LEGAL

Regulatory Disclosures

Last updated: October 5, 2026

1. NO OFFER OR SOLICITATION

Nothing on the site located at www.cocoanutcapital.com constitutes, or is intended to constitute, an offer to sell or a solicitation of an offer to buy any security, or any interest in any vehicle organized or managed by Cocoanut Row Capital Partners, LLC or any of its affiliates. The site is informational in nature.

2. THE FIRM

The firm operates through Cocoanut Row Capital Partners, LLC, a Delaware limited liability company headquartered in Palm Beach, Florida. The firm sponsors and manages its investment vehicles and is responsible for its own regulatory compliance, books, and obligations.

3. OFFERING UNDER REGULATION D RULE 506(b)

Vehicles organized by the firm are, and will be, offered in reliance upon the exemption from registration provided by Rule 506(b) of Regulation D under the United States Securities Act of 1933, as amended. Interests in the firm's vehicles are offered only to persons with whom the firm has established a substantive pre-existing relationship, and are offered only through the confidential offering materials and subscription documents of each specific vehicle.

No general solicitation or general advertising, within the meaning of Rule 506(c), is or has been undertaken in connection with any vehicle organized by the firm.

4. INVESTMENT COMPANY ACT · SECTION 3(c)(1)

Vehicles organized by the firm are, and will be, structured to rely upon the exemption from the definition of "investment company" provided by Section 3(c)(1) of the United States Investment Company Act of 1940, as amended. Accordingly, no vehicle organized by the firm will admit more than one hundred (100) beneficial owners of its securities, calculated in accordance with the integration and look-through principles applied under that section.

5. ACCREDITED INVESTOR QUALIFICATION

Participation in any vehicle organized by the firm is limited to investors who qualify as "accredited investors" under Rule 501(a) of Regulation D. Qualification will be verified through the subscription documentation of the relevant vehicle.

6. FORWARD-LOOKING STATEMENTS

Certain statements on the site are forward-looking. Forward-looking statements reflect the firm's present views of its intended practice and are not guarantees of future outcomes. Actual practice, and the specific terms of any vehicle offered by the firm, may differ materially from statements on the site and will be superseded by the governing documents of each specific vehicle at the time of offering.

The firm undertakes no obligation to update any forward-looking statement on the site.

7. RISK OF LOSS

Investments in private-market vehicles of the type organized by the firm involve a high degree of risk, including the possibility of loss of the entire amount invested. Such investments are suitable only for investors of substantial means who can bear the economic risk of an illiquid investment and the absence of ongoing disclosure. Past performance, whether of the firm, its principals, or any underlying issuer, is not indicative of future results.

Positions in thematic vehicles are acquired after final close. There is no assurance that every disclosed position will be acquired, or acquired at or below its disclosed maximum entry valuation. A thematic vehicle may therefore hold fewer positions than contemplated, with correspondingly greater concentration of risk.

8. NO INVESTMENT, LEGAL, OR TAX ADVICE

Nothing on the site is, or should be construed as, investment, legal, tax, accounting, or regulatory advice. Prospective investors should consult their own counsel and qualified advisers before considering any investment in any vehicle organized by the firm.

9. COUNSEL ENGAGEMENT

The firm retains qualified United States securities counsel in connection with the formation, offering, and subscription documentation of each vehicle. Counsel is identified in the governing documents of each specific vehicle.

10. JURISDICTIONS

United States — federal. Interests in the firm's vehicles are offered under the federal exemption provided by Rule 506(b) of Regulation D as described in Section 3 above. The firm does not offer interests in reliance upon Rule 506(c) and undertakes no general solicitation or general advertising.

United States — state blue-sky notices. Each offering is intended to qualify as a "covered security" under Section 18 of the Securities Act of 1933, with the effect that state-level registration requirements are preempted. The firm or its administrator nonetheless makes notice filings required under applicable state law (typically a Form D filing under Rule 503 of Regulation D, together with any corresponding state notice form) within the applicable statutory period following the first sale in each state, and pays any applicable notice-filing fee. Notice filings are tracked by the firm's administrator and kept current throughout the offering period of each vehicle.

State-level investor requirements. Certain states impose suitability standards or additional disclosures beyond the federal accredited-investor definition. The firm applies the more stringent of federal or applicable state standards to each subscriber, as determined at the time of subscription and as administered through the subscription documentation of each vehicle.

Non-United States persons. The firm may accept commitments from non-United States persons in reliance upon Regulation S under the Securities Act of 1933, in parallel with the firm's Rule 506(b) exemption for United States persons. Whether Regulation S is relied upon in any specific offering, and the specific category of Regulation S applied, are determined at the time of offering and set out in the governing documents of each vehicle. Non-United States subscribers are additionally responsible for compliance with the securities, tax, and other laws of their own jurisdictions. The firm makes no representation that interests in any vehicle may lawfully be offered or acquired under the laws of any non-United States jurisdiction, and prospective non-United States subscribers are advised to consult their own counsel.

Excluded jurisdictions. The firm does not offer, and will not accept subscriptions from persons resident in, any jurisdiction subject to comprehensive sanctions administered by the United States Office of Foreign Assets Control (OFAC), the European Union, the United Kingdom, Switzerland, or the United Nations, or any jurisdiction in which the offer or acquisition of interests in the firm's vehicles would require the firm to register, qualify, or undertake any other licensing step that the firm has not undertaken. The firm reserves the right to decline any subscription at its discretion for any reason, including on grounds of jurisdictional inappropriateness, anti-money-laundering diligence, or sanctions screening.

11. CONFIDENTIALITY

All offering materials and subscription documents distributed by the firm are confidential and are provided on a named-recipient basis, subject to the terms of the firm's Mutual Non-Disclosure Agreement, which is executed electronically in advance of the firm sharing vehicle-specific materials.

12. CONTACT

Regulatory inquiries may be directed to introductions@cocoanutcapital.com. The firm will respond as, and to the extent, appropriate.