General Description BlueArc Capital Management, LLC (collectively with its affiliates “BACM” or the “Firm”) was founded in August 2005 and is headquartered in Atlanta, Georgia. BACM is wholly owned by BlueArc Capital, LLC, a diversified financial services firm whose other subsidiaries include a private equity business, real estate business, and private debt business. Another subsidiary of BlueArc Capital, LLC, BlueArc Special Situations Credit Management, LLC, (“BSSCM”) is included as a relying adviser on this brochure. BSSCM shares certain personnel and corporate overhead with BACM and is subject to BACM’s policies and procedures. BACM’s (801-79523) registration with the Securities and Exchange Commission ("SEC") as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended, was approved on April 8, 2014. This registration does not imply any level of skill or knowledge. The principal owner of the Firm is Ronald Zazworsky, Jr. An organizational chart depicting the “principal owners” of BACM’s advisory affiliates related to the BlueArc Funds is included as Exhibit A to this document. Please see Item 10: Other Financial Industry Activities and Affiliations for a list of all Investment Advisory Affiliates. BACM’s Advisory Services BACM, either directly or through its subsidiaries, provides advisor services to private fund clients and consulting, research, and non-discretionary advisory services to other clients. Advisory clients and clients that are private funds are referred to herein as “Clients”. Clients that are private funds are also referred to herein as “BlueArc Funds”. This brochure may also from time to time refer to investors within the funds as “Fund Investors”. In its capacity as the manager and investment adviser to a BlueArc Fund, the Firm provides management services and investment advice, as applicable, solely to the applicable BlueArc Fund, and not to individual Fund Investors. The descriptions set forth in this brochure of specific advisory services that we offer to our Clients, and investment strategies pursued and investments made by us on behalf of our Clients, including the BlueArc Funds, should not be understood to limit in any way our investment activities. We may offer any advisory services, and, in the case of BlueArc Funds, engage in any investment strategy and make any investment, including any not described in this brochure, that we consider appropriate, subject to each BlueArc Fund’s investment objectives and guidelines. We do not provide investment advisory services to any Client except pursuant to a written advisory agreement. The investment strategies we pursue are speculative and entail substantial risks. Private Funds BACM manages

and advises several BlueArc Funds with varying strategies, including private equity, hedge, real estate, and private credit. Each BlueArc Fund includes investment guidelines and parameters as well as specific reporting requirements and accounting guidelines. Each BlueArc Fund is managed to the specific objectives of such BlueArc Fund and are not tailored to the individual needs of the Fund Investors. The descriptions of the BlueArc Funds in this brochure, including the type of investments made and strategies used, fees and expenses charged, risk factors and conflicts of interests that may arise in BACM’s management of such funds and investments are qualified in their entirety by reference to each BlueArc Fund’s formal offering materials (e.g., the BlueArc Fund’s offering memorandum, memorandum and articles of association, limited partnership agreement or limited liability company agreement, and subscription document) provided to investors in the BlueArc Funds (collectively referred to herein as the “Offering Documents”). Consulting, Research, and Non-Discretionary Advisory Services BSSCM, a relying adviser under common control with BACM, provides consulting, research, and non-discretionary advisory services to a limited number of Clients. Research and analysis of specific assets, along with any recommendations, are guided by the Client’s individual situation, objectives, and criteria. BSSCM consulting, research and non-discretionary services are focused primarily on investments in corporate securities, loans, equity, debt, derivatives and other similar investments in the aviation industry and other related sectors as may be identified by the client’s criteria. Client accounts may or may not be continually supervised, as established in the Client’s particular agreement; however, generally recommended assets purchased by the Client are monitored to ensure previous recommendations remain appropriate. Where BSSCM is not providing continuous supervision to an account, we consider the assets of the account to be assets under advisement rather than a part of our regulatory assets under management. As a part of these services, BSSCM may recommend an investment in a BlueArc Fund; however, clients are under no obligation to invest in any recommended product, including the BlueArc Funds. To date, no BSSCM client has invested in a BlueArc Fund. Agreements to provide consulting, research, and non-discretionary advisory services are entered into on a limited basis, and the related terms and fees are negotiated separately for each case. Assets Under Management As of September 30, 2023, BACM has $1,171,912,215 discretionary assets under management. BACM also has $179,371,453 of assets under advisement.