Obra Capital Management, Llc.

Allegations: THE PLAINTIFFS ALLEGE THAT THE DEFENDANTS VIOLATED THE TEXAS SECURITIES ACT ("TSA") BY MISREPRESENTING AND/OR FAILING TO DISCLOSE WEAKNESSES IN THE FUND'S INTERNAL PROCESSES AND PROCEDURES IN THE OFFERING MATERIALS.THE PLAINTIFFS ALSO ASSERT A CLAIM THAT DEFENDANTS FAILED TO DISCLOSE ALLEGED MATERIAL CONFLICTS OF INTEREST PERTAINING TO INFORMATION THAT THEY BELIEVE WAS MATERIAL TO INVESTORS AND SHOULD HAVE BEEN PROVIDED TO INVESTORS PRIOR TO MAKING A DECISION AS TO WHETHER TO INVEST IN THE FUND. Status: Final Summary: MARCH 2021 CLASS ACTION LAWSUIT FILED IN THE U.S. DISTRICT COURT FOR THE DISTRICT OF DELAWARE (GENERALLY REFERRED TO HEREIN AS THE "COMPLAINT"). DEFENDANTS CONSIST OF THE VIDA LONGEVITY FUND, LP ("VLF") AND CERTAIN AFFILIATED ENTITIES AND JEFFREY R. SERRA (COLLECTIVELY, THE "DEFENDANTS"). COMPLAINT GENERALLY ALLEGES THAT, IN VIOLATION OF THE TEXAS SECURITIES ACT, THE DEFENDANTS FAILED TO DISCLOSE ALLEGEDLY MATERIAL INFORMATION RELATING TO VLF'S PURPORTED LACK OF ADEQUATE / WEAKNESS IN PROCESSES AND PROCEDURES TO EVALUATE (I.E., UNDERWRITE AND ASSESS RISK) ITS LIFE SETTLEMENT ASSETS AND PURPORTED CONFLICTS OF INTEREST. THE INVOLVED PARTIES HAVE CONTINUED TO MAKE POSITIVE FORWARD PROGRESS IN NEGOTIATING SETTLEMENT TERMS. THE PLAINTIFF'S / PLAINTIFF'S COUNSEL MOVED THE COURT FOR I) PRELIMINARY APPROVAL OF THE PROPOSED SETTLEMENT, II) FOR AUTHORIZATION TO SEND NOTICE TO THE SETTLEMENT CLASS, AND III) FOR THE SCHEDULING OF A FAIRNESS HEARING. THE COURT PROVIDED PRELIMINARY APPROVAL OF THE SETTLEMENT AND ITS TERMS ON NOVEMBER 21, 2022. NOTICES WITH ADDITIONAL INFORMATION FOR ALL SETTLEMENT CLASS MEMBERS RELATED TO THE TERMS OF THE SETTLEMENT AND ANY ACTIONS TO BE TAKEN WERE PROVIDED TO CLASS MEMBERS. THE COURT SET A FINAL FAIRNESS HEARING ON THE MATTER SCHEDULED FOR APRIL 18, 2023. THE COURT HELD THE NOTED HEARING ON APRIL 18, 2023 AND REQUESTED A SHORT SUPPLEMENTAL BRIEF FROM THE PLAINTIFF'S COUNSEL RELATING TO RESPONSE RATES. THAT SUPPLEMENTAL FILING OCCURRED ON APRIL 21, 2023, AND THE PARTIES ARE WAITING FOR THE COURT TO ISSUE ITS ORDER ON THE MATTER. THAT SUPPLEMENTAL FILING OCCURRED ON APRIL 21, 2023, AND ON MAY 2, 2023, THE COURT ENTERED AN ORDER APPROVING CLASS ACTION SETTLEMENT.

Allegations: THE PLAINTIFF ALLEGES THAT THE DEFENDANTS OVERVALUED A PORTION OF VIDA LONGEVITY FUND'S ("VLF") LIFE SETTLEMENT ASSETS FROM 2017 UNTIL LATE 2020, AND CLAIMS THAT THIS RESULTED IN A BREACH OF FIDUCIARY DUTY OF LOYALTY TO VLF IN NOT PROPERLY VALUING THE PORTFOLIO AND RESULTING IN VLF PAYING EXCESSIVE MANAGEMENT FEES AND PERFORMANCE FEES, WHICH BENEFITED CERTAIN DEFENDANTS. THE PLAINTIFF ALSO ALLEGES THAT THE NAMED INDIVIDUAL DEFENDANTS UNJUSTLY ENRICHED THEMSELVES THROUGH REDEMPTIONS WHEN VALUATIONS WERE ALLEGEDLY INFLATED. Status: Final Summary: ON SEPTEMBER 28, 2021, A COMPLAINT WAS PUBLICLY FILED ON BEHALF OF VIDA LONGEVITY FUND ("VLF") NAMING AS DEFENDANTS CERTAIN AFFILIATED ENTITIES OF VIDA CAPITAL MANAGEMENT, LLC, AS WELL AS JEFFREY R. SERRA, WILLIAM TICE AND DAN YOUNG, AS INDIVIDUAL DEFENDANTS, AND NAMING VLF AS A NOMINAL DEFENDANT. THIS DERIVATIVE LAWSUIT WAS FILED IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE, CAPTIONED THE MOLLER FAMILY TRUST, DERIVATIVELY AND ON BEHALF OF VIDA LONGEVITY FUND, LP VS. VIDA MANAGEMENT I, LLC, VIDA CAPITAL MANAGEMENT, LLC, VIDA CAPITAL, INC., VIDA CAPITAL, LLC, JEFFREY R. SERRA, DAN YOUNG AND WILLIAM TICE AND VIDA LONGEVITY FUND, LP, A NOMINAL DEFENDANT, CIVIL ACTION NO. 2021-0823-MTZ. THIS DERIVATIVE LAWSUIT IS BASED ON ALLEGATIONS THAT OVERLAP WITH THOSE IN THE PREVIOUSLY DISCLOSED SECURITIES CLASS ACTION COMPLAINT IN O'HERN, ET AL. V. VIDA LONGEVITY FUND, LP, ET AL., FILED IN MARCH 2021, ALTHOUGH THE DERIVATIVE SUIT SEEKS RELIEF FOR VLF ITSELF, NOT FOR VLF'S LIMITED PARTNERS (AS THE CLASS ACTION DOES). THE DERIVATIVE COMPLAINT ASSERTS CAUSES OF ACTION BASED ON ALLEGED OVERVALUATION OF A PORTION OF VLF'S LIFE SETTLEMENT ASSETS FROM 2017 UNTIL LATE 2020, AND IT CLAIMS THAT THE NAMED ENTITY DEFENDANTS AND MR. SERRA BREACHED THEIR FIDUCIARY DUTY OF LOYALTY TO VLF IN NOT PROPERLY VALUING THE PORTFOLIO AND IN PAYING EXCESSIVE MANAGEMENT FEES AND PERFORMANCE ALLOCATIONS BASED ON VLF'S PURPORTEDLY INFLATED ASSETS AND PERFORMANCE. THE COMPLAINT ALSO CHARGES THAT THE INDIVIDUAL DEFENDANTS UNJUSTLY ENRICHED THEMSELVES THROUGH REDEMPTIONS WHEN VALUATIONS WERE ALLEGEDLY INFLATED AND THAT VIDA ENTITIES WERE UNJUSTLY ENRICHED THROUGH RECEIPT OF EXCESSIVE MANAGEMENT FEES AND PERFORMANCE ALLOCATIONS. VIDA CAPITAL MANAGEMENT AND THE INDIVIDUAL DEFENDANTS BELIEVE THAT THE FIRM AND THE TEAM OPERATED WITH LIMITED PARTNERS' BEST INTERESTS IN MIND AND THAT ANY CLAIMS OF MISCONDUCT AREUNFOUNDED. THE PARTIES HELD DISCUSSIONS ON THE MERITS OF THE CLAIMS MADE TO SEE IF THERE WAS ANY BASIS FOR A POTENTIAL RESOLUTION THEREOF AND CONDUCTED A MEDIATION SESSION. PRIOR TO THE FINALIZATION OF AN ULITMATE RESOLUTION, THE PLAINTIFF DISMISSED THE MATTER ON JULY 14, 2022. NO FURTHER ACTION HAS BEEN TAKEN AND WE CONSIDER THE MATTER TO BE RESOLVED.

Allegations: THE SEC ALLEGED THAT A FORMER EMPLOYEE OF THE REGISTRANT, IN 2019, MADE A CAMPAIGN CONTRIBUTION TO AN ELECTED OFFICIAL BEFORE BEING HIRED BY THE REGISTRANT, WAS THEN HIRED INTO A POSITION IN WHICH THE INDIVIDUAL BECAME A COVERED ASSOCIATE, AND WITHIN TWO YEARS AFTER THE CONTRIBUTION THE REGISTRANT PROVIDED INVESTMENT ADVISORY SERVICES FOR COMPENSATION TO A STATE PUBLIC PENSION FUND OVER WHICH THE ELECTED OFFICIAL HAD INFLUENCE; THE INVESTMENT PRE-DATED THE CONTRIBUTION. PURSUANT TO AN OFFER OF SETTLEMENT, THE SEC FOUND, AND THE REGISTRANT NEITHER ADMITTED NOR DENIED, THAT THE REGISTRANT VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-5 THEREUNDER. Status: Final Sanction Detail: THE ORDER IMPOSES A CIVIL PENALTY OF $95,000 TO BE PAID WITHIN 10 DAYS OF THE ORDER. Summary: THE SEC ADMINISTRATIVE ORDER IS FINAL, PURSUANT TO THE AUGUST 19, 2024 ORDER DESCRIBED ABOVE. THE CIVIL PENALTY WAS PAID WITHIN 10 DAYS OF THE ENTRY OF THE ORDER.