Finback, a Delaware limited liability company, was formed in October 2019 and commenced operations in January 2020. Finback became an Exempt Reporting Adviser in 2020 and as of June 29, 2021, applied for registration with the SEC as a registered investment adviser. The term the “Firm” is used within this brochure to refer broadly to the entire Finback enterprise and its related entities, and not to a specific legal entity. The Firm is headquartered in Coral Gables, Florida. The owners of Finback are listed in Part 1A of the Firm’s ADV. One owner holds an interest of 40%. As of December 31, 2023, the Firm provides investment management services (“Advisory Services”) to nine privately offered pooled investment vehicles, with institutional and other sophisticated investors, that are funds organized as Delaware limited partnerships:
• Finback AP, LP;
• Finback Evolv II, LLC;
• Finback Evolv, LLC;
• Finback GPO, LP;
• Finback PACE LP;
• Finback Seniorlink, LP;
• Finback ISCP, LP;
• Finback Investment Partners 2021 Fund, LP, and
• Finback Investment Partners 2024 Fund LP, (collectively, the “Funds” and each a “Fund”). The Deal-by-Deal Funds have historically invested in one portfolio company. The 2021 Fund is a blind pooled vehicle that primarily makes minority equity investments in private companies in parallel with lead third-party private equity managers. The ISCP Fund is a private fund that has invested substantially all of its investable assets in a private fund managed by an unaffiliated investment adviser. The Firm may also engage in other business activities from time to time, such as forming joint ventures and partnerships with companies. The Firm generally partners with a lead private equity manager and seeks an active minority role in its portfolio companies. The Firm takes a long-term approach to its investments and partnerships, investing in and partnering with companies it believes are poised for growth and that attract high- quality management teams. The Firm looks to partner closely and work cooperatively with management teams and entrepreneurs that have track records of success, and where the Firm’s unique expertise and network can differentially create value. The Firm provides Advisory Services directly to each Fund (and not individually to any Fund investor) pursuant to the terms of the pertinent offering document, limited partnership agreement, investment management agreement or other similar agreements (the “Governing Documents”). Investors in the Funds do not receive Advisory Services tailored to their individual needs. The Firm does not offer a wrap fee program. As of December 31, 2023, the Firm advised on a discretionary basis approximately $818,405,768 of regulatory assets under management. The Firm does not manage any assets on a non- discretionary basis. In certain circumstances, third parties may be offered the opportunity to co-invest alongside the Funds through joint ventures or other entities (“Co-Investors”). The Firm will consider any factors it deems relevant in determining such allocations, including, without limitation, the potential Co- Investor’s size, sophistication, tenure as an investor with the Funds generally; commitment to making co-investment funds available; ability to consummate co-investments within a specified time frame and with the same diligence as the Firm; interest in pursuing co-investment opportunities; potential Co-Investor’s strategic expertise or other benefits; whether the potential Co- Investor has previously been offered opportunities to co-invest and whether the potential Co- Investor has taken up those opportunities (or conversely has passed on opportunities); the potential Co-Investor’s financial and operational resources and other relevant wherewithal to evaluate and participate in the co-investment opportunity; the aggregate size of the co-investment opportunity; the size of a potential Co- investor’s commitment to the Fund or other client (if any); the expertise, knowledge and sophistication of the potential Co-Investor with respect to the issuer, segment, industry, geographic region or other characteristics that are relevant to the investment; whether a potential Co-Investor has an interest in investing in the industry in which the proposed portfolio company participates; whether the participation of a potential Co-Investor in the acquisition group might improve the Firm’s chances to

win the deal in a competitive situation; geographic nexus between the potential Co-Investor and the potential portfolio company; whether the proposed investment is of a financial nature attractive to a particular proposed Co-Investor; whether the participation of a potential Co-Investor in the proposed investment could add value to the proposed portfolio company; existence of a formal or informal strategic relationship with the potential Co- Investor; and other factors that the Firm considers important in connection with the specific transaction or investment, including, without limitation, expected holding period, services provided by the potential Co-Investor to the issuer of the investment (or otherwise provided by the potential Co-Investor with respect to the investment). Co-investment opportunities typically will be offered to some and not to other investors, and the consideration of the factors set forth above likely will result in certain investors receiving multiple opportunities to co-invest while others expressing interest in co-investments have the potential to receive none. When and to the extent that employees and related persons of the Firm and its affiliates make capital investments in or alongside the Fund, the Firm and its affiliates are subject to potentially conflicting interests in connection with these investments. Co-investments will not necessarily be made on the same terms as the Fund’s investment in the portfolio company. For example, Co-Investors may pay no advisory fees or carried interest in connection with the co-investment or pay them at a lower rate than the investors with which they are co-investing. Any management fees, carried interest or other amounts received by the Firm or any of its affiliates will be for the sole benefit of the Firm or such affiliate and not, for the avoidance of doubt, the benefit of any Limited Partner. Co-investors may also acquire their interest in a portfolio company at the same time as the Fund or purchase their interest from the Fund after the Fund has consummated the investment in the portfolio company. In either case, potential Co- Investors typically do not bear any transaction costs of investments that are not consummated, including any legal or consulting costs in evaluating a potential investment, reverse break fee and other broken deal expenses. Such costs and expenses would instead be borne by the Fund and could be material to the Fund and the investors. The Funds may enter into separate agreements, commonly referred to as “side letters”. The Firm may enter into side letters or other similar agreements with particular investors in connection with such investor’s admission to the Fund without the approval of or disclosure to any other investor, which would have the effect of establishing rights under or supplementing the terms of the Governing Documents with respect to such investor in a manner more favorable to such investors than those applicable to other investors, and such rights may be significant. Such rights or terms in any such side letter or other similar agreement may include, without limitation, (i) reporting obligations of the Firm, (ii) different economic rights (including different obligations for management fees, carried interest, organizational expenses and Fund expenses), (iii) waiver of certain confidentiality obligations, (iv) consent of the Firm to certain transfers by such investor or (v) rights or terms necessary in light of particular legal, regulatory or policy characteristics of an investor, including rights to withdraw from the Fund or be excused from contributing capital in certain circumstances (which may increase the percentage interest of other investors in, and their contribution obligations for, future investments and expenses, and reduce the overall size of the Fund). The Fund will not be required to disclose any such agreements to other investors, unless otherwise required to do so pursuant to applicable law or regulation. Investors that are granted such rights may include, without limitation, individuals affiliated with the Fund. To the extent that compliance with any of the provisions of any such agreement would cause the Fund, the Firm, or any of their respective affiliates to violate their respective fiduciary obligations to other clients or to violate any applicable laws, the Fund, the Firm or such affiliate will not comply with any such provision and any such non-compliance will not be deemed to be a breach of such agreement.