offering documents. For example, investors may be permitted to withdraw capital periodically from an SPV that invests in a private investment fund, if that fund itself permits withdrawals. Distributions are made at VSR's discretion and at the end of the SPV's term, as provided in the SPV's offering documents.
Non-Comprehensive List The foregoing is not a comprehensive list of services that VSR provides to clients, nor are the descriptions necessarily the only ways in which the services are provided. Clients should refer to their client and service agreements for information regarding the services applicable to them.