A. Description of the Firm ClearAlpha is a Delaware limited partnership that was formed on June 15, 2021. ClearAlpha GP LLC is the general partner of ClearAlpha. Brian Hurst, Sean Terretta, and Elisha Wiesel serve as the managing members of ClearAlpha GP LLC, and Brian Hurst is the principal owner of ClearAlpha. B. Description of Advisory Services ClearAlpha serves as the investment adviser and provides discretionary investment advisory services to private pooled investment vehicles, of which interests are offered to investors on a private placement basis. Additionally, ClearAlpha provides non-discretionary investment advisory services to institutional investors. In particular, ClearAlpha serves as the investment adviser and provides discretionary investment advisory services to Niche Plus Master Fund Ltd (the “Master Fund”), Niche Plus Onshore Fund LP (the “Onshore Feeder”) and Niche Plus Offshore Fund Ltd (the “Offshore Feeder” and, collectively with the Master Fund and the Onshore Feeder, the “Fund”). The Fund is organized as a master- feeder structure with the Onshore Feeder and the Offshore Feeder each investing all of their investable assets, other than assets invested in a cash account of each feeder Fund established for a specific share class (Class M), in the Master Fund. The assets of the cash accounts are held in cash and/or money market-equivalent investments and may be invested in U.S. treasury bills. The Fund may also make investments, enter into transactions, or effect one or more of its investment strategies directly or indirectly through any subsidiary, special purpose vehicle, alternative investment vehicle, holding company, or other similar entity formed in respect of the Fund which enables the Fund to carry out its purpose (each, a “fund vehicle”) from time to time. Accordingly, references to the term Fund as used in this Brochure in the context of the Fund’s portfolio, investment program, or related risks should be understood to mean the Fund and/or any other fund vehicle through which the Fund makes investments, enters into transactions, or effects its investment strategies. The Fund is managed according to the investment objectives and guidelines outlined in its governing documents. Broadly, ClearAlpha aims to achieve its overall investment objective of achieving capital appreciation of its assets at attractive risk-adjusted rates of return by allocating the Fund’s capital across a diversified range of investment strategies. These strategies are managed by various investment teams, including “Internal Investment

Teams” (personnel employed by ClearAlpha) and “External Investment Teams” (personnel employed by unaffiliated third-party sub-advisors). Together, these teams are collectively referred to as “Investment Teams”. A more detailed description of the Fund’s investment program can be found in Item 8 of this brochure and in the Fund’s governing documents. ClearAlpha may, at times, provide non-discretionary investment advice to institutional investors, including Fund investors and/or prospective investors. Non-discretionary investment advisory services will vary from client to client based on their individual needs and may include providing customized asset allocation (strategic and tactical) advice, active risk budgeting, asset class portfolio structuring, risk assessments, educational programs, and investment recommendations. As used throughout, the term “client” refers to the Fund and non-discretionary investment advisory clients. The descriptions set forth in this Brochure are of the specific advisory services that ClearAlpha provides to the Fund, the investment strategies we pursue, and the investments we make, on behalf of the Fund. It also includes a description of the non-discretionary investment advisory services that we may provide to institutional investors. The descriptions should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy, and make any investment (including those not described in this Brochure) which we consider appropriate, subject to the investment objectives and guidelines of each client. The investment strategies we pursue are speculative and entail substantial risks. Investors in the Fund should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of the Fund will be achieved. C. Availability of Customized Services for Individual Clients ClearAlpha’s advisory services emphasize the customization of solutions for each client. ClearAlpha does not provide customized investment advice to underlying investors in the Fund except to the extent that they are also non-discretionary investment advisory clients of ClearAlpha. D. Wrap Fee Programs ClearAlpha does not currently participate in any Wrap Fee Program. E. Assets Under Management As of December 31, 2023, ClearAlpha has $965 million in discretionary regulatory assets under management and $0 in non-discretionary assets under management.