ACR Alpine Capital Research, LLC is an SEC-registered investment adviser with its principal place of business located in St. Louis, Missouri. ACR is a fundamental valuation-based asset management firm which provides portfolio management services to institutional investors and intermediaries. ACR began conducting business in 1999 under the name Alpine Investment Management, LLC (“AIM”). ACR is wholly owned by ACR Alpine Capital Research, LP (“ACR LP”), whose general partner is ACR Alpine Capital GP, LLC (“ACR GP”). AIM is the principal shareholder (i.e., controlling 25% or more of the company) of ACR GP. Alpine Holdings Corp is the sole owner of AIM and a trust controlled by Nicholas Tompras is Alpine Holdings Corp’s principal shareholder (i.e., controlling 25% or more of the company). Mr. Tompras also serves as both Chief Executive Officer and Chief Investment Officer for ACR. Institutional Account Management ACR offers investment advisory services in the form of discretionary portfolio management to institutional investors (“Institutional Account Management”), either directly, through sub-advisory arrangements or through commingled funds managed by ACR; frequently, institutional investors are advised by an investment consultant. Each institutional investor has the opportunity to select, typically in consultation with its investment consultant, one or more of ACR’s investment strategies: either ACR Equity Quality Return (“EQR”) or ACR Equity Partners(“Equity Partners”), long-only, multi-capitalization equity strategies, and/or one of the commingled funds managed by ACR (either one or more mutual funds or limited partnerships, as described below). Separately Managed Accounts (SMA) SMA Advisory and SMA Sub-Advisory ACR provides investment advisory services in the form of discretionary portfolio management to certain clients, either directly (“SMA Advisory” clients) or through sub-advisory arrangements on behalf of clients (“SMA Sub-Advisory” clients). Each SMA Advisory or SMA Sub-Advisory client has the opportunity to select, typically in consultation with his/her/its investment consultant or financial adviser, one or more of ACR’s investment strategies or products. For separately managed accounts, ACR offers EQR and Equity Partners strategies. SMA Advisory and SMA Sub-Advisory accounts for both strategies are managed in accordance with each client’s investment objectives and financial situation. In that respect, SMA Advisory and SMA Sub- Advisory clients may impose reasonable restrictions on the management of their accounts. Wrap Programs ACR provides investment sub-advisory services in the form of discretionary portfolio management to separately managed account programs sponsored by various broker-dealers or registered investment advisers (each, the “Sponsor”) in both “dual contract” and “single contract” wrap fee programs under which an all-inclusive (or “wrap”) fee is paid by the client to the Sponsor and the Sponsor in turn pays ACR a portion of the fee collected from the wrap fee client (“Wrap Programs”). Under ACR’s Wrap Program services, clients are provided access to ACR’s EQR and Equity Partners strategies and ACR will generally execute trades on the client’s behalf through the Sponsor. There are instances, however, where executing trades away from the Sponsor are more advantageous to the Wrap Program client. In these instances, the Wrap Program client will pay commissions and other charges for trade execution purposes. See Item 12 – Brokerage Practices for additional details. Custody, tax reporting, client reporting, trading commissions, performance monitoring and other services are typically provided by each Sponsor. ACR contracts directly with each Sponsor’s client in dual contract programs and with the Sponsor in single contract programs. In both the dual contract and single contract Wrap Programs in which ACR participates, the Sponsor typically:
• assists the client in defining the client’s investment objectives based on information provided by the client and provides the client with the opportunity to impose reasonable restrictions on management of the account;
• determines whether the fee arrangement is suitable for the client;
• aids in the selection of an investment adviser to manage

the account (or a portion of its assets);
• periodically contacts the client to ascertain whether there have been any changes in the client’s financial circumstances or objectives that warrant a change in the arrangement or the manner in which the client’s assets are managed, whether the client wishes to impose reasonable restrictions (or additional reasonable restrictions) on the management of the account or reasonably modify existing restrictions; and
• ensures that personnel who are knowledgeable about the account are reasonably available to the client for consultation. Wrap Program clients generally receive all ACR disclosure documents (including Form ADV Parts 2A and 3), as well as any required prospectuses, from their respective Sponsor. Unified Management Accounts (UMAs) ACR provides recommendations, typically in the form of a “model portfolio” to a number of unified managed account (“UMA”) program sponsors (the “UMA Program Sponsors”). For these accounts, ACR does not have discretion and does not report the performance of UMA relationships in its various investment composites. Trades recommended by ACR may or may not be executed by each UMA Program Sponsor, and ACR’s recommendations may or may not be implemented by each UMA Program Sponsor in all of that sponsor’s client portfolios. ACR is not responsible for either trade execution or reconciliation of these accounts but does provide specific trade instructions to each UMA Program Sponsor’s trading desk. As such, ACR has determined that it provides continuous and regular management services as it relates to its services to UMA Program Sponsors. Privacy and Security For privacy safeguards and security purposes, ACR has established a Privacy Notice, which is sent to all new clients at the time of account opening. Any material changes to ACR’s Privacy Notice will be distributed to existing clients promptly and is available upon request by contacting us any time as described in Item 1. When applicable, a separate supplemental Privacy Notice is distributed to Clients residing in certain states that have enacted additional privacy disclosure obligations. In addition, the Firm has in place a Business Continuity Plan to protect the firm and its clients in the event of a significant business disruption. To cover all aspects of the firm’s use of technology, a Written Information Security Plan is in place which includes a detailed cybersecurity plan. Mutual Fund and Limited Partnership Management ACR also serves as the investment adviser to various commingled funds. These funds are described below and collectively referred to within this Brochure as “the ACR Funds”:
• The “Mutual Funds” (each a series of the Investment Managers Series Trust II, registered under the Investment Company Act of 1940), include the ACR Opportunity Fund and the ACR Equity International Fund.
• ACR also serves as investment adviser to the ACR Opportunity, LP and ACR Strategic Credit, LP (“ASC LP”), private funds that are structured as limited partnerships and may advise other registered investment companies or private funds in the future (the “Partnerships”). ACR continuously manages the assets of the ACR Funds based on the investment goals and objectives as outlined in the Mutual Funds’ prospectuses and the Partnerships’ private placement memorandum, respectively. The individual needs of the investors in the ACR Funds are not the basis of investment decisions made by ACR; investment advice is provided directly to ACR Funds and not to the individual investors holding shares of the funds. ANY REFERENCE TO THE ACR FUNDS WITHIN THIS BROCHURE SHALL NOT CONSTITUTE AN OFFER TO SELL OR THE SOLICITATION OF AN OFFER TO BUY INTERESTS IN THE ACR FUNDS. Educational Due Diligence ACR offers current and prospective financial intermediaries educational due diligence visits at its home office. ACR will incur all costs including travel, meals, and lodging. Amount of Managed Assets As of December 31, 2023, ACR was actively managing $3,758,684,382 of clients’ assets on a discretionary basis. Additionally, through unified managed accounts (UMAs), the Firm provides advice on $1,862,655,387 of clients’ assets on a non-discretionary basis.