0001206774-19-000138 Sample Contracts

DISTRIBUTION AGREEMENT
Distribution Agreement • January 18th, 2019 • ACAP Strategic Fund • New York

THIS DISTRIBUTION AGREEMENT (the “Agreement”) by and between ACAP STRATEGIC FUND a Delaware statutory trust (the “Fund”), and BREAKWATER GROUP L.L.C., a Delaware limited liability company (the “Distributor”), is dated as of May 18, 2015 and effective as set forth in Section 9(a) of this Agreement.

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INVESTMENT COMPANY REPORTING MODERNIZATION SERVICES AMENDMENT TO ADMINISTRATION AND ACCOUNTING SERVICES AGREEMENT
Administration and Accounting Services Agreement • January 18th, 2019 • ACAP Strategic Fund

This Investment Company Reporting Modernization Services Amendment (the “Amendment”) is made as of ___________ by and between ACAP STRATEGIC FUND (the “Fund”) and BNY MELLON INVESTMENT SERVICING (US) INC. (“BNY Mellon”).

SPECIAL CUSTODY and PLEDGE AGREEMENT
Special Custody and Pledge Agreement • January 18th, 2019 • ACAP Strategic Fund • New York

THIS SPECIAL CUSTODY and PLEDGE AGREEMENT, (hereinafter, the “Agreement”) dated _____________, is made by and among ACAP STRATEGIC FUND (“Customer”), MERRILL LYNCH PROFESSIONAL CLEARING CORP. on behalf of itself and as agent for the other BofAML Entities (as defined below) (“Broker”), and THE BANK OF NEW YORK MELLON (“Custodian”).

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