Hite Hedge Asset Management LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:

11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
U.S. SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/21/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AP FILE NO: 3-21308
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED HITE HEDGE ASSET MANAGEMENT PURCHASED SECURITIES IN A SECONDARY OFFERING WHEN IT SOLD SHORT SHARES OF THE SAME
SECURITY WITHIN THE RULE 105 (REGULATION M) RESTRICTED PERIOD.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
02/21/2023
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
N/A
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN FEBRUARY 2023, THE SEC AND HITE ENTERED INTO A SETTLEMENT TO RESOLVE A SINGLE VIOLATION OF RULE 105 OF REGULATION M. THE SEC
FOUND THAT HITE VIOLATED RULE 105 BY PARTICIPATING IN ONE SECONDARY OFFERING IN 2021 WHILE ALSO SELLING SHORT DURING THE
RESTRICTED PERIOD. HITE HAS RESOLVED THIS MATTER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. AS PART OF THIS RESOLUTION, HITE
AGREED TO CEASE AND DESIST FROM VIOLATING AND ANY FUTURE VIOLATIONS OF RULE 105. HITE ALSO AGREED TO PAY A ONE-TIME CIVIL MONEY
PENALTY OF $103,591. THE FUNDS THAT PARTICIPATED IN THE SECONDARY OFFERING WERE REQUIRED TO DISGORGE $111,629.52 AND TO PAY
PREJUDGMENT INTEREST OF $4,937.24; HITE HAS REIMBURSED THE FUNDS FOR THIS DISGORGEMENT AND PREJUDGMENT INTEREST TO ENSURE THAT
THERE WOULD BE NO FINANCIAL LOSS FOR INVESTORS AS A RESULT OF THIS SETTLEMENT. HITE HAS ALWAYS TAKEN RULE 105 VERY SERIOUSLY, AND
THIS EVENT OCCURRED DESPITE OUR TEAM FOLLOWING THE APPROPRIATE COMPLIANCE PRACTICES BASED IN PART ON INCORRECT INFORMATION
FROM THE UNDERWRITER ABOUT THE NATURE OF THE OFFERING. SINCE THIS OCCURRENCE, WE HAVE FURTHER ENHANCED OUR DOCUMENTATION
AND PROCEDURES BASED ON THE KNOWLEDGE GAINED FROM THIS EXPERIENCE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
U.S. SECURITIES AND EXCHANGE COMMISSION
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
DISGORGEMENT
3.
Filing Date of Court Action (MM/DD/YYYY):
02/17/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
U.S. DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS, DOCKET NO. 1:23-CV-10351-LTS
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE SEC ALLEGED HITE PURCHASED SECURITIES IN A SECONDARY OFFERING WHEN IT SOLD SHORT SHARES OF THE SAME SECURITY DURING THE
RULE 105 (REGULATION M) PERIOD.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 

10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Consent
12. Resolution Date (MM/DD/YYYY): 
02/28/2023
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 103,591.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
HITE HEDGE ASSET MANAGEMENT LLC PAID A CIVIL PENALTY IN THE AMOUNT OF $103,591. AS PART OF THIS ACTION, HITE HEDGE LP WAS
REQUIRED TO DISGORGE $19,042.63. HITE HEDGE II LP WAS REQUIRED TO DISGORGE $41,744.06. HITE HEDGE OFFSHORE LTD WAS REQUIRED
TO DISGORGE $55,780.07
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
IN FEBRUARY 2023, THE SEC AND HITE ENTERED INTO A SETTLEMENT TO RESOLVE A SINGLE VIOLATION OF RULE 105 OF REGULATION M. THE SEC
FOUND THAT HITE VIOLATED RULE 105 BY PARTICIPATING IN ONE SECONDARY OFFERING IN 2021 WHILE ALSO SELLING SHORT DURING THE
RESTRICTED PERIOD. HITE HAS RESOLVED THIS MATTER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. AS PART OF THIS RESOLUTION, HITE
AGREED TO CEASE AND DESIST FROM VIOLATING AND ANY FUTURE VIOLATIONS OF RULE 105. HITE ALSO AGREED TO PAY A ONE-TIME CIVIL MONEY
PENALTY OF $103,591. THE FUNDS THAT PARTICIPATED IN THE SECONDARY OFFERING WERE REQUIRED TO DISGORGE $111,629.52 AND TO PAY
PREJUDGMENT INTEREST OF $4,937.24; HITE HAS REIMBURSED THE FUNDS FOR THIS DISGORGEMENT AND PREJUDGMENT INTEREST TO ENSURE THAT
THERE WOULD BE NO FINANCIAL LOSS FOR INVESTORS AS A RESULT OF THIS SETTLEMENT. HITE HAS ALWAYS TAKEN RULE 105 VERY SERIOUSLY, AND
THIS EVENT OCCURRED DESPITE OUR TEAM FOLLOWING THE APPROPRIATE COMPLIANCE PRACTICES BASED IN PART ON INCORRECT INFORMATION
FROM THE UNDERWRITER ABOUT THE NATURE OF THE OFFERING. SINCE THIS OCCURRENCE, WE HAVE FURTHER ENHANCED OUR DOCUMENTATION
AND PROCEDURES BASED ON THE KNOWLEDGE GAINED FROM THIS EXPERIENCE.