A. Caspian Capital LP, formed in October 2010, is an investment advisory services firm specializing in alternative investment management. The principal owners of our firm are Adam S. Cohen and David N. Corleto (the “Principals”). The first Caspian fund was established in 1997 when Caspian was part of another institution. We use the terms “Caspian,” “our,” “us,” and “we” in this brochure to refer to Caspian Capital LP and various affiliates and related entities that are also involved in conducting our business. B. Caspian specializes in offering investment management services to private investment funds and similar institutional accounts. Caspian also provides sub- advisory services on behalf of an open-end investment company registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”) and an investment company incorporated in the Cayman Islands. In providing our advisory services, our objective is to achieve capital appreciation over the long term by applying a flexible and opportunistic approach to investing which involves evaluating the current attractiveness of various asset classes, including bank loans, bonds, equities, speculative investments, and cash equivalents. We are permitted to trade and make investments in public and private debt and equity securities. Consistent with this opportunistic approach, however, there are no fixed limitations or diversification requirements as to specific asset classes in which we invest. We use the term “Caspian Funds” in this brochure to refer to the private funds

and dedicated investor funds that we sponsor, manage, and advise. We use the term “Managed Account” with respect to our sub-advisory agreement with the regulated investment company (“RIC Account”) and investment company incorporated in the Cayman Islands (“Cayman Account”) and Managed Account agreements with private funds not sponsored by Caspian. Also, we use the term “Client” when referring to our advisory relationships collectively. C. Caspian tailors its advisory services to the specified investment mandates of our Clients. Our Principals have sole discretion over the allocation of the assets of the Caspian Funds and adhere to the investment strategy set forth in the Caspian Funds’ private placement memoranda and the investment guidelines as agreed to for certain Caspian Funds and the Managed Account clients. Investors in some Caspian Funds can impose restrictions on investing in certain types of investments. In these cases, we are permitted to avoid investing in the restricted positions on behalf of the entire Caspian Fund or exclude the affected investors from participating in these positions and allocate profits and losses with respect to these positions separately from the rest of the Caspian Fund’s portfolio. These types of terms are all arranged on a case-by-case basis. D. We do not participate in wrap fee programs. As of December 31, 2023, we advised or managed client assets in the amount of approximately $5,057,526,000 (calculated as Regulatory Assets Under Management), all of which are managed on a discretionary basis.