Shelter Growth Capital Partners LLC

Item 5 - Fees and Compensation
A. Fees charged to the Funds are detailed in the Fund documents. In the case of SMA’s, fees are separately
   negotiated and described in the investment management agreement for each SMA, as applicable. In
   general, SGCP typically charges both management fees and incentive fees to Clients.

B. SGCP deducts management fees periodically in advance from the Funds. This process is more fully
   described in the fund documents for each Fund. SMA fees are separately negotiated and are billed to,
   and payable by, each SMA in arrears pursuant to the investment management agreement. This process
   may vary from SMA to SMA.

C. Certain specific operating expenses incurred by Clients may be paid by SGCP and reimbursed by the
   Clients or in the case of the Funds, paid directly from the Funds by a fund administrator. These fees and
   expenses are detailed in the Fund documents for each Fund or investment management agreement for
   each SMA.

D. Management fees that are paid in advance are generally not refundable, and management fees that are
   paid in arrears are paid through the date of termination.

E. Neither SGCP nor any of its supervised persons accepts compensation for the sale of securities or other
   investment products.

   Clients managed by SGCP periodically enter into transactions with its affiliates, SG Capital Partners LLC,
   ClearEdge Lending LLC, or another affiliate. Clients purchase residential mortgage and commercial real
   estate loans or other structured credit assets from SG Capital Partners LLC, ClearEdge Lending LLC or
   another affiliate from time to time for investment purposes. Each such transaction is a “principal
   transaction” for purposes of Section 206(3) of the Investment Advisers Act of 1940 (the “Advisers Act”).
   SGCP has adopted a policy for Funds managed by SGCP to address these transactions that consists of
   a third-party valuation company valuing any assets transferred and a committee of individuals
   unaffiliated with SGCP and acting on behalf of SGCP Clients reviewing and approving in writing in
   advance based on the valuation all transactions between Funds managed by SGCP and its affiliates.

   SGCP receives loan transaction servicing fees per loan in connection with Clients that purchase
   residential mortgage loans.

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Shelter Growth Capital Partners LLC Form ADV: Part 2A

Item 7 - Types of Clients
SGCP provides advice to pooled investment vehicles for institutional and high net worth investors and SMAs
(as described in Item 4 above). Funds managed by SGCP have various minimum investment amounts as
more fully described in the respective Fund documents.

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Shelter Growth Capital Partners LLC Form ADV: Part 2A