Buena Vista Fund Management, Llc.

Buena Vista Fund Management, LLC, established in July 1998, offers discretionary investment advisory services to private investment funds, focusing on undervalued securities primarily in Asian markets, with a fundamental strategy emphasizing economic earnings. The firm, led by Robert M. Rosner, operates with full investment discretion and manages assets totaling $525,836,768 as of December 31, 2020. The management fee structure for the funds varies, with a temporary 10% reduction in fees from October 2021 to December 2022. Buena Vista does not participate in wrap fee programs and provides investment advice to pooled investment vehicles without a minimum account value requirement. The firm conducts independent research, including company evaluations and cash flow modeling, to inform investment decisions. Risks associated with the investment strategy include non-U.S. market volatility, currency fluctuations, and small-cap stock investments. Buena Vista's Code of Ethics prioritizes client interests and compliance with securities laws. The firm may use soft dollars for research and brokerage services and has no directed brokerage arrangements. Clients receive annual audited financial statements, monthly performance summaries, and quarterly investment letters. Buena Vista has custody of client assets through a Prime Broker and exercises full discretion over investment portfolios. The firm also has authority to vote on client securities and has no financial conditions that could impact its ability to manage client accounts.