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EVANSTON ALTERNATIVE

OPPORTUNITIES FUND
2Q19 LETTER
The Evanston Alternative Opportunities Fund (“EAOF” or the “Fund”) JULY 26, 2019
returned an estimated +2.1% (Class I) and +1.9% (Class A) net of all
fees and expenses in the second quarter and has returned an estimated
+7.5% (Class I) and +7.1% (Class A) net of all fees and expenses year-
to-date. Net assets in the Fund are approximately $45 million and total
strategy assets are approximately $3.2 billion.1
RETURNS AND STATISTICS FOR PERIODS ENDED JUNE 30, 2019
Trailing
Trailing
3-Year Sharpe
QTD YTD 1-Year ITD2 Volatility2 Beta2
Annualized Ratio2
Return
Return

Evanston Alternative Opportunities


2.1% 7.5% -0.1% 4.0% 1.6% 4.9% 0.2 --
Fund (Net) - Class I
Evanston Alternative Opportunities
1.9% 7.1% -0.9% 3.2% 0.7% 4.9% 0.0 --
Fund (Net) - Class A
HFRI FOF Index 1.6% 6.3% 1.3% 4.3% 2.2% 3.7% 0.4 --
90-Day T-Bill 0.6% 1.2% 2.3% 1.4% 0.8% 0.3% -- --
Barclays Aggregate Bond Index 3.1% 6.1% 7.9% 2.3% 3.0% 2.9% 0.7 -0.10
S&P 500 Index 4.3% 18.5% 10.4% 14.2% 10.7% 12.0% 0.8 0.33
MSCI World Index 4.0% 17.0% 6.3% 11.8% 6.6% 11.7% 0.5 0.35
Sources: Bloomberg; HFR Database

INTRODUCTION

Evanston Capital Management, LLC (“ECM”) is pleased to provide you with the EAOF quarterly letter.
The following pages include:

•  Portfolio Holdings & Statistics


•  2nd Quarter Strategy Discussion
•  Portfolio Discussion and Risk Management
•  2nd Quarter Op/Ed

PAST PERFORMANCE DOES NOT GUARANTEE FUTURE RESULTS


Evanston Alternative Opportunities Fund’s (the “Fund”) performance data quoted represents past performance (as described below) and is presented net of the Fund’s
fees and expenses. All performance data that includes the current month shown above is estimated. An investment’s return and principal value will fluctuate so that a
Fund shareholder’s shares, if and when repurchased in a tender offer, may be worth more or less than their original cost. Current performance may be lower or higher
than the performance data quoted. Where applicable, all returns shown reflect the reinvestment of all distributions of income and capital gains.
Class I: Performance for the period from July 1, 2014 through June 30, 2015 is based on a reduced management fee of 0.90% per annum per the management fee waiver.
Class I’s performance would be lower without the management fee waiver during such period. From July 1, 2015 through December 31, 2018, Class I’s management fee
was 1.20% per annum; effective January 1, 2019, the management fee is 1.0% per annum. Class I is not subject to a sales load.
Class A: Performance shown prior to Class A’s inception date (06/01/2015) is based on the performance of Class I Shares, adjusted to reflect Class A’s fees and expenses.
Performance shown through December 31, 2018 for Class A reflects a management fee of 1.20% per annum. Effective January 1, 2019, Class A’s management fee is
1.00% per annum with a distribution and service fee of 0.75% per annum.
The Fund’s Class I and Class A net performance reflects expense reimbursements that are in effect until July 31, 2020. Performance would have been lower without the
expense reimbursements that are currently in effect. Neither Class I nor Class A’s performance was reduced by the early withdrawal fee of 3% that is payable to the Fund
for shares the Fund repurchased within 12 months of issuance. If the early withdrawal fee were reflected, performance would be reduced.
1. As of July 1, 2019 2. From inception, July 1, 2014 Foreside Fund Services, LLC, Distributor

Copyright 2019. Evanston Capital Management, LLC. All rights reserved.


UNDERLYING MANAGERS3 STRATEGY CONTRIBUTION4

Approximate 2Q19 YTD Annualized ITD


Manager Name Discipline Hedge Fund
Contribution Contribution Contribution
Allocation % Strategy
to Performance to Performance to Performance

Element Capital Management LLC Global Asset Allocation 8.4% Long/Short


1.4% 5.7% 1.1%
Equity
Long/Short Equity, Global Asset
Zebedee Capital Partners LLP 6.2% Event Driven 0.4% 0.9% 0.2%
Allocation

Silver Point Capital, LP Event Driven 5.9% Relative Value 0.1% -0.1% -0.4%

Diameter Capital Partners LP Event Driven, Relative Value 5.6% Global Asset
0.1% 0.9% 0.7%
Allocation

Whale Rock Capital Management LLC Long/Short Equity 5.5% Total (Class I) 2.1% Net 7.5% Net 1.6% Net

Anchorage Capital Group, LLC Event Driven, Relative Value 5.3%


STRATEGY ASSET ALLOCATION3,5
Rokos Capital Management LLP Global Asset Allocation 5.1%

Long/Short Equity: 48%


Matrix Capital Management Company LLC Long/Short Equity 5.1%
Global Asset Allocation: 20%
Event Driven: 19%
Pleiad Investment Advisors Limited Long/Short Equity 5.0%
Relative Value: 13%

Sachem Head Capital Management LP Long/Short Equity, Event Driven 4.6%

Oxbow Capital Management Long/Short Equity 4.5% STYLE ALLOCATION3,5


U.S. Long/Short Equity: 23%
Adelphi Capital LLP Long/Short Equity 4.3%
Global Asset Allocation: 20%
Europe Long/Short Equity: 12%
Wellington Management Company, LLP Relative Value 4.3%
Credit and Capital
Structure Arbitrage: 12%
Long/Short Equity, Global Asset
Castle Hook Partners 4.1% Distressed Debt - Long: 10%
Allocation
Emerging Markets
Marblegate Asset Management, LLC Event Driven 3.9% Long/Short Equity: 8%
Japan, Developed Asia
Long/Short Equity: 5%
Wellington Management Company, LLP Long/Short Equity 3.9% Distressed Debt - Relative Value: 4%
Other Special Situations: 3%
Pelham Global Financials Ltd Long/Short Equity 3.7% Distressed Debt - Special Situations: 2%
Statistical Arbitrage: 1%
Great Point Partners, LLC Long/Short Equity 3.6%

Long/Short Equity, Event Driven,


Senator Investment Group LP
Relative Value
2.1% GEOGRAPHIC ALLOCATION3,5
Long/Short Equity, Relative
Coatue Management, L.L.C. 1.3%
Value
U.S.: 52%
Long Pond Capital, LP Long/Short Equity 0.7% Europe: 27%
Emerging Markets: 12%
Cash 6.3% Japan/Developed Asia: 9%

PAST PERFORMANCE DOES NOT GUARANTEE FUTURE RESULTS


3. As of July 1, 2019. Holdings and allocation percentages are subject to change, and may be significantly different than those set forth above at the time of your investment. This list
excludes the managers of any Portfolio Funds where (i) the Portfolio Fund is in the process of winding up its operations, (ii) the Fund has submitted a full redemption request but
retains an investment in such Portfolio Fund with respect to side pockets at the Portfolio Fund level, and/or (iii) the Fund has requested a full or partial redemption and such Portfolio
Fund has paid part or all of the redemption proceeds to the Fund in-kind in the form of shares or interests in a special purpose vehicle (collectively, “Excluded Funds”). The Fund’s
estimated net return includes investments in Excluded Funds. Excluded Funds are estimated to represent approximately 0.5% of the Fund’s net asset value as of July 1, 2019. “Cash”
includes cash, cash equivalents and redemption proceeds payable to the Fund from Portfolio Funds but not yet received (excluding side pocket and other illiquid investments at the
Portfolio Fund level). Total amounts may not sum to 100% due to rounding.
4. As of June 30, 2019. Contribution to performance for Class A for 2Q19 was as follows: Long/Short Equity, 1.3%, Event Driven, 0.4%, Relative Value, 0.1%, and Global Asset Allocation/
Macro, 0.1%. Class A’s 2Q19 net return was 1.9%. Contribution to performance for Class A for YTD was as follows: Long/Short Equity, 5.5%, Event Driven, 0.9%, Relative Value, -0.1%,
and Global Asset Allocation/Macro, 0.8%. Class A’s YTD net return was 7.1%. Contribution to performance for Class A for ITD annualized was as follows: Long/Short Equity, 0.7%,
Event Driven, 0.0%, Relative Value, -0.6%, and Global Asset Allocation/Macro, 0.5%. Class A’s ITD annualized net return was 0.7%. Please see the performance disclosures on Page
1. Total may not sum due to rounding.
5. A
 ll exposures shown herein represent ECM’s subjective assessment of the exposures of Portfolio Funds contained in the Fund. All exposures exclude investments in Excluded Funds
(defined on page 2, footnote 3) as well as cash and cash equivalents held at the Fund level. However, please note that in calculating the Fund’s gross and net exposures as a
percentage of net asset value, the Fund’s allocations to Excluded Funds and cash and cash equivalents are included in the net asset value. Strategy, style, and geographic allocations
are subject to change. Japan/Developed Asia exposure includes exposures to Japan, Hong Kong, Singapore, Australia, and New Zealand. Total amounts may not sum to 100% due to 2
rounding.

1560 Sherman Avenue | Suite 960 | Evanston, IL | 60201 | P. 847-328-4961 | F. 847-328-4676 | www.evanstoncap.com
2ND QUARTER RETURN DISCUSSION

Global equities continued their ascent last quarter as investors cheered a clearly more dovish Fed and the “bad-news-is-good-news” narrative of
yesteryear seemed to return to markets. Ongoing concerns about trade policy and slowing economic growth, which caused market turbulence
mid-quarter, took a back seat, at least temporarily, as expectations for a rate-cutting cycle built. The result was a strong, nearly universal June
rally, in which risk assets as well as traditional safe havens, such as U.S. Treasuries, participated. At the halfway point for the year, global equities
and high yield credit each had notched healthy, double-digit gains (MSCI World +17% YTD in USD terms; BofA ML High Yield Master II +10%
YTD), while Treasury yields had declined meaningfully across maturities, more so at the middle- and long-end of the curve. Despite hopes for an
anticipatory shift in monetary policy and its potential ability to extend the current economic expansion, investors remain wary of the inverted
yield curve, which is often a precursor to a recession.

EAOF continued to perform well during the second quarter, returning an estimated +2.1% net (Class I) and +1.9% net (Class A), and is now
up an estimated +7.5% net (Class I) and +7.1% net (Class A) year-to-date. Like the first quarter, long/short equity was the dominant driver of
performance, accounting for almost 70% of the Fund’s 2Q19 return. Certainly, this strategy bucket saw some uplift simply from net long exposure
to rising equity markets, but strongly positive alpha from stock selection was also a key contributor. In fact, we estimate that EAOF’s long/short
bucket generated a stand-alone gross return of +3.5% in the second quarter, nearly keeping pace with the returns of both U.S. and global equities
(S&P 500 Index and MSCI World each +4% in 2Q19) despite average net exposure of approximately 45%.

The Fund’s event driven allocation was the next largest contributor to performance. All of the Fund’s event driven managers were profitable for
the period, and most kept up with the returns of broader credit markets even with more defensive postures at this stage of the cycle. Results
within global asset allocation (“GAA”) and relative value were mixed, resulting in slightly positive attribution from both strategy buckets.

At the manager level, we saw both a good hit-rate (i.e. number of winners) and a positive skew of outcomes (i.e. magnitude of gains versus losses).
Seventeen of the Fund’s 22 core managers were profitable last quarter with the top five contributors adding 1.7% to gross performance and all
five detractors subtracting 0.5%. Below we discuss the results of each strategy bucket and individual managers in more detail.

LONG/SHORT EQUITY

It was an up-and-down (in fairness, an up-down-up) quarter for equity markets, but most major indices finished in positive territory. U.S. large
capitalization stocks (S&P 500 Index +4%) extended their run, and Europe was also quite strong (EuroSTOXX 50 +6%), leaving global indices
(MSCI World +4% in USD terms) with a solid return even as Asia lagged (MSCI AC Asia Pacific +1% in USD terms). Gains from the first two
quarters have led to the strongest start for many indices in years; for instance, the S&P’s year-to-date gain of +19% is its best first-half return
since 1997. Technology continued to be the hot sector (S&P 500 Information Technology +27% YTD), but all major sectors were positive for the
second quarter with the notable exception of energy (S&P 500 Energy -3% 2Q).

We posited in our January letter that 2019 might portend better opportunities for shorting with higher interest rates offering a positive short
rebate for the first time in a decade and potentially revealing the differences between strong and weak companies. Despite the Fed’s more dovish
rhetoric, we saw positive short alpha from many of the Fund’s long/short equity managers and, even more encouragingly, positive absolute short
performance from some. While the overall markets climbed higher and long positions were the primary source of returns, market leadership
continued to be narrow among mega-cap growth stocks, and there were certainly pockets of weakness for managers to exploit.

Sector and Region Focused Long/Short Equity Managers

The Fund’s best performing manager last quarter, a TMT specialist, was helped significantly by the strong early returns from a biotechnology
IPO. Other contributors in their long portfolio included a position in a software company, which agreed to be acquired during the quarter, as well
as a long-time holding in an industrial company. This manager also has been more active in the semiconductor sector, which they have traded
successfully both long and short over recent quarters. The other TMT manager in the Fund extended its strong performance run with winners in
several areas of technology. Payment processors and payment-system developers have become a significant theme in the portfolio, and while
many of the payment processors were flat for the month, a software enterprise focused on business-spend management soared and was a big
contributor due to its core sizing in the portfolio. This manager also got some timely protection from its short portfolio during May’s market
downdraft, which added to overall alpha generation.

The Fund’s real estate specialist benefited from a bid for a Las Vegas-based gaming company that we have written about in previous letters. As
part of a multi-pronged thesis for owning the stock, this manager was an early believer that a strategic transaction was a credible catalyst for
unlocking shareholder value. The bid drove the stock over 30% higher during the quarter for a year-to-date gain of over 70%. Two hotel stocks
also did well as general sentiment toward that sub-sector improved, with one company specifically highlighting positive results from acquisitions
made last year. Continued speculation that the Fed’s next move will be a rate cut also boosted several homebuilder stocks that this manager
holds.
3

1560 Sherman Avenue | Suite 960 | Evanston, IL | 60201 | P. 847-328-4961 | F. 847-328-4676 | www.evanstoncap.com
The Fund’s financials specialist had an excellent quarter thanks to allocations to important growth themes as well as solid stock-picking within
those themes. Two stock exchange companies, one in developed markets and one in emerging, performed strongly, partly because exchanges
tend to do well during bouts of stock volatility like we saw in May. Bank holdings in Russia and Turkey also outperformed. The manager’s largest
thematic bet in financial technology was a bit of a mixed bag, especially in Brazil, where the manager’s core holdings diverged dramatically. One
sold off on competitive threats while the other rose on strong quarterly results. For one of the Fund’s European specialists, financials exposure,
focused on European bank stocks, was also a positive contributor for the quarter. The manager made this bet on the belief that markets would
push higher early in the quarter but then potentially fade into summer as China stimulus fails to significantly impact broader global growth.

In Asia, the Fund’s managers limped along last quarter as trade policy headlines dented confidence in Asian equities, particularly in China.
Losses in Chinese stocks offset gains in other countries, leading to flattish performance for both managers. One of the managers broke even on
long positions with strength in Japan and India and lost a little on shorts. A technology company with an entertainment arm climbed on news
that an activist was advocating for a split-up of the conglomerate. Holdings in an Indian asset manager and real estate developer also provided
a ballast for them, helping the manager hold on to strong year-to-date performance. The other Asia specialist’s performance attribution was the
reverse, with longs detracting and shorts breaking even. This manager believes earnings growth, broadly speaking, will be weaker than expected
in the second half of 2019 and into 2020, so they have maintained a defensive tilt.

Biotechnology stocks started the year strongly, and within the industry, small caps (Russell 2000 Biotech +24% YTD) have outperformed the
broader cohort (Nasdaq Biotech +13% YTD), though neither gained much ground in 2Q (Russell flat; NBI -2%). With an average net-long posture
of about 60%, the Fund’s health care specialist slightly underperformed both market measures on an exposure-adjusted basis for the quarter but
added alpha versus both benchmarks year-to-date. While there were no dramatic sell-offs or rallies among the manager’s top holdings for the
period, the volatile nature of biotech means that even marginally bad or good news can lead to big moves in price. As such, a couple holdings with
clinical updates that did not quite meet expectations traded 20% lower, contributing to a modest loss for the quarter.

EVENT DRIVEN

Credit Managers

While the ride was a little bumpier last quarter, credit markets continued their strong start to the year, benefitting from further spread tightening
and an acceleration in the move lower in interest rates. Late-cycle growth concerns have injected a degree of caution into the credit markets, but
those fears have been overwhelmed by investors’ thirst for yield as a record 25% of global fixed income assets now trade with negative yields.
While global central banks look to maintain accommodative financial conditions, this dynamic appears poised to continue, at least in the near-
term. Both the Barclays U.S. Aggregate Bond Index and BofA Merrill Lynch U.S. High Yield Master II Index finished the quarter up +3%, bringing
their year-to-date returns to +6% and +10%, respectively. The Fund’s credit managers largely kept up with the credit indices last quarter and
collectively made a solid contribution to overall performance.

A distressed manager in the Fund continued to grind out steady returns during the quarter and generated gains on both the long and short side
of the portfolio all while maintaining a defensive posture with limited market beta. While there were no outsized individual contributors, winners
were concentrated in the performing high yield and loan space where a flexible, trading-oriented approach has proven advantageous. Another
distressed manager bounced back nicely from a slow start to the year. Similarly, this manager’s gains were concentrated in the performing credit
book. In particular, a core position in a pet supply retailer continued to trade higher on the back of a well-received IPO of its online pet food-seller
subsidiary. The manager’s distressed book, meanwhile, has been more of a mixed bag this year as a couple of small wins have been neutralized by
weakness in a large holding of a media company. The manager is focused on monetizing legacy distressed holdings in the back-half of 2019, which
they believe will drive attractive near-term returns and set them up well for the inevitable turn in the credit cycle. A third distressed manager in
the Fund had gains that came from a combination of core legacy holdings and a newer top position. Winners included diversified exposure to
Puerto Rico, a restructured global furniture retailer, and a Chinese gaming company. A newer, large position in a distressed Californian utility
was also a nice contributor as momentum built in the state legislature to pass a comprehensive policy solution addressing wildfire liabilities. This
development increased the market’s optimism for a shorter bankruptcy process.

Equity-Oriented Event Managers

The Fund’s activist manager had a solid quarter driven by contributions from two newer activist positions. One is a communications infrastructure
provider that controls a large fiber optic network and had been a passive holding for over a year. The thesis at initiation was that this company
was a strategically important asset operating in an industry with strong structural tailwinds, particularly given the coming 5G rollout and the
associated increase in data intensiveness. While this manager initially had confidence in the well-aligned management team, some operating
missteps in 2018 caused them to re-underwrite the position and led to more active engagement with the company. They began publicly pushing
for a sale of the company, believing an operational turnaround would best be undertaken in the private markets and understanding that there
was substantial interest from strategic buyers. In May, the company subsequently announced its sale to a private equity consortium at a healthy
premium from the early-year trading lows. The other activist position is an ongoing holding in an industrial conglomerate. This manager believes
4

1560 Sherman Avenue | Suite 960 | Evanston, IL | 60201 | P. 847-328-4961 | F. 847-328-4676 | www.evanstoncap.com
cash flows from the company’s high-quality assets are being used inappropriately to subsidize the expansion into a lower-quality business line.
Sub-optimal capital allocation decisions have destroyed significant shareholder value and led the company to trade at a material discount to
the sum of its parts. This manager was pushing for a separation of these businesses to eliminate the conglomerate discount. The company
announced during the quarter that it would undertake such a plan, and the stock price reacted positively.

GLOBAL ASSET ALLOCATION (“GAA”) AKA MACRO

There was meaningful dispersion in returns among the Fund’s GAA managers during the quarter, resulting in a small positive contribution overall.
The best GAA performer generated gains from rates strategies and equity trading in the U.S. and Europe. This manager’s base case for the U.S./
China trade war is that retaliatory tariffs and other measures likely will worsen prior to any definitive agreement being reached. If inflation
continues to run below target and trade tensions slow economic growth more significantly, they believe the Fed is more likely to enter a sustained
rate-cutting cycle. While another Fund GAA manager is also worried about the economic impact of a prolonged U.S./China trade war, they are
relatively more constructive on the potential for resolution between now and year-end. To the extent a deal is successfully negotiated, economic
conditions in the U.S. remain favorable for equity risk as growth has been solid, if unspectacular, and inflation remains tame. However, they also
acknowledge that the risks to their core bullish U.S. equity view have increased as the current U.S. economic expansion is the longest on record,
and as always, they will remain nimble as facts change.

A third GAA manager in the Fund had a difficult quarter and has been frustrated with performance so far in 2019. While they made the right
top-down call to be bullish equities in the first half of the year, the implementation of this view was poor, and they generated significant negative
alpha from security selection. They were rewarded for bets on secular growth areas, such as technology, but those gains were more than offset by
losses from exposure in out-of-favor areas, such as commodity-related stocks and non-biotech healthcare. In response, this manager evolved the
investment process to include a more systematic approach to bottom-up security analysis and communication within the team with the goal of
reducing position count and more closely adhering to the top-down outlook. While the core investment philosophy and strategy are unchanged,
they are optimistic these tweaks will result in better execution going forward.

RELATIVE VALUE

The Fund’s relative value managers also had divergent outcomes last quarter. The Fund’s emerging market debt specialist generated steady gains
and profited from all three of its underlying strategies. The directional credit portfolio benefited from positions in Eastern Europe, where the team
has been monetizing gains, and still favors a number of frontier countries in regions such as sub-Saharan Africa. Meanwhile, the manager’s
relative value strategies continued to capitalize on a choppier market backdrop, as the approach relies upon dispersion and price volatility to
capture spreads between related securities. The core bet in this part of the portfolio has been long developed market investment grade credit
versus short emerging market credit, BBBs in particular.

The Fund’s volatility specialist continued to struggle last quarter. The increasingly dovish rhetoric out of the Fed further depressed U.S. interest
rate volatility, and implied volatilities in developed market currencies continued to plumb historic lows. The potential asymmetry for a long
volatility strategy at current levels is attractive, but the pathway for significant and sustained volatility expansion in the near-term, particularly
in interest rates, is less certain with the Fed “put” seemingly back in place. We fully redeemed the Fund’s investment at the end of the quarter.

PORTFOLIO DISCUSSION AND RISK MANAGEMENT

We made a few notable changes to the Fund’s manager line-up during the second quarter. EAOF completed a full redemption with Ionic Capital
Partners LP and initiated a new investment in Coatue Management, L.L.C. (described in detail below). Despite this manager-level activity, the
Fund’s overall risk profile did not fluctuate significantly. The Fund maintains a tilt toward long/short equity (48% as of July 1), followed by near
equal allocations to GAA (20%) and event driven strategies (19%), while the allocation to relative value (13%) continues to be at the low end of
its historical range. The Fund’s gross exposure (235% as of July 1) declined modestly quarter-over-quarter, but net exposure (37%), the majority
of which remains in U.S. equities, was quite stable.

New Investment with Coatue Management, L.L.C. (“Coatue Quant”)

EAOF initiated an investment in Coatue Quant on May 1. Coatue was founded in 1999 by Philippe Laffont, previously of Tiger Management, and
is consistently recognized as one of the premier technology-focused asset management firms globally. Coatue Quant is a systematic, equity
market-neutral fund that was launched with internal capital in 2018 and opened to external investors in May 2019. It follows a “quantamental”
investment approach, combining fundamental research insights with the ability to capture, process, and synthesize high volumes of data to
forecast stock prices. Portfolio construction and execution are systematic and designed to maximize alpha generation—in practice, this means
running a well-diversified portfolio with relatively high turnover, while also maintaining low net exposure and targeting beta and factor-risk
neutrality. We believe Coatue Quant introduces a new source of alpha to EAOF and expect to continue building the size of the Fund’s investment
in Coatue Quant in coming quarters.
5

1560 Sherman Avenue | Suite 960 | Evanston, IL | 60201 | P. 847-328-4961 | F. 847-328-4676 | www.evanstoncap.com
OP/ED

This section of the letter typically addresses a key component of our investment process, a general hedge fund topic, and/or events in the markets
that may impact performance. Typically, our second quarter Op/Eds focus on business or operational topics. Past subjects have included a deep
dive on security valuation (2016), cybersecurity and IT risk (2015), fund expenses (2014), existing manager operational due diligence (2013), and
a statistical breakdown of ECM’s managers on various operational metrics (2012). Please let us know if we can provide a copy of any of these
write-ups.

This quarter’s Op/Ed focuses on one of the more glamourous areas of the investment management business—compliance! Compliance is an
important component of our business and one that we focus on when performing operational due diligence on prospective and underlying
managers. We expect managers to establish and devote adequate resources to their compliance function and believe that managers of a
reasonable size should have dedicated legal and compliance professionals on staff. This is true for around 80% of our flagship strategy’s core
managers today (and ECM itself has two lawyers who are dedicated to legal and compliance matters). It is important that senior compliance
personnel not only have relevant backgrounds and expertise, but also that they are given adequate authority to create and enforce compliance
policies. In addition to internal compliance personnel, 80% of our flagship strategy’s core managers currently utilize external compliance
consultants to support their compliance program. While we are comfortable with managers utilizing compliance consultants as an extension of
their teams, we believe that a compliance function ultimately should be managed internally, rather than being fully outsourced.

In tandem with a manager’s compliance policies, there should be procedures to monitor and document adherence to its compliance program
as well as periodic training to educate both new and established employees on compliance matters. We estimate that 60% of our flagship
strategy’s core managers conduct three or more compliance training sessions each year (as does ECM). External audits of the compliance
function and preparations for regulatory exams through mock audits also have become best practice in the hedge fund industry. Roughly 60%
of our flagship strategy’s core managers have performed a mock audit (ECM typically does so every other year), and some that haven’t yet are
strongly considering it. Many managers utilize compliance software to efficiently manage the administration of their compliance programs—this
is true for approximately 65% of our flagship strategy’s core managers today. In addition, adequate compliance procedures and controls around
research activities, including the use of paid consultants, should be in place.

It is often said that compliance starts with the backing of senior management, the so-called “tone at the top”, and we could not agree more.
While compliance relies on the attitude of an organization’s individuals, to help ensure that investment advisers’ employees are properly focused
on compliance with federal securities laws, the Investment Advisers Act of 1940, as amended (the “Advisers Act”), requires certain policies and
procedures. A Code of Ethics (“Code”) is one of these prescriptive policies. Under the Advisers Act, all registered investment advisers, which
includes most hedge fund and private equity fund managers, are required to establish, maintain, and enforce a written Code. Although the
Securities and Exchange Commission (“SEC”) allows advisers significant flexibility to tailor their Codes to their operations, at a minimum, the
Advisers Act mandates:

• Advisers to adopt a standard of business conduct for its employees, and this standard must reflect an adviser’s fiduciary obligations
and those of its employees;

• Employees to comply with applicable federal securities laws;

• That certain employees report, and the advisers review, personal trading transactions and personal securities holdings periodically;

• Employees to report Code violations to the adviser’s Chief Compliance Officer; and

• Advisers to provide employees with a copy of the Code and any amendments, and employees to provide advisers with a written
acknowledgement of receipt of the Code and any amendments.

In addition to personal trading policies that are required to be set forth in an adviser’s Code, other typical provisions found in a Code include
procedures and reporting with respect to gifts and entertainment, policies pertaining to political contributions, and policies against insider
trading. This last issue, insider trading, is one of the most difficult to guard against, especially among larger advisers, and should be well fleshed
out in a Code because there is no direct statute that defines insider trading; rather, case law provides the roadmap to what constitutes insider
trading. As has been reported exhaustively in the popular press, the government has become more aggressive in bringing insider-trading cases
and using new methods, such as wire fraud statutes, to prosecute such cases.

To illustrate how a few common provisions of a Code operate, we decided to enlist the help of a friend and his colleagues from the hit TV show The
Office (who knew they ran a hedge fund, too!): Michael Scott of Dunder Mifflin Capital, LLC.

1560 Sherman Avenue | Suite 960 | Evanston, IL | 60201 | P. 847-328-4961 | F. 847-328-4676 | www.evanstoncap.com
Fact Pattern

Michael Scott, a Scranton, PA resident, is an investment analyst at Dunder Mifflin Capital, LLC (“DMC”), a long/short equity hedge fund focusing
on emerging companies in the technology space. On the train to work, Michael’s friend, Todd Packer, calls. A few minutes later, Michael’s
financial advisor emails to recommend buying 100 shares of International Paper Co. (“IP”). DMC’s Code of Ethics (“DMC Code”) states that
employees must pre-clear all personal trades. Michael, distracted by Todd’s call, sends a quick email instructing his financial advisor to execute
the IP trade and does not pre-clear the purchase.

That afternoon, Michael reviews data showing that Bob Vance’s Semiconductors (“BVS”), a company in which DMC invests, has performed poorly
the past two quarters. DMC is considering reducing its position in BVS. Bob Vance, BVS’s CEO, invites Michael and his boss, Jan, to dinner
that night at a Michelin-starred restaurant, and the meal totaled $1,200. DMC’s gifts and entertainment policy requires employees to pre-
clear entertainment above $250 per employee. Bob says that DMC should remain shareholders of BVS and that more fancy dinners are in play
if DMC continues to hold its stake. The next day, Jan recommends reducing DMC’s position in BVS, but she and Michael forget to report the
entertainment to the compliance team.

Later that afternoon, Michael’s friend, Pam Beesly, calls. Pam is the New York State Treasurer and is running for U.S. Senate, and her friend,
Angela Martin, is a New York Congresswoman running for re-election. Pam asks Michael to donate $500 to each of their campaigns. The DMC
Code caps political contributions for state and local candidates at $350 for elections in which an employee can vote and $150 for elections in
which an employee cannot vote, but it requires all amounts to be pre-cleared by DMC’s compliance team. Michael wants to split the difference
and contribute $250 to each campaign, but he recalls that federal elections are sometimes treated differently from state and local elections
under the DMC Code. He calls the compliance team to help him understand what he can donate.

Issue # 1: Personal Trading


“You miss 100 percent of the chances you don’t take.”

– Michael Scott

Although we want to see our managers invest in their own strategies, we understand that investment managers’ employees will also trade securities
for their personal accounts. The SEC recognizes this too, and Advisers Act Rule 204A-1 places the onus on registered investment advisers to
monitor certain employees’ personal trading (referred to as “access persons”) and protect investors from the risk of fraud from employees trading
for their own account. Specifically, Codes require these employees to (1) report their personal security holdings and transactions, and (2) obtain
pre-approval of certain investments.

All investment advisers have a fiduciary duty to their clients—a legal obligation to act in clients’ best interests. Rule 204A-1 requires employees
to pre-clear two types of securities: initial public offerings (“IPO”) and private placements. Most individuals rarely have the opportunity to invest
in these types of securities, and such a purchase could raise questions as to whether the employee is misappropriating an investment opportunity
that should first be offered to eligible clients.

Advisers often go further and set stricter personal trading requirements than Rule 204A-1 mandates, such as the pre-clearance of many types of
securities, including stocks, options, and bonds. Many also: (1) prohibit or require pre-clearance of securities that the adviser trades on clients’
behalf; (2) establish “watch lists” or “restricted lists” of securities employees may not trade; and (3) set minimum holding periods to restrict
“short-swing” trades. This more conservative approach is commonly treated as an industry best practice; these days, it’s considered “off-market”
for an adviser to solely require pre-clearance of IPOs and private placements. In fact, some firms ban personal trading entirely or allow employees
to buy and sell open-ended mutual funds only. Best practices aside, advisers take a more restrictive stance because it can allow them to better
ascertain any misuse of potential material non-public information (“MNPI”), ensure clients are being treated fairly, and help to gauge whether
any employees are spending a disproportionate amount of their work hours on personal trading.

Despite best efforts by advisers and employees, sometimes personal trading violations happen, even if unintentionally. In Michael’s case, he was
distracted and told his financial advisor to execute the proposed purchase of IP shares. Based on the fact pattern, Michael did not have any MNPI
about IP, and IP is most certainly not an emerging company in the technology space (on which DMC focuses). Nonetheless, since the DMC Code
requires pre-clearance of all personal trades, Michael should have pre-cleared the trade.

It is in DMC’s discretion to determine the consequences of Michael’s violation. At the very least, Rule 204A-1 requires any violations of the
Code to be reported to the Chief Compliance Officer or designated employee. DMC will formally document the violation and, if Michael’s a
repeat offender, DMC’s compliance team may inform other senior DMC members of his violation, such as his boss, Jan, and potentially impose a
monetary fine, require Michael to unwind the position, or, in more extreme cases, ban Michael from engaging in personal trading for a set period.
Whatever the case, DMC must document and discuss the violation with Michael to seek to prevent future pre-clearance errors. Ultimately, DMC
should aim to demonstrate to the SEC that it took reasonable action to enforce its Code and to seek to deter future violations.
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1560 Sherman Avenue | Suite 960 | Evanston, IL | 60201 | P. 847-328-4961 | F. 847-328-4676 | www.evanstoncap.com
What can Michael do next time? Other than remembering to pre-clear trades in the future, he could consider opening a managed account with
his financial advisor. Rule 204A-1 excepts employees from pre-clearing trades in securities accounts over which the employee has no direct or
indirect influence or control, and the SEC issued further guidance on such arrangements in June 2015.6 So long as Michael’s financial advisor
has full discretion over the account, and Michael never suggests or directs trades or consults with the financial advisor on particular allocations
of investments in that account, Michael won’t need to worry about submitting pre-clearance requests for trades (other than IPOs and private
placements) in that particular account.

In addition, improvements in technology have allowed for better monitoring of personal security holdings and trades. Compliance software can
directly link an access person’s brokerage accounts to an online feed and allow firms to go entirely paperless in their monitoring and approval
processes. This technology can improve an investment adviser’s ability to enforce its Code and make the process easier for employees, advisers,
and regulators.

Issue # 2: Gifts & Entertainment


“Presents are the best way to show someone how much you care. It’s like this tangible thing that you can point to and say, ‘Hey, man, I love
you this many dollars’ worth.’”

– Michael Scott

Presents are great, but ultimately, the major concern for regulators and investment advisers is the conflicts of interest they can engender.
Because the Advisers Act does not specifically address gifts and entertainment (“G&E”), regulators look to Section 206, the anti-fraud provision,
and, more generally, an adviser’s fiduciary duty to its clients. Practically, investment advisers often incorporate G&E policies in their Codes based
on what’s considered industry standard and set caps accordingly. Advisers that have employees who are registered representatives of a broker
dealer will also look to FINRA Rule 3220, which sets a $100 yearly limit on gifts given and/or received. It’s also common for advisers to list some
exclusions to their gifts policy, such as gifts or promotional items of nominal value.

It’s important that a G&E policy be tailored to the adviser’s business and that advisers seek to ensure any G&E given or received is not lavish or
excessive in nature. For example, an adviser in New York typically will have higher dollar limits for G&E given the cost of living there versus, say,
Scranton, PA. Advisers conducting business with state and local pension plans and unions should have their G&E policy address the adviser’s
approach to state and local rules for soliciting investment advisory business from public plans and any ethical rules the public plans themselves
may have in place. Similarly, G&E to unions will trigger compliance with U.S. Department of Labor rules and may also trigger additional reporting.
In Michael’s case, DMC’s G&E cap is $250/per person for entertainment received; the Michelin dinner was $400/per person. The DMC Code
requires G&E above $250 to be pre-cleared, and Michael and Jan knew about the dinner in advance; it was not an impromptu event. If Michael,
Jan, or another employee mention the dinner to the compliance team, or it’s discovered via forensic testing, DMC’s compliance team certainly
would speak to Michael and Jan of their responsibility to pre-clear under the DMC Code and create a record of this violation in DMC’s compliance
files.

While G&E dollar limits are helpful to set bright-line rules for adviser’s employees, determining whether G&E could be reasonably construed as
“lavish or excessive” and trigger additional steps to seek to “cure” a G&E violation requires consideration of the facts and circumstances. Michael
and Jan exceeded DMC’s G&E cap by $150 each; is it reasonable to think that these amounts would incentivize Michael and Jan to continue
investing in BVS (versus, for example, Super Bowl tickets)? Likely not. But Bob Vance explicitly stated at dinner that continued investment in
BVS would mean more fancy dinners. Since Jan decided to reduce DMC’s BVS investment the following day, clearly Jan was not influenced by
Bob’s dinner.

Imagine instead that Jan had recommended increasing DMC’s investment in BVS. In that case, it’s still not clear that the fancy dinner had unduly
influenced Jan, but because her decision would be tainted by Bob’s comments, DMC’s compliance team may have wanted, in that circumstance,
to reimburse BVS for the additional $300 above the $250/per person cap. Now imagine that Bob had made this statement when he first issued
the invitation to Jan and Michael; the dinner would appear to have been designed to unduly influence them, and Jan and Michael should have
declined outright.

6
https://www.sec.gov/investment/im-guidance-2015-03.pdf
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1560 Sherman Avenue | Suite 960 | Evanston, IL | 60201 | P. 847-328-4961 | F. 847-328-4676 | www.evanstoncap.com
Issue # 3: Political Contributions
“And I knew exactly what to do. But in a much more real sense, I had no idea what to do.”

– Michael Scott

Investment advisers provide advisory services to a large assortment of investors, including U.S. state and local pension funds. As of year-end
2018, assets in state and local government public pension plans totaled over $9 trillion.7 In 2010, the SEC finalized rule 206(4)-5 of the Advisers
Act, known colloquially as the “pay to play rule.” Public pension plans are administered and managed by government officials who, in turn, often
can appoint or influence the selection of investment advisers to manage these assets for millions of employees and retirees. Given public pension
plans’ asset size, the SEC expressed concern that such state or local government officials would select investment advisers not out of merit or fit,
but to reward them for donating to their election campaigns and that investment advisers would engage in this quid pro quo for the opportunity
to manage a public pension plan’s assets.

Rule 206(4)-5 applies to donations to state and local government officials and is designed to curb pay to play—broadly speaking, it prohibits
investment advisers that make non-de minimis contributions to such government officials’ campaigns from receiving any compensation for the
first two years after the contribution. Under the Rule, de minimis contributions equal a maximum of $350 per election to a candidate the adviser’s
employee is eligible to vote for and $150 per election to a candidate for whom the employee is ineligible to vote. The two year “cooling off” period
is meant to lessen the influence that an adviser’s campaign donation may have had on a government official.

Michael’s decision to go straight to the compliance department with his questions is the right instinct, as Rule 206(4)-5 is nuanced and involves
various considerations. The good news for Michael is that he’ll be able to donate to Pam’s and Angela’s campaigns once he submits pre-clearance
requests. The question is, how much? The DMC Code caps political contributions using the de minimis amounts set by Rule 206(4)-5. Although
not mandated under Rule 206(4)-5, it’s common for advisers to require that any political contribution dollar amount, even those under the de
minimis threshold, be pre-cleared. This makes it easier for an investment adviser to track an employee’s contributions over time to ensure he or
she does not exceed the de minimis amount per election.

Since Michael can’t vote for Pam and Angela because he does not live in New York, the $150 cap appears to apply on its face. However, Michael
needs to consider the public office (if any) that the candidates he wants to support currently hold, as well as the public office they are running
for, to determine whether any of these are state or local government positions and, therefore, subject to Rule 206(4)-5. In Pam’s case, she is
running for U.S. Senator, a federal office; however, because she currently holds a state government position, Rule 206(4)-5 applies to her Senate
election campaign. Using the SEC’s rationale in the Rule 206(4)-5 final rule release, an incumbent state or local official like Pam could influence
the hiring of DMC as a function of her current role as NYS Treasurer; likewise, if she loses her bid for the Senate, she could influence DMC’s hiring
in her continued role as NYS Treasurer. Michael will be able to donate a maximum of $150 to Pam’s campaign. In Angela’s case, she is a New
York Congresswoman running for re-election. Because Angela currently holds federal office, and is running for re-election to this federal office,
Rule 206(4)-5 does not apply to Angela’s campaign. Michael will be able to donate more than the de minimis amount to Angela’s congressional
campaign.

Rule 206(4)-5 has many nuances that are not covered by the fact pattern; for example, we assumed Michael was a “covered associate” to whom
the rule applies. Covered associates are typically defined as executive officers of a firm, or employees who have a similar status or function, as
well as employees who solicit government entities and/or supervise employees who do so. The rule also has restrictions on directly or indirectly
soliciting and/or coordinating any person or political action committee to make contributions or payments. Given that an investment adviser
would forfeit acceptance of any fees or other compensation for providing advisory services to a government client for two years if Rule 206(4)-5
is incorrectly applied, it’s very important that employees promptly consult with their compliance department on how to proceed with any desired
political contributions.

7
Board of Governors of the Federal Reserve System, Flow of Funds Accounts of the United States, Flows and Outstandings, Fourth Quarter 2018, 99 tbl.L.120 (Mar.
7, 2019).
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1560 Sherman Avenue | Suite 960 | Evanston, IL | 60201 | P. 847-328-4961 | F. 847-328-4676 | www.evanstoncap.com
Communication Is Key to Achieving a Code’s Purpose
“Would I rather be feared or loved? Easy – both. I want people to be afraid of how much they love me.”

– Michael Scott

While we wouldn’t take it as far as Michael, we strongly encourage employees to regularly communicate with their compliance team. Regulators
don’t embrace the saying that it’s easier to ask for forgiveness than to get permission, and a proactive approach is particularly important to head
off potential issues before they arise and to better understand a Code’s nuances. For example, an employee may know their Code’s standard
entertainment cap but may not recall offhand how these limits change for union officials because she doesn’t frequently host such investors.
Compliance teams often know the Code inside and out, and we encourage employees to leverage that knowledge.

OPERATIONS AND ADMINISTRATION

Jake Gorobetz, an Associate on our client service team, left ECM in June to return to the East Coast. We wish Jake much future success.

As always, we would welcome your comments and questions about any of these items. We appreciate your support and trust, and we look forward
to continuing to work for the benefit of our aligned interests.

Regards,

The Evanston Capital Team


Evanston Capital Management, LLC
(847) 328-4961
investorrelations@evanstoncap.com

10

1560 Sherman Avenue | Suite 960 | Evanston, IL | 60201 | P. 847-328-4961 | F. 847-328-4676 | www.evanstoncap.com
IMPORTANT FUND INFORMATION AND DISCLOSURES
The Fund is a continuously-offered, non-diversified, registered closed-end fund with limited liquidity. The Fund’s shares are subject to legal
restrictions on transfer and resale and you should not assume you will be able to resell your shares. No assurance can be given that the Fund will
achieve its objectives. This quarterly letter does not constitute an offer to sell or a solicitation of an offer to purchase the Fund’s securities. Any
such offer will be made only by means of the Fund’s Prospectus.
The hedge fund strategy classification of each of the Fund’s underlying portfolio funds used to calculate contribution to performance as shown
on page 2 is determined by ECM in its discretion. Totals may not sum due to rounding.
The contents of this Fund quarterly letter are solely for informational purposes, are current as of the date set forth on this quarterly letter, and are
subject to change from time to time. Neither the Fund nor ECM is obligated to notify you of changes to this information.
Certain statements made herein constitute forward-looking statements. These statements reflect ECM’s current views about, among other
things, future events and financial performance, and results may differ, possibly materially, from these statements. Neither ECM nor the Fund is
obligated to update or revise the statements made or information presented herein.
Fund Liquidity/Tenders: The Fund intends to conduct quarterly tender offers. Each repurchase offer is expected to be limited to the repurchase
of approximately 5-25% of the outstanding shares, in the Board of Trustees’ discretion. No Fund investor can require the Fund to redeem shares,
regardless of how the Fund performs.
Early Withdrawal Fee: Shareholders who seek to sell their shares back to the Fund less than one year after purchasing the shares will be subject
to a 3% early withdrawal fee payable to the Fund.
Fund Fees and Expenses:
Portfolio Fund Fees and Expenses: The Fund is a “fund of funds” that invests in Portfolio Funds managed by Portfolio Managers unaffiliated with
ECM. Portfolio Funds’ management fees range from approximately 1% to 3% per annum, and incentive fees that a Portfolio Fund may charge
range from approximately 15% to 35% of profits per annum.8 Portfolio Fund fees and expenses may be substantially higher or lower as a result
of the Fund’s investments in new or different Portfolio Funds. The Fund anticipates that its total annual expenses, taking into account the
Expense Limitation Agreement and the Portfolio Fund fees and expenses, but excluding any sales load that may be assessed, will be approximately
5.93% with respect to Class I and 6.68% with respect to Class A, as described in detail in the Fund’s Prospectus. Actual expenses may be higher
or lower than estimates provided due to the Portfolio Funds’ fees and expenses.
Distribution and Service Fee. The Fund pays Foreside Fund Services, LLC (the “Distributor”) a distribution and/or service fee equal to 0.75% per
annum of the aggregate value of the Class A shares outstanding, determined as of the last calendar day of each month (prior to any repurchases
of shares and prior to the Fund’s management fee (“Management Fee”) being calculated) (“Distribution and Service Fee”) in accordance with a
plan adopted by the Fund in compliance with the provisions of Rule 12b-1 under the Investment Company Act of 1940, as amended (the “1940
Act”). The Distribution and Service Fee is payable quarterly, and the Distributor pays all or a portion of the Distribution and Service Fee to certain
financial intermediaries. ECM also pays a fee out of its own resources to financial intermediaries. Please see the Fund’s Prospectus for more
detailed information.
Management Fee and Management Fee Waiver. ECM contractually agreed to waive a portion of the Management Fee from July 1, 2014 through
June 30, 2015, such that it equaled 0.90% per annum (the “Management Fee Waiver”) for such period. Class I’s performance data through June
30, 2015 is shown net of the reduced 0.90% Management Fee. From July 1, 2015 through December 31, 2018, the Management Fee Waiver was
terminated, and performance for Class I is shown net of a 1.2% Management Fee during such period. Effective January 1, 2019, Class I’s
Management Fee is 1.0% per annum.
Performance shown prior to Class A’s inception date (06/01/2015) is based on the performance of Class I Shares, adjusted to reflect Class A’s fees
and expenses. Performance shown through December 31, 2018 for Class A reflects a Management Fee of 1.20% per annum. Effective January 1,
2019, Class A’s Management Fee is 1.0% per annum with a distribution and service fee of 0.75% per annum.
Expense Reimbursement. Effective January 1, 2019 through July 31, 2020, ECM has contractually agreed to limit the Fund’s total annualized
expenses (excluding any borrowing and investment-related costs and fees, taxes, extraordinary expenses, and the Portfolio Fund Fees and
Expenses) to 1.5% with respect to Class I and 2.25% with respect to Class A (the “Expense Limitation Agreement”). Prior to January 1, 2019, ECM
had contractually agreed to limit the Fund’s total annualized expenses to 1.7% with respect to Class I and 2.45% with respect to Class A. ECM
and the Fund may continue to renew the Expense Limitation Agreement for one-year terms thereafter, and may terminate it with 30 days’ prior
written notice to the other party. ECM will be permitted to recover from the Fund expenses it has borne in later periods, if Class I and Class A’s
expenses fall below the annual rate of 1.5% and 2.25%, respectively. The Fund is not obligated to pay any such amount more than 3 years after
the fiscal year-end in which ECM deferred a fee or reimbursed an expense.
Please review the Fund’s Prospectus for information about other fees, including the Fund’s operating expenses.
Additional Fund Exposures Information: The Fund and Portfolio Fund exposures generally reflect the value of cash positions as well as the
economic value of underlying positions, including derivatives positions such as futures and options. ECM has not received the most recent
exposures from the majority of the Portfolio Funds as of the date hereof. Consequently, the most recent exposure information previously received
by ECM for such Portfolio Funds is used herein.

8
The Portfolio Fund Fees and Expenses are estimated to be approximately 4.43%.
11

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STRATEGY DEFINITIONS
Long-Short Equity: Seek to profit by taking positions in equities and generally involve fundamental analysis in the investment decision process.
Long-short equity strategies may aim to have a net long directional bias, a net short directional bias, or be neutral to general movements in the
stock market. Long-short equity Portfolio Managers tend to be “stock pickers” and typically shift allocations between long and short investments
based on market conditions and outlook.
Event Driven: Seek to invest in opportunities that are created by significant transaction events, such as spin-offs, mergers and acquisitions, and
reorganizations.
Relative Value: Seek to profit by exploiting pricing inefficiencies between related instruments, while remaining long-term neutral to directional
price movements in any one market. Short selling is an integral part of this strategy.
Global Asset Allocation: Seek to exploit opportunities in various global markets. Portfolio Funds employing these strategies have a broad mandate
to invest in markets and instruments they believe provide the best opportunity.
INDEX AND OTHER DEFINITIONS
An investor cannot invest in an index. Please note that the indices or performance benchmarks below are composed of securities which for the
most part are dissimilar to the positions held directly or indirectly by the Fund, and these indices or benchmarks do not have similar risk/return
profiles to that of the Fund. However, these indices or benchmarks have been included herein because they represent various asset classes to
which an investor may choose to compare the Fund’s performance.
90-Day T-Bill: rate of return is derived from cash-equivalent securities.
Barclays Aggregate Bond Index: comprises government securities, mortgage-backed securities, asset-backed securities and corporate securities,
and is a broad measure of the taxable U.S. bond market.
CBOE Volatility Index (VIX Index): is considered by many to be the world’s premier barometer of equity market volatility. The VIX Index is based on
real-time prices of options on the S&P 500 Index (SPX) and is designed to reflect investors’ consensus view of future (30-day) expected stock
market volatility.
HFRI FOF Composite Index: is an index composed of funds of funds that voluntarily report their performance to HFR.
HFRI Asset Weighted Composite Index: is a global, asset-weighted index comprised of over 1,500 single-manager funds that report to HFR
Database.
BofAML US High Yield Master II Index: tracks the performance of US dollar denominated below investment grade rated corporate debt publicly
issued in the U.S. domestic market.
EURO STOXX: is Europe’s leading blue-chip index for the Eurozone, providing a blue-chip representation of super-sector leaders in the region. The
index covers 50 stocks from 11 Eurozone countries.
MSCI AC Asia Pacific: is a free-float weighted equity index. It was developed with a base value of 100 as of Dec. 31, 1987.
MSCI EAFE Index: is a free float-weighted equity index that captures large and mid-cap representation across developed markets, excluding U.S.
and Canada.
MSCI EM: is a free-float weighted equity index that captures large and mid-cap representation across Emerging Markets (EM) countries. The
index covers approximately 85% of the free float-adjusted market capitalization in each country.
MSCI World Index: is a free float-adjusted market capitalization weighted index that is designed to measure the equity market performance of
developed markets.
NASDAQ Biotech: is a modified market cap-weighted index designed to measure the performance of all NASDAQ stocks in the biotechnology
sector with a base value of 200 as of Nov. 1, 1993.
NASDAQ Composite Index (NASDAQ): is a broad-based capitalization-weighted index of stocks in all three NASDAQ tiers: Global Select, Global
Market, and Capital Market. The index was developed with a base level of 100 as of February 5, 1971.
Nikkei 225: is a price-weighted average of 225 top-rated Japanese companies listed in the First Section of the Tokyo Stock exchange.
Russell 1000 Growth: measures the performance of those Russell 1000 companies with higher price-to-book ratios and higher forecasted growth
values. The index was developed with a base value of 200 as of August 31, 1992.
Russell 2000: is composed of the smallest 2000 companies in the Russell 3000 Index, representing approximately 8% of the Russell 3000 total
market capitalization. The index was developed with a base value of 135.00 as of December 31, 1986.
Russell 2000 Biotechnology Index: is composed of the smallest Biotechnology companies in the Russell 3000 index.
S&P Energy: is a capitalization-weighted index and GICS Level 1 sector group.
S&P 500 Index: is composed of 500 publicly traded stocks representing all major U.S. industries.
S&P Healthcare: is a market cap-weighted index. The index comprises stocks included in the S&P 500 that are classified as members of the GICS
Healthcare sector.
S&P 500 Information Technology Index: comprises those companies included in the S&P 500 that are classified as members of the GICS®
information technology sector.
Shanghai Stock Exchange Composite Index: is a capitalization-weighted index. The index tracks the daily price performance of all A-shares and
B-shares listed on the Shanghai Stock Exchange. 12

1560 Sherman Avenue | Suite 960 | Evanston, IL | 60201 | P. 847-328-4961 | F. 847-328-4676 | www.evanstoncap.com
Alpha: Measures a manager’s value added relative to a passive strategy, independent of the market movement.
Beta: is measured versus the relevant index.
Sharpe Ratio: is a measure of risk-adjusted returns and is defined as the excess return over cash per unit of volatility.
IMPORTANT RISK FACTORS CONCERNING THE FUND
As described in the Fund’s Prospectus and Statement of Additional Information, an investment in the Fund is speculative, involves a substantial
degree of risk, and an investor could lose all or substantially all of his or her investment. There can be no assurance the Fund will achieve its
investment objectives or avoid significant losses. The Fund is only available to “eligible investors” who can bear significant risk and do not
require a liquid investment. Please see the Fund’s Prospectus for important information about the Fund’s terms, risks, and other disclosures.
The Fund’s Portfolio Managers may, in some cases, be recently organized or may manage Portfolio Funds that are recently organized and have no
or a very limited operating and performance history. The Fund is managed by ECM, and its success will depend, in large part, on ECM’s skill and
expertise. While ECM has over 15 years managing privately offered fund of hedge fund products, ECM has not previously managed a registered
investment company.
The Fund’s shares are subject to restrictions on transfer and have limited liquidity. The Fund does not list its shares for trading on any national
securities exchange; there is no secondary market for the shares, and none is expected to develop. An investment in the Fund’s shares is not
suitable for investors that require liquidity, other than liquidity provided through the Fund’s repurchase policy. There can be no guarantee that an
investor will be able to sell any of its shares when it desires to do so. The Fund’s repurchase offer policy may decrease its size over time absent
significant new investments in the Fund. It could force the Fund to maintain more liquid investments, sell assets prematurely, substantially
increase the Fund’s ratio of illiquid to liquid securities for non-redeeming investors, and/or reduce the investment opportunities available to the
Fund and cause its expense ratio to increase.
The Portfolio Funds are not registered under the 1940 Act, and therefore are not subject to the 1940 Act’s restrictions and protections, such as
fee limitations, asset coverage requirements, and reporting requirements. The Portfolio Managers may use investment strategies and techniques
that are not generally permissible for registered investment companies, and Portfolio Funds may be less transparent in providing portfolio holding
and valuation information.
ECM relies on the valuation of the Portfolio Funds to value the Fund’s shares. Fair value estimates may prove to be inaccurate and may be subject
to later adjustments from time to time. Similarly, inaccurate or delayed information that a Portfolio Manager may provide could adversely affect
ECM’s ability to accurately value the Fund’s shares.
The net asset values received by ECM or the Fund’s administrator from Portfolio Funds may be estimates only, and, unless materially different
from the actual valuations, generally will not be subject to revision. ECM relies on these estimates in calculating the Fund’s net asset value for,
among other things, reporting the performance data reflected herein. Portfolio Funds are typically audited on an annual basis.
The Fund may borrow money for portfolio management and other purposes, and may have to pledge assets when borrowing, which could affect
the Fund’s operations in the event of an uncured default. The Portfolio Funds may use leverage to purchase instruments, sell securities short,
and/or other means, which would increase any loss incurred. Consequently, the Portfolio Funds may be subject to major losses if market
disruptions destroy any hedged positions, which would negatively impact the Fund’s performance.
The Fund intends to meet the requirements necessary to qualify for favorable tax treatment as a “regulated investment company,” or “RIC” under
Subchapter M of the Internal Revenue Code. If the Fund fails to satisfy the applicable requirements, it may lose its status as a regulated investment
company, and in such case, all of its taxable income would be subject to U.S. federal income tax at regular corporate rates without any deduction
for distributions to shareholders. Disqualification as a RIC would have a material adverse effect on the value of the Fund’s shares and the Fund’s
distribution amounts.
You should consult with your own legal, tax, financial, and other professional or advisers before investing in the Fund.
Before investing, you should consider carefully the Fund’s investment objectives, limited liquidity, risks, charges, and expenses. The prospectus
contains this and other information about this investment company. You can obtain a copy of the prospectus by contacting ECM at
investorrelations@evanstoncap.com or calling 847-328-4961 or by requesting a copy from your financial professional. Please read the
prospectus carefully before you invest.

13

1560 Sherman Avenue | Suite 960 | Evanston, IL | 60201 | P. 847-328-4961 | F. 847-328-4676 | www.evanstoncap.com

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