SELBY LANE CAPITAL, LLC

Part 2A of Form ADV: Brochure Selby Lane Capital, LLC 1300 El Camino Real, Suite 100 Menlo Park, CA 94025 (650) 463-9511 www.selbylane.com Date: March 28, 2025 This brochure (“Brochure”) provides information about the qualifications and business practices of Selby Lane Capital, LLC which is an investment adviser registered with the United States Securities and Exchange Commission (the “SEC”). If you have any questions about the contents of this brochure, please contact us at (650) 463-9511. The information in this Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment adviser with the SEC does not imply any level of skill or training. Additional information about Selby Lane Capital, LLC is also available at the SEC’s website www.adviserinfo.sec.gov (click on the link, select “investment adviser firm” and type in our firm name). i  Item 2: Material Changes This Brochure dated March 28, 2025, is the annual amendment to our Form ADV Part 2A filing, and replaces the February 29, 2024 version of our Form ADV Part 2A We will provide you with an updated brochure at least annually, as required, and based on any material changes. We will provide this brochure at any time without charge. The following changes were made to this Firm Brochure since our last filing, which was filed February 29, 2024: Item 4: Updated the Regulatory Assets Under Management. • Item 10: Updated Other Financial Industry Activities and Affiliations. • iii  Item 3: Table of Contents Item 1: Cover Page. ..................................................................................................................................... i Item 2: Material Changes .......................................................................................................................... ii Item 3: Table of Contents ........................................................................................................................ iiii Item 4: Advisory Business ......................................................................................................................... 1 Item 5 – Fees and Compensation ............................................................................................................ 2 Item 6: Performance-Based Fees and Side-By-Side Management .................................................... 4 Item 7 – Types of Clients ........................................................................................................................... 4 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 5 Item 9: Disciplinary Information ................................................................................................................ 8 Item 10: Other Financial Industry Activities and Affiliations ................................................................. 8 Item 11: Code of Ethics, Participation in Client Transactions, Personal Trading .............................. 9 Item 12: Brokerage Practices ................................................................................................................. 10 Item 13: Review of Accounts .................................................................................................................. 11 Item 14: Client Referrals and Other Compensation............................................................................. 11 Item 15: Custody..................................................................................................................................... 122 Item 16: Investment Discretion ............................................................................................................... 13 Item 17: Voting Client Securities ............................................................................................................ 13 Item 18: Financial Information................................................................................................................. 14 iii  Item 4: Advisory Business Firm Overview Selby Lane Capital, LLC (“Selby Lane” or “Firm” or “Adviser”) is an investment firm that primarily provides advisory services to private pooled investment vehicles and separate account clients according to bespoke mandates according to the clients’ needs. Selby Lane was originally founded in 2020 with a mission to help its clients achieve their investment goals by offering solutions that provide exposure to venture capital, private equity and other private asset classes. The Firm is privately owned, and its principal owner is David C. Burke. Advisory Services Selby Lane provides discretionary portfolio management services to private pooled investment vehicles (the “Private Fund(s)” or the “Fund(s)”) in accordance with the investment guidelines set forth in each Private Fund’s offering documents. Selby Lane is responsible for the investment decisions and performance of the Private Funds. Selby Lane also provides discretionary advisory services to separately managed accounts, which follow a similar strategy of investing in third-party managed private pooled vehicles. Selby Lane’s investment advice is limited to investments in managers of private equity, growth equity, venture capital, and other private asset classes. Investors are required to meet certain qualifications, such as being an “Accredited Investor,” a “Qualified Client” and/or a “Qualified Purchaser” as defined under federal laws. Investors interested in a certain Private Fund should refer to the offering documents of such Private Fund for important information regarding the investment objectives, risks, fees and additional disclosures for a complete understanding of the terms and conditions for investing in the fund. Private Pooled Vehicles Each Private Funds invest substantially all of its assets in the limited partnership interests of other private funds (“underlying funds”) managed by third-party managers (the “Managers”). Selby Lane provides discretionary portfolio management services in accordance with the investment guidelines set forth in each Private Fund’s offering documents. Selby Lane is responsible for the investment decisions and performance of the Private Funds. 1  Advisory Consulting Services Selby Lane also provides bespoke advisory services to institutional and individual investors to facilitate investments in private equity, venture capital, and other private asset classes. These services include, but are not limited to, research, identification, allocation, facilitation, and monitoring of investments in third-party managed funds. Each client’s portfolio is customized to suit the client’s desired investment objectives and strategies and is implemented by the client, according to the terms of the client’s investment management agreement with Selby Lane. Assets under Management As of December 31, 20241, Selby Lane had total regulatory assets under management (RAUM) of $332,681,699. Item 5 – Fees and Compensation Adviser Compensation Private Fund Management Fees: Each Private Fund investor bears its proportionate share of the applicable investment management fee charged to the Private Fund. Compensation earned by Selby Lane for providing investment advisory services to the Private Funds is generally composed of an asset-based management fee, which does not exceed 2% and is generally payable quarterly in advance in addition to a performance-based fee, if applicable. In the event that an advisory agreement is terminated prior to the conclusion of a billing period, Selby Lane will refund a pro rata portion of any pre-paid management fees in accordance with the terms of the governing agreements. The management fee is generally deducted directly from the Private Fund’s assets. Management fees are based on committed capital, invested capital, net asset value or the aggregate of committed and invested capital, according to the terms of a fund’s governing agreement. Commitment-based fees are generally charged to a Private Fund during its investment period. After the investment period, the basis for the management fee varies according to the terms of each Private Fund’s governing agreement. Management fees that are based on the Funds’ net asset value, which calculated by the funds’ administrator using data from the Managers of the underlying funds. On a quarterly basis, each Manager provides the fund administrator with valuation reports showing the net asset value of the underlying funds. The fund administrator compiles these reports and calculates the net asset value for each Private Fund in compliance with the Firm’s valuation policy. The Firm’s Valuation 1 Gross Asset Values for the Funds: Due to the timing of this filing, the Firm has estimated gross asset values as of 12/31/2024 utilizing valuations as of 9/30/2024. An amended ADV will be filed reflecting final 12/31/2024 values once available. 2  Committee reviews and approves the administrator’s calculations. If a Manager’s net asset values are not otherwise available, Selby Lane will follow its fair valuation policies and procedures. Any market-traded securities held in a client’s custodian account are priced by the custodian or other independent pricing service provider. In addition, as described in Item 6 - Performance-Based Fees and Side-by-Side Management, Selby Lane or its affiliates has the potential to earn performance-based compensation from certain Private Funds in the form of a carried interest in profits. A Private Fund’s general partner (an affiliate of Selby Lane) may, in its discretion and in accordance with the fund’s offering documents, offer one or more limited partners of the fund the opportunity to co-invest alongside the Private Fund in an underlying fund. Management fees and/or carried interest that may be received by Selby Lane or its affiliates in connection with co- investments will be determined on a deal-by-deal basis. Advisory Consulting Services Fees: The Firm will charge either a fixed or asset-based fee that is determined according to the type and complexity of the specific services we provide. Asset-based fees could be charged based on the amount of a client’s capital commitments or on net asset value or invested capital. In some cases, clients will pay an incentive or carried interest fee. Terms regarding scope and nature of services provided, fees charged for those services, fee calculations, and manner of payment are documented in a client’s investment advisory agreement. Investment advisory agreements may be terminated according to the terms of the agreement. Fees are prorated for the number of days for which the agreement is in effect. We reserve the right to negotiate our advisory fees. The fees that we charge for advisory services, fixed fees, or project fees are specified in a client’s investment advisory agreement or other services agreement you have with us. Other (Non-Advisory) Fees Selby Lane’s advisory fees are exclusive of transaction and other fees and expenses that may be incurred by a Private Fund. These other fees and expenses are described in detail in each Private Fund’s offering memorandum or partnership agreement. Other fund fees and expenses may include, among others: • • • • Third-party custody fees; Organizational expenses; Legal, fund administration, accounting and tax preparation fees; and Fees and expenses of money market funds that hold cash balances. 3  All fees paid to Selby Lane for investment advisory services are separate and distinct from these other (non-advisory) fees and expenses. More information regarding a Private Fund’s fees and expenses is set out in the fund’s offering documents. Neither Selby Lane nor any of its employees receive placement fees or commissions from third parties for the sale of securities or other investment products, including asset-based charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management Performance Based Fees As described above in Item 5: Fees and Compensation, a portion of each Private Fund’s profits is distributed to certain Selby Lane affiliates (the “Carried Interest”). Because the general partner of each Private Fund is an affiliate of Selby Lane, Carried Interest is considered performance- based compensation that benefits Selby Lane. Carried Interest payments, if any, typically are paid periodically from proceeds received upon disposition investments that otherwise would be distributed to a Private Fund’s limited partners, pursuant to the terms of each fund’s limited partnership agreement. While the receipt of Carried Interest is intended to align Selby Lane affiliates’ interests with those of the relevant Private Fund, the nature of the Carried Interest creates a potential conflict of interest between Selby Lane affiliates and the Private Funds. The nature of performance fees can encourage unnecessary speculation with Private Fund assets in order to earn or increase the amount of the fee. The result of riskier investments can have a positive effect in that results could equal higher returns when compared to an asset-based fee account. On the other hand, riskier investments historically have a higher chance of losing value. However, this risk is somewhat mitigated because Carried Interest is only paid on realized investments, and Selby Lane’s affiliates have an obligation to return any excess Carried Interest distributions if actual returns upon a final disposition would result in investors receiving aggregate distributions that are less than a preferred return or in Selby Lane’s affiliate receiving more than the specified percentage of actual distributions to which it is entitled under the terms of the applicable partnership agreement. Selby Lane invests Private Fund assets in investment opportunities that it believes are in the best interests of the Private Funds without regard to fee arrangements. Item 7: Types of Clients Selby Lane provides advisory services to a variety of investors including individual investors, institutional investors, and private pooled vehicles. 4  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategy Selby Lane’s clients primarily invest in underlying private funds managed by third-party managers. The risks relating to the underlying private funds should be considered before investing. Use of Third-Party Managers. Adviser selects certain third-party managers to manage a substantial portion of its clients’ assets. In these situations, the Adviser conducts initial and ongoing due diligence of each Manager, but the success of Adviser’s strategy depends on the abilities of the Managers to successfully implement their respective investment strategies. In addition, Adviser does not supervise the independent Managers or direct their investment strategies. Initial due diligence is conducted via calls/meetings or on-site with a Manager. The Firm evaluates the following items, such as the Manager’s investment process, performance track record, fee structure, background of personnel, governing documents for the private fund under consideration, prior investor reporting and any third-party assessments of the Manager. Each Manager will be reviewed regularly (at least annually) by members of the Investment Committee. The reviews will consist of, but are not limited to, the evaluation of the Manager’s performance, reporting, changes in personnel, compliance with investment objectives, and whether there any material regulatory or legal issues pending or resolved during the review period. General Investment Risks General Economic Conditions. General economic conditions may affect investments made in client accounts. Interest rates, general levels of economic activity, the price of securities and participation by other investors in the financial markets may affect the value and number of investments made or considered for prospective investment. Illiquid and Long-term Investments. Investment in a privately-held company or private fund may require a long-term commitment with no certainty of return of capital. Private investments tend to be highly illiquid. Although some investments may generate current income, the return of capital and realization of gain, if any, from some investments will occur only upon the partial or complete disposition or refinancing of those investments. Uncertain Economic, Social and Political Environment. Consumer, corporate and financial confidence may be adversely affected by current or future tensions around the world, fear of terrorist activity and military conflicts, localized or global financial crises or other sources of 5  political, social or economic unrest. Such erosion of confidence may lead to or extend a localized or global economic downturn. A climate of uncertainty may reduce the availability of potential investment opportunities, and increase the difficulty of modeling market conditions, potentially reducing the accuracy of financial projections. In addition, limited availability of credit for consumers, homeowners and businesses, including credit used to acquire businesses, in an uncertain environment or economic downturn may have an adverse effect on the economy generally and on the ability of a Private Fund and its underlying fund’s portfolio companies to execute their respective strategies and to receive an attractive multiple of earnings on the disposition of businesses. This may result in longer holding periods for investments and slow the rate of making future investments. Uncertain economic, social and political conditions may have an adverse effect on client and Private Fund accounts as well as on underlying funds and their portfolio companies. No Market for Interests; Restrictions on Transfers. There will be no public market for the interests in the Private Funds or in the underlying funds, and none is expected to develop. There are substantial restrictions upon the transferability of each fund’s interests under the applicable partnership agreement and applicable securities laws. In general, withdrawals and redemptions of fund interests are not permitted. Failure to Make Capital Contributions. If an investor fails to pay when due installments of its capital commitment to a Private Fund, and the contributions made by non-defaulting investors and borrowings by a Private Fund are inadequate to cover the defaulted capital contribution, the Private Fund may be unable to pay its obligations when due. As a result, each Private Fund may be subjected to significant penalties that could materially adversely affect returns to the investors (including non-defaulting investors). If an investor defaults, it may be subject to various remedies as provided in the applicable Private Fund partnership agreement, including, without limitation, forced sale of the investor’s interest in the Private Fund and bar from future Private Fund investment opportunities. A Private Fund general partner may, subject to certain limitations, require additional capital contributions from non-defaulting investors to fund any shortfall caused by a defaulting investor. Lack of Operating History; Prior Investment Performance Not Indicative of Future Results. Although Selby Lane’s investment professionals have extensive experience in investing in private markets, each Private Fund is a newly formed entity and, accordingly, has no operating history upon which prospective investors may evaluate its likely performance. The performance of prior investments by the principals of Selby Lane is not necessarily indicative of future results. While Selby Lane intends to make investments that have estimated returns commensurate with the risks undertaken, there can be no assurance that the target returns for a Private Fund will be achieved or that investors will receive a return of their invested capital. 6  Risks Related to Investments Manager Risk: While the Firm conducts thorough due diligence on Managers, there can be unpredictable circumstances that put the investment at risk. The Manager could face issues such as key personnel changes, litigation, regulatory enforcement, or make unsuccessful investments in portfolio companies it selects for the underlying fund any of which could materially impact the performance of the investment. Private Company Risk. Each Private Fund investment portfolio is expected to consist primarily of securities issued by other private funds that invest in privately held companies, and operating results in a specified period will be difficult to predict. Private companies may be in early stages of growth, and the performance of such companies may be more volatile due to their limited product lines, markets or financial reserves, their susceptibility to competitors’ actions, or major economic downturns. The portfolio companies held in the fund in which the Private Funds invest, may also depend on the management talents and efforts of a small group of individuals and, as a result, the death, disability, resignation or termination of one or more of those individuals could have a material adverse impact on prospective business opportunities and investments made. Additionally, some of the private companies may require a significant investment of capital to support their operations or finance the development of their products or markets and may be highly leveraged and subject to significant debt service obligations, which could have a material adverse impact on the performance of the investment. Non-diversification. Some private fund investments may be concentrated in other private funds that invest in a relatively small number of companies and industries. Selby Lane’s investment program will be less diversified than funds investing in a broader range of industries and a greater number of companies and, therefore, could experience greater volatility than more diversified funds. Special Risks Associated with Foreign Investments. The Private Funds may invest in managers that invest in portfolio companies that are organized, headquartered, or have substantial sales or operations outside of the United States, its territories, and possessions. Such investments may be subject to certain additional risks due to, among other things, potentially unsettled points of applicable governing law, the risks associated with fluctuating currency exchange rates, capital repatriation regulations, the application of complex U.S. and non-U.S. tax rules to cross-border investments, possible imposition of non-U.S. taxes, and possible non-U.S. tax return filing requirements. Additional risks of non-U.S. investments include: (a) economic dislocations in the host country; (b) less publicly available information; (c) less well-developed and/or more restrictive laws, regulations, regulatory institutions and judicial systems; (d) greater difficulty of enforcing legal rights in a non-U.S. jurisdiction; (e) civil disturbances; (f) government instability; and (g) 7  nationalization and expropriation of private assets. Moreover, non-U.S. companies may not be subject to uniform accounting, auditing and financial reporting standards, practices and requirements comparable to those that apply to U.S. companies. Material Non-Public Information. Selby Lane and its affiliates may come into possession of material, non-public information that may be relevant to an investment decision. Consequently, the Firm may be restricted from initiating a transaction or selling an investment to which the material, non-public information relates. Cybersecurity Risk: Selby Lane, the Managers they select for investments and the private companies owned in the underlying private funds, are subject to operational and information security risks, including those resulting from cyber-attacks. Risk of Private Investment Funds. Privately placed investment funds, such as private equity funds or private pooled vehicles that invest in other private funds are not registered investment companies and are not subject to the same regulatory reporting or oversight as registered investment companies. The managers of these funds have broad discretion in selecting investments. There are few limitations on the types of securities or other financial instruments that may be traded and no requirement to diversify. There are numerous other risks in investing in private investment funds. Investors should review each fund’s private placement memorandum and other offering documents to understand the nature of a fund’s risks prior to investing. Investing in venture capital, growth equity, private equity, and other private asset classes involves risk of loss, including total loss of invested capital, that investors should be prepared to bear. Item 9: Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Selby Lane or the integrity of the Firm’s management. Selby Lane has no information applicable to this Item. Item 10: Other Financial Industry Activities and Affiliations Selby Lane and its management persons are not registered, and do not have an application pending to register, as a broker-dealer or as a registered representative of a broker-dealer, as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. 8  Selby Lane is affiliated with the general partners for the Private Funds managed by Selby Lane, as outlined in each Private Fund’s offering documents. Other Activities of Principals: Although the principals of Selby Lane collectively intend to devote most of their time and attention to management of the Private Funds and other Client accounts, they may in the future organize and manage one or more entities with objectives similar to, or different from, those of one or more Private Funds or other Client accounts. Selby Lane employees serve on the board of advisors of other investment managers or advisors. These arrangements are compensated and can include the opportunity to invest by Selby Lane employees with the investment managers or advisors. Selby Lane is committed to putting the interests of its clients first and seeks to act in a manner consistent with its fiduciary and contractual obligations to its clients and applicable laws. Selby Lane reserves the right to prohibit Selby Lane employees from participating in other activities that present material conflicts of interest. Selby Lane Digital. Selby Lane’s subsidiary, Selby Lane Digital (“SLD”), which is majority owned and controlled by Selby Lane, develops technology for client-facing infrastructure. The other owners of SLD include managers of underlying funds in which certain Private Funds managed by Selby Lane are or will be invested and those managers also make investments in certain Private Funds managed by Selby Lane. Selby Lane maintains policies and procedures for performing due diligence on the investments it makes on behalf of the funds it manages and these funds were evaluated according to the same standards as any other investment that is made by the Private Funds. Item 11: Code of Ethics, Participation in Client Transactions, Personal Trading Selby Lane has adopted a Code of Ethics in accordance with the Investment Advisers Act of 1940, as amended (the “Advisers Act”), which applies to all Access Persons of the Firm and describes its high standard of business conduct and fiduciary duty to all clients of Selby Lane. Currently, all employees of the Firm are deemed Access Persons. The Code of Ethics, in addition to the Firm’s compliance policies and procedures, includes provisions related to the confidentiality of Client and Investor information, a prohibition on insider trading, restrictions on and reporting of significant gifts and business entertainment as well as policies and procedures governing trading securities in personal accounts. All Access Persons at Selby Lane must acknowledge the terms of the Code of Ethics upon employment, annually thereafter, and as amended from time to time. The Code of Ethics is designed to ensure that the personal securities transactions, activities and interests of the Access Persons of Selby Lane will not interfere with (i) making decisions in the 9  best interests of the Private Funds and other Clients and (ii) implementing such decisions while, at the same time, allowing Access Persons to invest for their own accounts. Under the Code of Ethics certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of Selby Lane’s Clients. In addition, the Code of Ethics requires preclearance of transactions involving initial public offerings, limited offerings, and private placements. Related persons of Selby Lane do invest their own money in the Private Funds. Investors or prospective investors may request a copy of the firm’s Code of Ethics by contacting us at (650) 463-9511. Side Letters: The Firm may enter into side letters or other similar arrangements with limited partners that have the effect of establishing or otherwise benefiting such investor in a manner more favorable than the rights and benefits described in the Private Fund’s offering documents. Rights and benefits that are more favorable in any material respect may be afforded to a limited partner based upon its commitment level, for example, and the same favorable rights and benefits may be extended to other limited partners in accordance with each respective Private Fund’s offering documents. These rights and benefits include, but are not limited to, most favored nation status, capacity, investment restrictions, reporting requirements, tax considerations, and other terms and conditions. Co-Investments. The Adviser may, in its discretion, but subject to each Private Fund’s governing documents and side letters, make available co-investment opportunities to certain investors. The Adviser is not required to offer co-investment opportunities to all investors and may select certain investors that it deems appropriate for co-investment opportunities. Co-investment opportunities may be made available through limited partnerships or other entities formed to make such investments. The Adviser will allocate available investment opportunities among the Private Funds, any co-investment vehicle and any third parties in accordance with its allocation policy. Therefore, in the event that a co-investment is a successful investment, any investor that did not participate in such co-investment will not participate in the profits of such co-investment. The Adviser has adopted policies and procedures to address co-investment opportunities, in an effort to offer co-investment opportunities to investors and/or third parties which it believes are suitable for co-investment opportunities. Item 12: Brokerage Practices Selby Lane primarily engages in private investment transactions through investments made in private funds managed by a third-party manager. In the event Selby Lane engages in public securities transactions, Selby Lane will use a qualified custodian to hold the Client’s assets, in the name of the Client, and execute transactions on terms that are overall most advantageous when 10  compared to other available providers and their services. A range of factors would be considered including: • Price • The size of the transaction • The nature of the market • Capability to execute, clear and settle trades (buy and sell securities for your account) • Capabilities to facilitate transfers and payments to and from accounts quality of services • Reputation, financial strength, and stability of the provider Selby Lane does not currently maintain any soft dollar arrangements or any referral arrangements with broker/dealers. Selby Lane does not accept directed brokerage. Selby Lane may be presented with investment opportunities that fall within the investment objective of more than one Private Fund or other advisory client. When two or more clients are formed to invest on a parallel basis, Selby Lane will allocate investments in accordance with Selby Lane’s investment allocation policy, subject to any limitations in the applicable Private Fund offering documents or a Client’s investment advisory agreement. Selby Lane will provide a summary of its allocation policy to investors upon request. In addition, one or more non-parallel Private Funds may invest together, subject to limitations set forth in the applicable Private Fund offering documents. Selby Lane will determine allocations of investment opportunities in a manner that they believe is fair and equitable consistent with Selby Lane’s obligations to all Clients, as set forth in the applicable Private Fund offering documents, investment advisory agreements and Selby Lane’s allocation policy. Item 13: Review of Accounts Selby Lane’s principals are responsible, and have ultimate authority, for all transactions and investment decisions made on behalf of the clients. At least quarterly, a Selby Lane principal reviews Client portfolios to ensure compliance with the stated objectives and restrictions. Client investments are reviewed on an ongoing basis and may be reviewed specifically with regard to certain factors such as significant cash flows or in response to market conditions. Selby Lane, or its service provider, will furnish each client with written reports pursuant to the terms set forth in the offering document of each Private Fund or investment advisory agreement. Item 14: Client Referrals and Other Compensation 11  Selby Lane does not receive any economic benefits from persons other than clients for providing investment advice or other advisory services to clients. Selby Lane does not currently maintain any solicitor arrangements. 12  Item 15: Custody Selby Lane is deemed to have custody of the assets of each Private Fund since it has access to the Private Fund assets through the affiliated entities who serve as general partner/managing member to each Private Fund. However, all Client assets and transferable securities are maintained at independent qualified custodians in accounts registered to the Client or the Private Fund. Selby Lane will comply with the requirements of the Advisers Act Custody Rule, with regard to the Custody Rule as a result of affiliates serving as general partner to each Private Fund. Selby Lane has entered into a written agreement with an independent public accountant to provide audited financial statements to each Private Fund’s investors within 180 days following the Private Fund’s fiscal year end. The 180-day deadline is applicable to the Private Funds since each meets the definition of a fund of funds. Item 16: Investment Discretion Selby Lane is retained by Private Fund or separate account Clients pursuant to a management agreement to provide investment advisory services on a discretionary basis. When engaged by a Client on a discretionary basis, Selby Lane is generally authorized to make all decisions with respect to purchases and sales of securities, including the quantity and price of the securities to be bought or sold, as well as the selection of any brokers, dealers, or other service providers to be used in connection with such transactions. Investments for Clients are managed in accordance with each Client’s investment objectives, strategies and restrictions. Investments for the Private Funds are not tailored to the individualized needs of any particular investor in the Private Funds. Selby Lane does not exercise discretion over its Advisory Consulting Clients assets. Item 17: Voting Client Securities Selby Lane has written Proxy Voting Policies and Procedures as required by the Advisers Act. As part of the Firm’s policies and procedures, Selby Lane will exercise proxy voting authority when such authority is provided in the operating agreement of a Fund. Selby Lane seeks to vote proxies in the best interest of each Client. Selby Lane, or an affiliate thereof, will have voting power with respect to investments made on behalf of Clients but it is unlikely that any Client would hold any security for which proxies would be solicited since these are private market investments. If the situation arises, Selby Lane will monitor for potential conflicts of interest between the Clients’ interests and its own within the proxy voting process. 13  In order to ensure that Selby Lane is aware of the facts necessary to identify conflicts, senior management of Selby Lane must disclose to the chief compliance officer any personal conflicts such as officer or director positions held by them, their spouses or close relatives, in any private placement. Conflicts based on business relationships with Selby Lane, or any affiliate of Selby Lane will be considered only to the extent that Selby Lane has actual knowledge of such relationships. If a conflict may exist which cannot be otherwise addressed, Selby Lane may choose one of several options including: (i) vote matters that are specifically covered by the Proxy Voting Policies and Procedures in accordance with the policy; or (ii) if possible, erecting information barriers around the person or persons making the voting decision sufficient to insulate the decision from the conflict. It is not possible for limited partners to direct votes made by Selby Lane on behalf of a fund. Item 18: Financial Information Selby Lane does not require or solicit prepayment of fees six months or more in advance. Selby Lane is not aware of any financial condition that is reasonably likely to affect its ability to meet contractual and fiduciary commitments to clients. Selby Lane has never been the subject of bankruptcy proceedings. 14