Disruptive Technology Advisers Llc

Allegations: PLAINTIFFS ALLEGE PALANTIR AND DISRUPTIVE TECHNOLOGY ADVISERS LLC (COLLECTIVELY, THE "DEFENDANTS") TORTIOUSLY INTERFERED WITH A SECONDARY STOCK TRANSACTION IN WHICH PLAINTIFFS HOPED TO SELL PALANTIR SHARES TO A PROSPECTIVE BUYER. PLAINTIFFS ALSO ALLEGE THAT DEFENDANTS CONSPIRED TO DIVERT THE PROSPECTIVE BUYER SO THAT DEFENDANTS COULD APPROPRIATE THE STOCK TRANSACTION FOR THEMSELVES. Status: Pending Summary: THE CASE WAS SETTLED PRIOR TO THE COURT DATE AND THE SETTLEMENT AGREEMENT WAS EXECUTED BY THE PARTIES ON JULY 25, 2022. THE TERMS OF THE CONFIDENTIAL SETTLEMENT ARE UNDISCLOSED

Allegations: ON SEPTEMBER 5, 2023, DISRUPTIVE WAS THE SUBJECT OF AN ORDER FROM THE U.S. SECURITIES AND EXCHANGE COMMISSION. FOR PURPOSES OF THE ORDER, DISRUPTIVE WITHOUT ADMITTING OR DENYING THE FINDINGS WAS FOUND TO HAVE VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND SECTION 204(A) OF THE INVESTMENT ADVISERS ACT OF 1940, AS AMENDED, BETWEEN 2019 AND 2021, BY FAILING TO TIMELY DISTRIBUTE FUND AUDITED FINANCIAL STATEMENTS, UPDATE ITS FORM ADV UPON DISTRIBUTION, AND PROPERLY MAINTAIN REPRESENTATION OF FUND ASSETS WITH A QUALIFIED CUSTODIAN. AT NO TIME WERE INVESTOR ASSETS EXPOSED OR AT RISK. DISRUPTIVE WAS CENSURED, ORDERED TO CEASE AND DESIST AND DIRECTED TO PAY A $225,000 CIVIL MONEY PENALTY. UPON BECOMING AWARE OF THE EVENTS GIVING RISE TO THIS ORDER, DISRUPTIVE IMPLEMENTED ENHANCED PROCEDURES TO PREVENT ANY FUTURE DELAYS IN THE DISTRIBUTION OF AUDITED FINANCIAL STATEMENTS AND RELATED UPDATES TO ITS FORM ADV AS EVIDENCED BY DISRUPTIVE'S TIMELY DISTRIBUTION OF 2022 AUDITED FINANCIAL STATEMENTS FOR ALL FUNDS IN CALENDAR YEAR 2023 AND THE CORRESPONDING UPDATE TO ITS FORM ADV. DISRUPTIVE FOLLOWS INDUSTRY STANDARD FOR PRIVATE SECURITIES TO ENSURE ITS FUNDS' ASSETS OWNERSHIP IS PROPERLY RECORDED WITH UNDERLYING ISSUER COMPANIES, INVESTEE FUNDS, OR ASSET PURCHASE CONTRACTS. Status: Final Sanction Detail: ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER Summary: WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, DISRUTPIVE CONSENTED TO THE ENTRY OF AN ORDER BY WHICH IT AGREED TO: (I) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(4) AND 204(A) OF THE ADVISERS ACT; (II) BE CENSURED; AND (III) PAY THE CIVIL PENALTY.