AB CarVal Investors, LP

AB CarVal Investors is a global asset manager and is a wholly owned subsidiary of AllianceBernstein L.P. (“AB”). CCML is a wholly owned subsidiary of AB CarVal Investors and manages collateralized loan obligation vehicles (each an “AB CarVal CLO”), which invest primarily in broadly syndicated loans. AB CarVal operates independently, subject to governance oversight by AB. AB is an SEC-registered investment adviser that is owned in turn by two publicly traded companies. Equitable Holdings Inc. (NYSE:EQH), a publicly traded insurance company, and its subsidiaries own a controlling economic interest in AB. In addition, a minority economic interest in AB is owned by the public through AllianceBernstein Holding L.P. By way of background, CarVal Investors was originally formed in 2006 as a continuation of Cargill Value Investment (“CVI”), which was an internal business unit of Cargill, Incorporated (“Cargill”). Between 1987 and 2006, CVI solely managed proprietary investments on behalf of Cargill. In 2006, Cargill established CarVal as an independently managed alternative investment manager to continue and expand upon the investment activities of CVI. CarVal was a 100% owned, independently managed, indirect subsidiary of Cargill until a management buyout of Cargill’s ownership interest in 2019. Following the management buyout, the firm was owned indirectly by certain members of the firm’s senior management. On July 1, 2022, AB acquired 100% of the ownership interests previously held indirectly by the firm’s senior management. AB CarVal provides investment management services on a discretionary or non-discretionary basis to private domestic and non-U.S. collective investment vehicles which are described below (the “Funds” or the “AB CarVal Funds”). Interests in these vehicles are offered exclusively to investors satisfying applicable eligibility and suitability requirements. From time to time, AB CarVal will also provide advice to vehicles established for or by a single investor (“single-investor fund,” and collectively with other investment vehicles, “the Funds”). In addition, AB CarVal Investors became investment manager to a registered investment company for the first time in 2024 and may serve as investment manager to other registered vehicles in the future. The Funds invest primarily in one or more of four principal asset classes: Loan Portfolio Investments, Corporate Securities Investments, Structured Credit and Hard Assets, as well as Special Opportunities Investments. For greater detail on these strategies, see Item 8—Methods of Analysis, Investment Strategies and Risk of Loss. In providing services to the Funds, AB CarVal conducts its investment management business in part through certain affiliates. AB CarVal’s wholly owned subsidiary, CarVal Investors

UK Limited, which is based in London, England, is general partner of CarVal Investors GB LLP, a limited liability partnership that is regulated by the United Kingdom Financial Conduct Authority). CarVal Investors GB LLP has executed a sub-advisory agreement pursuant to which it provides investment management advice and expertise regarding local and regional capital markets, public and private transactions, and market participants. In addition, AllianceBernstein (Singapore) Ltd., a wholly owned affiliate of AB that holds a capital market services license and is regulated by the Monetary Authority of Singapore, employs several individuals who are dedicated to supporting AB CarVal and its investment management activity and perform such activity pursuant to a support services agreement with AB CarVal. Finally, AB CarVal holds an indirect majority interest in CarVal Wensheng Private Fund Management (Shanghai) Co., Ltd. (“CarVal Wensheng”), an investment adviser that is based in China.. CarVal Wensheng currently provides investment advisory services to a private fund whose beneficial owners are other AB-CarVal-managed vehicles. CarVal Investors GB LLP, AllianceBernstein (Singapore) Ltd. and CarVal Wensheng are included as participating affiliates on AB CarVal Investor’s Form ADV. As of December 31, 2025, AB CarVal and its subsidiaries employed 169 employees, including support staff. In addition to these employees, certain staff of affiliated entities support AB CarVal’s business. The Funds The Registrants manage multiple Funds. Please note that for the purposes of Form ADV Part 1, the Registrants report each master-feeder arrangement as a Fund. All feeders in these arrangements generally invest on a pro rata basis; there is no substantial differentiation in Investor holdings. Therefore, individual feeder funds are not included as separate clients in Item 5.C and 5.D of each Registrant’s respective Form ADV Part 1. Since some of the private funds AB CarVal manages have multiple master-feeder arrangements, the total number of private funds reported in Item 5.C.(1) of each Registrant’s respective Form ADV Part 1 may not correspond to the total number of Funds that the Registrants report on other documents including but not limited to marketing documents, private placement memoranda and official filings with regulators. In each master-feeder arrangement, various investors (each, an “Investor”) invest in one or more feeder funds which, in turn, invest capital in the assets the Funds hold, generally through one or more master funds or pooling entities. Investments in a Fund may be subject to a requirement that the Investor commit capital to the Fund for a given period of time. In AB CarVal’s current private Funds, commitments range from 6 months to 8 years from a fixed date set forth in the relevant governing documents, depending on the Fund. Each Fund may have different liquidity and/or redemption terms. AB CarVal Investors also advises a registered investment company that operates as an interval fund, offering quarterly liquidity of between 5% and 25% of the fund’s net asset value. Further

information can be found in each Fund’s private placement or offering memorandum, limited partnership agreement (“LPA”), subscription agreements, investment management agreements and/or other governing documents, as applicable (the “Offering Documents”). In its capacity as investment manager to the Funds, AB CarVal is responsible for executing each Fund’s investment objectives and strategy. As of December 31, 2025, AB CarVal’s total discretionary assets under management are $16,811,977,280. In addition, AB CarVal currently manages certain investments on a non-discretionary basis, and certain Funds are non-discretionary funds. As of December 31, 2025, AB CarVal’s total non-discretionary assets under management are $4,047,523,397. AB Carval’s assets under management, including both discretionary and nondiscretionary accounts, are $20,859,500,678.1 AB CarVal Investors, LP’s Regulatory Assets Under Management (as defined in Form ADV Part 1) are $18,441,989,964 as of December 31, 2025. CarVal CLO Management, LLC’s Regulatory Assets Under Management (as defined in Form ADV Part 1) are $7,304,940,802 as of December 31, 2025. AB CarVal does not participate in wrap fee programs. Apart from non-discretionary accounts and Funds, AB CarVal generally has broad and flexible discretion with respect to investment decisions made for the Funds, and also with respect to the selection of brokers, dealers and other counterparties for such investments, and the amount of commissions or other compensation to be paid by the Funds. AB CarVal provides investment advisory services to the Funds based on the particular investment objectives and strategies described in the applicable Fund’s Offering Documents. All discussions of the Funds in this Brochure, including but not limited to their investments, the strategies used in managing the Funds, the fees and other costs associated with an investment in the Funds, investor suitability standards and conflicts of interest faced by AB CarVal in connection with management of the Funds, are qualified in their entirety by reference to each Fund’s respective Offering Documents.

Fees for Funds The compensation each Fund pays AB CarVal is set forth in each Fund’s Offering Documents. The fees described below are generally non-negotiable except as set forth below. For each commingled Fund it manages, AB CarVal charges a management fee (the “Management Fee”) and/or a performance allocation or fee consisting of a percentage of realized and/or unrealized profits (subject in certain Funds to hurdle rates, high watermarks and holdback and clawback provisions as defined by the respective Offering Documents). Principals, employees,

directors, officers and certain individuals or entities that directly or through their affiliates have historic relationships to AB CarVal and are invested in the Funds may not be charged such asset-based or performance fees. For further information about performance-based compensation, see Item 6—PerformanceBased Fees and Side-By-Side Management. AB CarVal charges a Management Fee to Investors that varies pursuant to the terms of each Fund’s Offering Documents. The fees associated with an investment in a Fund vary, depending on the Fund, and are described in detail in each Fund’s Offering Documents. Current Management Fees for AB CarVal’s commingled Funds range between 0.5% and 2.0% of contributed or invested capital or net asset value. Management Fee calculations may vary depending on a particular Fund’s stage in its life cycle. The Management Fee may be calculated on a beginning- or end-of-quarter methodology and is typically paid quarterly in arrears. AB CarVal may, in its sole discretion, waive or reduce the Management Fee or performance-based compensation and distributions to Investors will be adjusted accordingly. AB CarVal may also charge a Management Fee that is higher than, lower than, or otherwise on different terms than those described above or may offer Management Fee holidays to investors for a pre-determined period of time. Fees for managing single investor or non-discretionary vehicles will be set forth in the written agreement with the relevant Investor(s). Generally, such arrangements will include an asset-based and/or a performance-based component and will be negotiated on a case-by-case basis and may be lower than Management Fees for other Funds. Fund agreements typically identify that placement agent fees and other ancillary fees (directors’ fees, transaction fees, break-up fees, etc.) offset the Management Fee payable to the investment manager for such Funds on a dollar-for-dollar basis. Fees for the AB CarVal CLOs CCML receives Management Fees from the AB CarVal CLOs in an amount ranging from 0.30% to 0.35% of the par value of the collateral and cash held in the AB CarVal CLOs. In general, Management Fees will be payable only if there are funds available in accordance with the priority of payments provisions of the AB CarVal CLOs’ governing documents. CCML also receives incentive fees, typically 20% of the excess cash flows due to the holders of the subordinated notes, subject to a stated hurdle rate. Fees for Registered Investment Companies In February 2024, AB CarVal Investors was appointed investment adviser to a fund that is a registered investment company under the Investment Company Act of 1940. This fund has a management fee of 1.5%.

1 AUM is comprised of fee-earning AUM and fee-eligible AUM. Fee-earning AUM includes those assets currently eligible to generate management fees. Fee-eligible assets includes capital that is committed to an AB CarVal Fund, but is currently uncalled or recallable. The number represented here excludes assets under AB CarVal’s management that are not generating fees due to the maturity of the Fund.

Automatic Fee Deduction

the Funds and (C) trade order management systems (e.g., Everest and eFront) whose primary purpose is to support the trading activities of the Funds and related record keeping for each and (ix) Internal Fund Operating Expenses. “Internal Fund Operating Expenses” include an allocation of the salaries and benefits of AB CarVal employees, contractors, affiliates or agents, and other compensation including an allocation of IT expenses related to such individuals, to the extent such individuals provide services related to or otherwise benefiting the organization, operations, investment or trading activity of the Funds. Examples of Internal Fund Operating Expenses charged to Investors include, without limitation, legal, operations, and risk personnel who assist with investment or trading activity of the Funds, tax personnel, administration of investor capital accounts, preparation and distribution of annual reports (including Form 200 or 205), notices, statements and other Fund-related communications to investors, internal asset management and oversight, monitoring of third-party service providers, cash management services, fund accounting and costs related to computer hardware and software. Internal Fund Operating Expenses charged to the Funds are often subject to a per annum limit expressed as a percentage of the average net asset value of the specific Fund.

AB CarVal generally deducts fees, if any, directly from each Fund, pursuant to the relevant Offering Documents and investment management agreement. The Offering Documents of each Fund describe the specific manner and means by which fees will be paid, including, if applicable, the circumstances in which fees may be invoiced for payment by the Investor. Expenses Each Fund will pay or reimburse either AB CarVal Investors or CCML, when applicable, for certain organizational, administrative, operational and other permissible expenses as described in its Offering Documents. These permissible expenses generally include costs and expenses relating to both the offer and sale of interests in the Funds (“Offering Expenses”) as well as the organization of the entities that comprise the critical Fund entities and their respective general partners and managing members (“Organizational Expenses”). Offering and Organizational Expenses may be capitalized or expensed for accounting purposes in accordance with GAAP. Each Investor is solely responsible for its own legal and tax counsel expenses and any out-of-pocket expenses incurred in connection with its admission to, or the maintenance of its interest in, the Funds. Pursuant to the underlying LPAs and other Offering Documents, and in addition to Management Fees, AB CarVal has the right to charge to its Funds certain expenses, including internal and third-party operational and administrative expenses. These generally include, but are not limited to, the following: (i)

Internal and third-party expenses incurred in connection with the organization, operations and investment or trading activity of the Funds’ investment vehicles (“Fund Operating Expenses”). Examples of Fund Operating Expenses include, without limitation, (i) internal and third party expenses of evaluating, making and monitoring investment activity including due diligence, travel (which may, per our travel policy, include first-class travel), and broken deal expenses; (ii) expenses (whether internal or external) of consultants, custodians, paying agents, registrars, bank service fees, accountants, brokers, servicers, financial advisors, investment bankers, legal, tax, accounting and other advice, (iii) expenses related to distributions, (iv) fees (including licensing fees) and expenses relating to adherence by fund entities with rules of any self-regulatory organization or applicable law in connection with Fund activities, including any governmental, regulatory, licensing, filing or registration fees, (v) expenses related to the compliance with the European Commission’s Sustainable Finance Disclosure Regulation (“SFDR”), (vi) expense of members of Investor Advisory Committees incurred in connection with attendance at an Investor Advisory Meeting, (vii) fees and expenses of any third-party AML Officer, (viii) fees and expenses related to: (A) market data and pricing services (e.g., Bloomberg, Expert Networks, Research Services), (B) document storage and obligations tracking systems for

(ii)

costs incurred in connection with meetings of Investors, including, but not limited to, costs to prepare and deliver materials for the conference, room and board, dining and transportation for attendees, as determined by the appliable Offering Documents.

(iii) Management Fees; (iv) any extraordinary expenses including all costs of a Fund’s indemnification, contribution or litigation, directly or indirectly, including, without limitation, attorneys’ fees incurred in connection therewith; (v)

the costs of any director, officer, general partner and management company liability or other insurance, extraordinary expense or liability relating to the affairs of a Fund;

(vi) the pro rata expenses of any subsidiary or special purpose vehicle in which a Fund invests; (vii) all expenses incurred in connection with any credit facility, subscription-line facility, working capital facility or other such indebtedness, including in connection with the repayment of any amounts, including principal, interest, expenses and costs under such credit facility; (viii) all expenses related to amendments to, waivers, consents or approvals pursuant to, Side Letters or similar agreements with Limited Partners including the tracking of such agreements and “most favored nations” election processes in connection therewith;

(ix) Fees related to the use of third-party Alternative Investment Fund Manager (“AIFM”) or paid to other management level entities where such fees are required by the rules that require and regulate the use of such entities in those jurisdictions; (x)

third-party administration, management, depositary and custody fees;

(xi) all expenses of liquidating a Fund and all fund owned investment vehicles; and (xii) any taxes levied in respect of a Fund, fees or other governmental charges levied against a Fund and all expenses incurred in connection with any tax audit, investigation, settlement or review of a Fund. Investor-borne expenses are generally allocated pro rata among the Investors, relative to their capital commitments in drawdown funds or net asset value in non-drawdown funds. Expenses borne by investors in the AB CarVal CLOs are described in the relevant governing documents and include expenses similar to those borne by the Funds. Fund Operating Expenses that are shared across multiple Funds will be allocated by AB CarVal among such Funds based on methodologies relative to (i) assets under management, (ii) market value, relative benefits to the applicable Fund(s), (iv) and/or such other criteria that AB CarVal believes to be fair and equitable taking into consideration the nature of such Fund Operating Expense. Certain Internal Fund Operating Expenses are allocated according to Fund assets under management rather than the cost of a specific service provided, which may not equal the benefit the Fund receives from the services provided. AB CarVal does not generally conduct external benchmarking of employee compensation for the specific purpose of evaluating Internal Fund Operating Expenses. AB CarVal maintains an office in Luxembourg for the benefit of many of its funds. The Funds that benefit from this structure bear all expenses associated with such office, including without limitation salaries and benefits, rent, utilities, IT expenses, other overhead and services. These expenses are generally paid by AB CarVal, with each of the relevant Funds reimbursing its proportionate share of expenses. The costs associated with pursuing broken deals generally are allocated among the Funds based on how such transaction would have been allocated to the Funds had it been successfully completed, including any funds in ramp up, subject to any specific requirements applicable to a Fund. More detailed information about the fees and/or expenses that a particular Fund may pay in connection with the advisory services that AB CarVal provides is contained in the relevant LPA or other governing documents entered into between AB CarVal and the

underlying Investors and the Offering Documents provided to such underlying Investors. In addition, please see Item 12—Brokerage Practices for a further discussion of the brokerage and other transaction costs that Funds pay. Other than as disclosed, neither AB CarVal nor its employees accept compensation for the sale of securities or other investment products to Funds.

Strategies and Risk of Loss AB CarVal focuses on investment strategies that fall within its core competencies in both developed and emerging markets. This includes pursuing select investments in “capital vacuums” of illiquidity and “orphaned” or “non-core” assets on the balance sheets of sellers and financial institutions. Additionally, AB CarVal will, from time to time, use its core competencies, skills, and methods to identify new asset categories for investment that are not already covered by their other investment programs. Each strategy involves significant risks, many of which are outside of AB CarVal’s control. Investing in securities and other investments involves significant risks, including the risk that Funds could lose some or all of any invested capital. An investment in a Fund will provide limited liquidity as there are significant restrictions on transferability of and withdrawals from interests in a Fund. A description of AB CarVal’s core investment strategies, as well as the risks that Funds may face in employing such strategies, is set forth below. A complete description of the risks associated with each particular investment strategy is included in the Offering Documents of the respective Funds, a copy of which is provided to prospective Investors and should be carefully reviewed prior to investing. Significant Investment Strategies AB CarVal generally focuses on the following key investment strategies: • Loan Portfolios—strategy centers on investments in portfolios of whole loans including consumer receivables, residential mortgages, small business loans, and other consumer, commercial and industrial obligations. This strategy also includes investments in performing residential solar loan portfolios, where the underlying borrowers are homeowners with a strong credit history and the loans are secured by the homeowners’ renewable energy assets. This strategy may also include investments in commercial real estate loan transactions, as well as real estate-related public debt and equity securities and loan portfolios containing real estate owned or other receivables. In executing this strategy, AB CarVal partners with a network of servicing and collections specialists, seeking to pair each portfolio with the servicing partner that is best positioned to maximize collections given the type and location of the obligations. This strategy may also include investments in or the origination of private debt to borrowers in various sectors, including loans to developers of solar power or storage projects.

• Corporate Securities—strategy centers on investments in obligations of leveraged and/or financially stressed and distressed corporations. These investments typically extend to mispriced or undervalued bonds, bank debt, credit default swaps and equities, but may also extend to other similar investment types or assets. From time to time, investments in this strategy will also include opportunistically investing in high-yield loans or debtor-in-possession financings to obligors, including, but not limited to, those who need cash quickly, are asset rich and liquidity poor or are in bankruptcy, as well as claims against bankrupt and liquidating businesses and entities. This strategy may also include performing debt secured by assets in or related to clean or renewable energy or providing energy usage efficiencies. Further, AB CarVal is an issuer of CLOs and will purchase secondary CLO equity opportunistically. • Structured Credit—strategy centers on investments in asset-backed securities including residential and commercial mortgage-backed securities, CLOs and other asset-backed securities. AB CarVal believes its capabilities and experience in whole loans, leveraged loans and commercial real estate provide a competitive advantage in investing in RMBS, CMBS, and CLO securities. Multiple AB CarVal teams routinely collaborate to evaluate investment opportunities in different structured credit securities. As well, AB CarVal is an active issuer of asset-backed securities across several different strategies including reperforming residential mortgages, aviation assets, residential solar loans and commercial real estate loans. • Hard Assets—these investments have historically included investments in aviation assets, certain types of vessels, and oil- and gas-related assets but may extend to any investment opportunity believed to be attractive and profitable under the circumstances. The strategy may also include investments in operating or development stage solar power generating and energy storage assets (held by a fragmented group of developers and investors with long-term contractual cash flows. • Special Opportunities—strategy centers on identifying undervalued situations across a broad range of asset categories, industries and markets that utilize AB CarVal’s core competencies, skills, and methods to identify and make investments in non-traditional asset categories that are not targeted through the above strategies. More detailed information regarding AB CarVal’s investment strategies and activities is set forth in the Offering Documents related to each Fund. General Methods of Analysis At the core of AB CarVal’s investment strategy is a rigorous investment selection and investment decision process which combines a top-down perspective and portfolio construction discipline with a bottom-up fundamental analytical approach. Considerable emphasis is placed on monitoring and reporting the performance of the ongoing investment portfolio. In evaluating potential investments, AB CarVal performs an extensive quantitative and qualitative analysis based on, among

other things, legal and financial due diligence (which may include reliance on third-party due diligence), information regarding environmental, social and governance matters that AB CarVal believes are material to the investment, and the experience and judgment of its investment professionals. AB CarVal structures deals to allow its Funds to invest on what it believes is a profitable and sustainable risk-adjusted basis and to provide flexibility in dealing with buyers, sellers, and operating partners. Consideration is given to targeted investment goals as well as existing market and sales trends in determining whether to continue to hold or sell an asset. AB CarVal seeks to continuously evaluate these factors to determine the appropriate timing for the disposition of any asset or group or category of assets. Material Risks The material risks presented by the strategies pursued by AB CarVal are summarized below. Additional information is set forth in the Offering Documents for each Fund. An investment in an AB CarVal Fund is speculative and involves the risk of loss of capital. AB CarVal neither guarantees nor represents that any Fund or investment will achieve its respective investment objectives or be able to avoid losses. A Fund may not be broadly diversified, and, therefore, the performance of one or a few investments could have a material adverse effect on the Fund’s investment returns. The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in one or more of the Funds or with each Registrant. The specific composition of investments in the Funds is difficult to predict, and thus it is not possible to disclose all the risk factors that may be relevant to an investment in each Fund or with each Registrant. The risk factors presented herein include those risks that the Registrants believe to be material and significant to significant investment strategies or methods of analysis employed by the Registrants. The risk factors outlined below may not be applicable to an investment in every Fund or with both Registrants. Investors are strongly encouraged to read the risks associated with their investment program, as contained in each Fund’s Offering Documents. Risks Related to the Funds Generally Legal and Regulatory Environment Applicable to the Registrants and the Private Funds and Registered Funds They Advise (including Interval Funds) The legal and regulatory environment for investment advisers, private investment funds and registered investment companies (including registered interval funds) is complex and continues to evolve in the United States and in other jurisdictions. As an SEC-registered investment adviser, AB CarVal and certain of its affiliates are subject to extensive regulation under the Investment Advisers Act of 1940 and other applicable laws and regulations, and their advisory and fund management activities are subject to examination, enforcement and interpretive positions by the SEC and other regulators. In addition, the private funds advised by AB CarVal are subject to regulation under the U.S. federal securities laws and other regimes (including offering, investor qualification, reporting and anti-fraud requirements),

and registered funds advised by AB CarVal (including interval funds) are subject to the Investment Company Act of 1940 and related SEC rules and guidance (including requirements relating to portfolio composition, liquidity, valuation, leverage and derivatives, custody, compliance programs and oversight by a board of trustees/directors). Changes in applicable laws, rules, regulatory interpretations or examination and enforcement priorities could require changes to AB CarVal’s or a fund’s structure, governance, operations, disclosures, fee arrangements or investment activities, could increase operating and compliance costs, and could limit investment flexibility or otherwise adversely affect AB CarVal’s ability to provide advisory services or to manage client assets effectively. Registered Fund Regulatory, Operational and Compliance Risks Registered funds, including interval funds, are subject to an extensive regulatory framework under the Investment Company Act of 1940 and related SEC rules, interpretations and disclosure requirements, as well as ongoing oversight by a board of trustees/directors and regulatory examinations. This framework may impose limits and conditions on investment activities and operations (including with respect to liquidity and liquidity risk management, valuation and fair value determinations, custody and safeguarding arrangements, use of leverage and derivatives, transactions with affiliates, co-investments and other joint arrangements, use of service providers, and portfolio concentration and diversification). Registered funds are also subject to detailed operational requirements relating to shareholder servicing, pricing and reporting, and, for interval funds, periodic repurchase offers and related liquidity planning and execution. These requirements may increase the complexity and cost of AB CarVal’s registered fund advisory business, may require enhancements to compliance policies and procedures and operational infrastructure, may constrain portfolio management flexibility, and may require a registered fund to modify its investment program or sell assets at inopportune times to satisfy regulatory or repurchase-related constraints. In addition, failure to comply (or allegations of non-compliance) could result in regulatory inquiries, fines, remedial measures, litigation, reputational harm, restrictions on AB CarVal’s activities, or other adverse consequences that could materially and adversely affect AB CarVal and the funds it advises. Compliance with Adviser and Registered Fund Regulatory Requirements May Constrain AB CarVal’s Activities and Increase Costs AB CarVal’s advisory activities and the operations of the private funds and registered funds it advises are subject to numerous substantive and compliance obligations that may change over time and may be interpreted differently by regulators, courts and market participants. For example, AB CarVal may be subject to, among other requirements, rules and guidance relating to fiduciary duty; disclosure and management of conflicts of interest; fees and expenses; performance reporting and advertising (including the SEC’s marketing rule);

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AB CarVal currently offers investment advisory services to private funds, single-investor vehicles, CLO vehicles, separately managed accounts, and non-discretionary accounts. The underlying Investors in the AB CarVal Funds and other investment vehicles are typically institutional investors (e.g., trusts, endowments, foundations, corporations, banks, insurance companies, public and private pension plans, private fund-of-funds, etc.) and high net worth investors meeting the terms of the exceptions and exemptions under which the Funds operate and wishing to invest in accordance with the Funds’ investment objectives. Generally, Investors must be both “accredited investors,” as defined in Rule 501(a) of Regulation D under the Securities Act of 1933, and “qualified purchasers”, as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “Investment Company Act”) or “knowledgeable employees” as defined in Rule 3c-5 under the Investment Company Act. In addition, beginning in 2024, AB CarVal Investors offers investment advisory services to a fund that is an investment company registered under the Investment Company Act of 1940.

Generally, the Offering Documents that govern each of the Funds require a minimum initial capital contribution prior to an Investor being admitted to a Fund. However, requirements for opening or maintaining accounts with AB CarVal can differ based on the applicable strategy and other factors in the discretion of AB CarVal. Accordingly, AB CarVal reserves the discretion in each of the Funds to adjust account size minimum with respect to any Investor.

AB CarVal Investors receives performance-based compensation from its Funds that is generally equal to a percentage of the net profits allocable to each Investor. For some Funds, performancebased compensation is not paid until specified performance thresholds are met. The specific terms governing the structure and calculation of performance-based compensation, which varies among Funds, are described in each Fund’s Offering Documents. AB CarVal reserves the right to reduce, waive or calculate differently such fees for certain Investors. In addition, certain single investor vehicles that AB CarVal may manage from time to time may pay or not pay fees to AB CarVal in a separately negotiated manner, including, but not limited to paying part or all of their fees to AB CarVal based on the performance of their investments. These terms will vary, and Investors should consult the Offering Documents of their applicable Funds. The Funds charge performance-based compensation of up to 25% of the net profits allocable to each Investor. The method each Fund utilizes in assessing and charging performance-based compensation varies pursuant to the terms of the applicable Offering Documents. Performance-based compensation is generally assessed annually at year end for evergreen Funds and during the harvest period of closed-end Funds, but, for some Funds, may be assessed at other times, such as quarterly or in connection with a distribution of redemption proceeds to an investor. Performance-based compensation may be subject to a highwater mark and may be adjusted for hurdle rates and holdbacks or clawbacks, pursuant to the terms of the applicable Offering Documents. CCML is eligible to receive performance-based compensation from the AB CarVal CLOs, typically 20% of the excess cash flows due to the holders of the subordinated notes, subject to a stated hurdle rate. Performance-based compensation creates a potential conflict of interest in that it may create an incentive 1) to make investments that are riskier or more speculative than in the absence of such a performance-based fee, and 2) to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. As a general matter, AB CarVal believes that it mitigates these potential conflicts by requiring senior employees to invest their own money in each of its commingled Funds. Further, AB CarVal follows procedures it believes are reasonably designed to ensure that all Funds are treated equitably over time and to prevent conflicts from influencing allocation decisions among Funds. AB CarVal’s allocation procedures are further described in

Item 12—Brokerage Practices. AB CarVal recognizes that it is a fiduciary and as such must act in the best interests of the Funds. Because of the nature of many of AB CarVal’s underlying investments, a significant portion of assets rely on internal analysis using mark-to-model methodologies that may include discounted cash flow analyses. Such analyses are inherently subjective. Changes in underlying assumptions and/or economic and market factors may have a material impact on the returns on which performance-based compensation is calculated. AB CarVal has adopted and implemented a valuation policy that governs the pricing of securities and other assets held by the Funds (the “Valuation Policy”). The Valuation Policy generally provides that liquid investments will be valued at readily ascertainable market values. In some circumstances, AB CarVal may be able to obtain a market value from only one source. For assets that lack such a readily ascertainable market value, the Valuation Policy requires AB CarVal to determine a value using various valuation methodologies as set forth in the policy. In valuing certain privately placed and less liquid assets, AB CarVal has considerable discretion. AB CarVal generally faces a conflict of interest in valuing assets because their value can impact certain of the fees payable to AB CarVal and the performance returns of the Funds. AB CarVal is responsible for determining the fair market value of each Fund asset. The methodologies used are inherently subjective and capable of producing a range of values that may be different from valuations performed by others applying their own judgment at different or similar dates. There is no guarantee that the valuations determined by AB CarVal represent values that can or will be realized in a sale or exchange of investments with an independent third party. AB CarVal documents its valuation decisions and reviews them on a periodic basis. On an annual basis, AB CarVal’s valuations are reviewed in connection with each Fund’s independent external audit.

Affiliations As described in more detail in Item 4—Advisory Business, CarVal Investors GB LLP, AllianceBernstein (Singapore) Ltd. and CarVal Wensheng Private Fund Management (Shanghai) Co., Ltd. are included as participating affiliates on AB CarVal Investor’s Form ADV. In addition, as mentioned in Item 4—Advisory Business, CCML, also an AB CarVal subsidiary, provides management services to AB CarVal CLOs, which are also portfolio investments for certain Funds. CCML has entered into a staff and services agreement with AB CarVal Investors pursuant to which it compensates AB CarVal Investors for providing certain services to CCML. Moreover, certain employees of AB CarVal Investors involved with the AB CarVal CLOs are shared employees with CCML. CCML files a separate Form ADV; however, this Form ADV Part 2A covers the activities of both AB CarVal Investors and CCML. AB CarVal employees at times serve on boards of directors, creditor committees or in other management capacities at companies in which the Funds invest. This may expose AB CarVal and its Funds to certain limitations on the ability to trade the securities of the issuer company and certain conflicts of interest. As a result of such service, an employee may become aware of material non-public information about the company in which the Funds invest, which could substantially restrict the Funds’ ability to trade the securities of such company. Such limitations may cause the Funds to forgo sales or purchases that they would otherwise make, thereby exposing the Funds to losses and lost opportunities. AB CarVal maintains policies and procedures that are intended to minimize the negative effects of such conflicts if they arise. However, there can be no guarantee that such activities will not result in less favorable results for the Funds than if the employee were not permitted to serve in such capacity. In the past, AB CarVal has purchased certain assets from third parties and warehoused all or part of these assets (“Warehoused Assets”) in anticipation of future AB CarVal fund launches. AB CarVal may deem some or all of these assets to be appropriate for future funds after they have launched. AB CarVal will partially or fully capitalize such Warehoused Assets with an equity and/or debt contribution. Alternatively, either may obtain secured financing for the purchase of Warehoused Assets. At a later point in time, typically at or around the time of the first admission of Investors to a relevant Fund, and after obtaining explicit consent from the Fund’s Investors, Warehoused Assets may be purchased by an AB CarVal Fund. Transfer pricing for Warehoused Assets will be determined by AB CarVal at the time of the transfer, which poses a potential conflict of interest with the Fund acquiring the assets. The basis for any transfer pricing will be disclosed to Investors before they subscribe to the Fund. To date such purchases have been made for cost, adjusted for expenses including those associated with any purchase price financing. AB CarVal is not under any obligation to transfer any

particular Warehouse Asset to a Fund and there may be times when it chooses not to transfer certain Warehoused Assets. AB CarVal’s decision not to transfer certain Warehoused Assets may conflict with the interests of the Fund that would have been the recipient of the assets. In certain circumstances, AB CarVal or certain of its affiliates may make loans to Funds in order to allow them to acquire assets. Typically, these loans are made to allow a Fund to acquire assets prior to a closing on capital commitments or prior to a capital call. The terms of these loans will be arms-length in nature and are disclosed to Investors pursuant to the applicable Offering Documents or if they are made prior to a capital call will be reviewed with investors in the manner set forth in such Fund’s Offering Documents. Asset Managers AB CarVal frequently uses third-party asset managers to manage assets owned by its Funds and may delegate to such asset managers some or all management responsibilities. There can be no guarantee that asset managers will have the resources or skills to effectively perform these functions. The asset managers enter into servicing relationships with the Funds (or their investments). All such services are performed by the asset manager’s personnel, not by personnel of other affiliates of AB CarVal, and AB CarVal does not exercise day-to-day control over or management of the asset manager. Asset managers are not generally controlled by AB CarVal, and they may not be required to direct investment opportunities to the Funds or spend a specified portion of their time managing investments held by the Funds. While asset managers may provide a source of deal flow, familiarity with markets and management expertise, there is no guarantee that they will in fact do so, and there can be no guarantee that actions or omissions on their part will not result in material adverse consequences to the Funds. Several conflicts of interest are inherent in AB CarVal’s use of asset managers. Asset managers may co-invest in and receive a share of the profits from the assets they manage. Since asset managers may manage assets held by the Funds and assets not held by the Funds, asset managers may face conflicts of interest relating to choices that may favor one investment over another, as well as decisions regarding devotion of time and resources. AB CarVal or certain Funds have ownership or other financial interests (e.g., owning shares or membership interests, providing loans to or obtaining warrants in the asset manager) in one or more asset managers, operating partners (“affiliated asset managers”) or service providers (“affiliated servicer platforms”). Both affiliated and unaffiliated asset managers and servicer platforms may enter into administrative or servicing relationships with the Funds. Ownership of or financial interest in an asset manager or service provider by AB CarVal or Funds may create certain conflicts among AB CarVal and the Funds or among different Funds. For instance, in a situation where one or more Funds has an

ownership interest in an affiliated servicer platform, AB CarVal could allocate all or a portion of an investment opportunity that will be serviced by the affiliated asset manager to a Fund that does not have an ownership interest in the affiliated asset manager. In that case, only the Fund or Funds that have an ownership interest in the affiliated asset manager would benefit from the servicing fees generated by the investment. AB CarVal intends for fees generated in this manner that are payable by the Funds to be fair and reasonable over time and not less favorable than could be obtained in an arms-length negotiation with an unrelated third party for similar services. Further, AB CarVal’s investment process, investment allocation policy and other controls (including those set forth in the Offering Documents of the Funds in question) mitigate the risk of such conflict. In most instances, AB CarVal does not anticipate that it would offset the management fees it charges to the Funds by the amount of fees paid by the Funds to Affiliated Asset Managers and/or affiliated servicer platforms to the extent those Affiliated Asset Managers and/or affiliated servicers were owned by AB CarVal and not the Funds. AllianceBernstein’s Advisory Affiliates and Majority Shareholder As also mentioned in Item 4—Advisory Business, AB CarVal is a wholly owned subsidiary of AllianceBernstein L.P, which is also a registered investment advisor, and has multiple investment teams and financial industry affiliates. Investment activities by AB or its affiliates could create potential conflicts of interest with AB CarVal and its Funds, including that AB affiliates may (i) pursue investment opportunities that are similar to, or compete with, opportunities pursued by AB CarVal, (ii) invest in different levels of an issuer’s capital structure, or (iii) utilize certain shared resources or personnel from time to time. AB CarVal seeks to mitigate these potential conflicts through independent investment decision-making and information-sharing controls, including limitations on dissemination of confidential or material non-public information within AB and its affiliates. See AllianceBernstein L.P. ADV (CRD # 108477/SEC#:80156720) Part 2A: Item 10—Other Financial Industry Affiliations for a list of AB’s affiliated brokers, affiliated advisors, and other related entities. In addition, AB’s controlling shareholder, and its broker-dealer affiliates, are involved in other financial services businesses. As controlling shareholder of AB, EQH has the ability to influence AB’s business which includes AB CarVal as a wholly-owned subsidiary of AB. However, when conducting its investment activities, AB CarVal allocates investment opportunities to all of its clients in a particular strategy according to the same principles of fair and equitable treatment, including EQH. Further, as a matter of policy and practice, AB CarVal does not collaborate with EQH on any investment decisions, and AB CarVal does not involve EQH personnel in any of its research processes. AB is also financially independent of EQH.

Transactions & Personal Trading Code of Ethics AB CarVal maintains a Code of Ethics (the “Code”) designed to govern the conduct of AB CarVal and its personnel, and to address potential conflicts that might arise in the context of personal trading and other employee activities. Upon employment, and annually thereafter, employees of AB CarVal acknowledge the terms of the Code. Employees who are subject to personal trading restrictions are identified in the Code as “Access Persons.” Pursuant to the Code, Access Persons must conduct their personal securities transactions (and those of certain members of their families) in compliance with the Code and must avoid taking inappropriate advantage of their positions within AB CarVal. Access Persons must provide annual holdings reports and quarterly transaction reports in accordance with Rule 204A-1. The Code permits Access Persons to invest for their personal accounts, but requires them to pre-clear all personal securities transactions involving reportable securities and to abide by the guidelines and restrictions set forth in the Code. AB CarVal maintains a restricted securities list containing the names of securities which Access Persons are generally prohibited from trading. The Code also generally restricts an Access Person from purchasing or selling securities held or traded by a Fund, and subjects certain employees to enhanced scrutiny based on their functions and duties. AB CarVal periodically reviews personal securities transactions and holdings reports in an effort to ensure that employees do not take advantage of their knowledge of activities in the Funds to benefit personally. The Code also addresses other obligations and requirements for AB CarVal employees including a section on outside business opportunities. Copies of the Code are available to any Investor or prospective Investor upon request to ADVrequests@abcarval.com. AB CarVal maintains separate policies that addresses various matters such as gifts and entertainment, political contributions, and conflicts of interest. Insider Trading In the course of providing investment advisory services, AB CarVal may come into possession of material, nonpublic and other confidential information which may limit AB CarVal’s ability to direct the purchase or sale of certain investments. For example, AB CarVal may enter into a confidentiality agreement, or an employee of AB CarVal may serve as a director or member of a creditor committee with respect to companies whose securities may be purchased or sold on behalf of the Funds. At times AB CarVal, in an effort to avoid investment restrictions with respect to the Funds, may elect not to receive information that is available to other market participants or counterparties. If an AB CarVal employee obtains material non-public information

with respect to any company, AB CarVal may be prohibited for a period of time from engaging in transactions on behalf of some or all its Funds with respect to the securities of such company, which may have an adverse effect on such Funds. While AB CarVal has designed and implemented policies and procedures reasonably designed to limit those situations, and to prevent the misuse of material, non-public information, there can be no guarantee that such policies and procedures will be successful or that investment restrictions will not occur. Interest in Client Transactions The general partner for the Funds is, in each instance, a wholly owned subsidiary of AB CarVal Investors. Please see Item 6—Performance-Based Fees and Side-by-Side Management regarding performance fees that may be paid by a Fund to AB CarVal. AB CarVal manages a variety of Funds and a particular AB CarVal Fund may not have the exclusive right to any investment opportunity. Item 12—Brokerage Practices includes a discussion of the allocation of investment opportunities. In addition, certain senior employees of AB CarVal are generally required to invest in AB CarVal’s commingled Funds, as set forth more fully in the Offering Documentation of each Fund. It is expected that the size and nature of such investments in any particular Fund will change over time and without notice to Investors. Such investments could incentivize the senior management and key employees to increase or decrease the risk profile of the Fund. AB CarVal’s employees may have conflicts in allocating their time and services among Funds. AB CarVal’s employees will devote as much time to each Fund as AB CarVal deems appropriate to perform its duties in accordance with the Fund’s Offering Documents. Furthermore, the AB CarVal Funds invest from time to time in securities issued by CLOs for which CCML acts as the investment adviser. To the extent that fees due to CCML are attributable to the interests owned by the Funds, such fees are ultimately borne by AB CarVal Investors and not the Funds, mitigating the conflict of interest that such investments may present. Additionally, certain AB CarVal Funds may invest in securities of certain AB CarVal CLOs in a manner whereby they own a higher percentage of securities in one AB CarVal CLO (or one tranche of an AB CarVal CLO) versus another AB CarVal CLO (or another tranche within the same AB CarVal CLO). AB CarVal may act in the interests of such Funds in certain cases where the interests will conflict with or be adverse to the interests of other holders of securities in that or other AB CarVal CLOs. AB CarVal Funds may also take majority control positions in AB CarVal CLOs. These positions may give the Funds the ability to exercise voting control with respect to matters including, without limitation, any vote to direct a redemption or refinancing of an AB CarVal CLO and any vote to accelerate or not accelerate the payment of certain AB CarVal CLO securities. CCML acts in its own interests with respect to such securities and in certain cases

such interests conflict with or may be adverse to the interests of other holders of securities in AB CarVal CLOs. Potential conflicts due to shared and overlapping Fund Investments Where AB CarVal Funds hold the same investment, the differing investment objectives of such Funds may result in a decision to sell or hold all or a portion of an investment on behalf of a Fund at different times as such investment or portion thereof is being sold or held by other Funds. Conflicts of interest may also arise when disposing of a particular investment would be beneficial for one Fund while retaining such investment would be beneficial for another Fund. In some instances, investments may not be divisible, and must be sold or held in their entirety. In such cases the decision to sell or hold an investment may be more beneficial or detrimental to one Fund than another. Further, there may be instances where investments are not divisible among eligible Funds prior to their acquisition as a result of, among other reasons, the timing of the transaction, tax, regulatory or legal issues, or significant operational burdens associated with dividing such investments. Specifically, such investments often include, but are not specifically limited to, investments in loan portfolios, securitization vehicles and hard asset investments such as aviation or shipping vessels. In such instances, AB CarVal may determine it is in the best interests of the Funds to acquire such investment into one eligible Fund and divide the investment among, or participate the investment to, all eligible Funds as soon as practicable after the acquisition, often by contributing the asset to a special purpose investment vehicle in which each eligible Fund receives an ownership interest commensurate with the portion of the investment that has been allocated to it. In connection with such division or participation, AB CarVal will endeavor to ensure that each eligible Fund’s ownership or participation in such investment will be segregated from each other eligible Fund in terms of, among other items, payment obligations, covenants and benefits, but in some cases AB CarVal may not be able to accomplish such segregation. Similarly, if any such shared investment is financed, one or more of the eligible Funds may be required to provide guarantees, collateral or other credit enhancement and as a result Funds sharing such investments may be exposed to counterparty risk of other Funds participating in the investment. Again, AB CarVal will endeavor to ensure that each eligible Fund is responsible ultimately for only its share of the financing obligations, but in some cases AB CarVal may not be able to do so. In some instances, legal or regulatory restrictions—including but not limited to those imposed by the Investment Company Act of 1940—apply to certain of the funds, and such restrictions may affect decisions about which Funds participate in an investment and how transactions are structured. In particular, in relation to a registered investment company, applicable law may at times prevent such fund from being able to participate in investments that it otherwise would participate in, and may require such fund to dispose of investments at a time when it otherwise would not dispose of such investment, in each case, in order to comply with applicable law. In addition, a registered

investment company relies on exemptive relief in order to be able to co-invest alongside other funds managed by AB CarVal, and the conditions and requirements of the exemptive relief could limit the registered investment company’s ability to participate in certain co-investment transactions. There can be no assurance that the return on one Fund’s investments will not be less than the returns obtained by other Funds participating in the same investment. Regarding securitization vehicles that are comprised of assets contributed by the AB CarVal Funds, AB CarVal will employ its standard valuation procedures when determining the value of the assets (e.g., whole loans) in connection with the transfer of such assets to the securitization vehicle, but the value that contributing AB CarVal Funds receive for such contributions in the form of cash or securities may not equal what such Funds would have received upon the sale of such assets to third parties. The AB CarVal Funds will not be required to take any action or refrain from taking any action to mitigate another Fund’s losses in such a scenario even if such decision may result in losses to a Fund, and AB CarVal will make decisions on how to resolve such situations in its sole discretion. Securitizations of assets may present a conflict of interest related to equity ownership and risk retention requirements that apply in certain jurisdictions. Risk retention requirements mandate that the sponsor or originator of a securitization retain a certain percentage of the securities and other asset-backed interests offered by the issuer. Where the sponsor or originator is a vehicle owned by multiple Funds, each of which has its own liquidity terms and investment horizon that may differ from that of the other Funds, a conflict may arise with respect to how the risk retention portion of the vehicle is allocated. For instance, a Fund with a shorter investment horizon may benefit from having another Fund hold the risk retention portion, which is subject to a required hold period, while the latter Fund has a portion of its capital tied up in the risk retention portion of the securitization rather than being able to invest this capital in other ways. Liquidity concerns in one Fund may require that Fund to sell its interests in the risk retention vehicle which may result in a trade between Funds. AB CarVal will endeavor to resolve such situations in a manner that is fair and equitable to all Funds involved. Further, from time to time, certain Funds may combine to own all of the equity of an AB CarVal-managed securitization vehicle. Further conflicts may arise if a Fund executes an investment in which one or more Funds have already invested. For example, questions may arise as to whether payment obligations and covenants should be enforced, modified or waived, or whether debt should be refinanced. Decisions about what actions should be taken in a distressed situation, including whether to enforce claims or whether to advocate or initiate a restructuring may raise conflicts of interest. In addition, a Fund may participate in restructuring or recapitalization transactions (including those requiring additional investments of capital) involving companies in which other Funds have invested or may invest. These transactions may present conflicts of interest,

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Selection Criteria for Brokers-Dealers—Best Execution The primary criterion AB CarVal uses to select brokers is their ability to provide best execution. In assessing best execution, and its overall broker relationships, AB CarVal considers a variety of qualitative and quantitative factors. AB CarVal will consider all or some of the following factors in selecting brokers: price, likelihood of execution, likelihood of execution within a desired time frame, market conditions, ability of a counterparty to execute in desired volume, ability of a counterparty to act on a confidential basis, ability of a counterparty to act with minimum market effect, creditworthiness of a counterparty in relation to risk created by the transaction, willingness and ability of a counterparty to make a market in particular securities, operational coordination with AB CarVal and the Funds’ custodians, reputation for ethical and trustworthy behavior, willingness of the counterparty to commit capital to a transaction, a counterparty’s market knowledge and as applicable the value of research provided, ability of a counterparty to source and/or execute difficult transactions in unique and/or complex securities, and identification of key components of favorable and efficient executions. Although AB CarVal generally seeks competitive commission rates, it is not required to solicit competitive bids or seek the lowest available commission or transaction costs. In seeking to obtain best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services. Commissions are negotiated with the broker on the basis of the quality and quantity of execution services that the broker provides, in light of generally prevailing commission rates with respect to any securities transactions involving a commission payment.

Many of the investments that AB CarVal manages involve specialized services or unique sourcing considerations that may result in higher commissions or their equivalents than would be the case with transactions requiring more routine services. As a result, AB CarVal anticipates that the commissions paid on its transactions may be higher on average than its peers that invest in more generic or widely traded securities. The reasonableness of commissions is based on the broker’s ability to provide professional services, competitive commission rates and other services that will help AB CarVal in providing investment management services to clients. The limited availability of many of the investments managed by AB CarVal will also impact the selection of a broker-dealer and the related commission will likely be higher than industry averages. Soft Dollar and Directed Brokerage Policies From time to time, AB CarVal may pay a broker-dealer commissions for effecting Fund transactions in excess of that which another broker-dealer might have charged for effecting the transaction in recognition of the value of the brokerage and research services provided by the broker-dealer. AB CarVal effects such transactions, and receives such brokerage and research services, only to the extent that they fall within the safe harbor provided by Section 28(e) of the Exchange Act and subject to prevailing guidance provided by the SEC regarding Section 28(e). AB CarVal believes it is important to its investment decision-making processes to have access to independent research. Also, consistent with Section 28(e), research products or services obtained with “soft dollars” generated by the Fund may be used by AB CarVal to service one or more other Funds, including Funds that may not have paid for the soft dollar benefits. AB CarVal does not seek to allocate soft dollar benefits to Funds in proportion to the soft dollar credits the Funds generate. Where a product or service obtained with soft dollars provides both research and non-research assistance to AB CarVal (i.e., a “mixed use” item), AB CarVal will make a good faith allocation of the cost which may be paid for with soft dollars. In making good faith allocations of costs between administrative benefits and research and brokerage services, a conflict of interest may exist by reason of AB CarVal’s allocation of the costs of such benefits and services between those that primarily benefit AB CarVal and those that primarily benefit the Funds. When AB CarVal uses brokerage commissions (or markups or markdowns) generated by any Fund to obtain research or other products or services, AB CarVal receives a benefit because it does not have to produce or pay for such products or services. AB CarVal may have an incentive to select or recommend a broker-dealer based on AB CarVal’s interest in receiving research or other products or services, rather than on a Fund’s interest in receiving most favorable execution. In some instances, in accordance with MiFID II and FCA rules governing the payment for investment research, AB CarVal

may obtain research from brokers or other research providers through a number of permitted payment arrangements. Where AB CarVal pays separately for research provided by a broker, these costs are separately negotiated and do not involve soft dollar payments. The cost of such research may be borne by the Funds, in accordance with the practices described in Item 5— Fees and Compensation and each Fund’s Offering Documents. From time to time, AB CarVal participates in capital introduction events, including events hosted by certain broker dealers that act as prime brokers on behalf of AB CarVal Funds. However, AB CarVal does not consider whether it receives Investor referrals in deciding (i) whether to participate in such events or (ii) the manner in which it selects broker-dealers. In addition, AB CarVal does not allocate Fund brokerage business to a broker-dealer unless AB CarVal determines in good faith that the commissions payable to such broker are consistent with seeking best execution as discussed above. Finally, neither AB CarVal nor its Funds compensate such third-party brokers for introducing AB CarVal to potential Investors or for any investments ultimately made by such Investors. However, such introductions AB CarVal may receive could present a potential conflict of interest to the extent AB CarVal uses such brokers in connection with brokerage, financing and other activities on behalf of its Funds. AB CarVal has discretion in deciding which broker-dealer its Funds will use and in negotiating the rates of commissions that Funds will pay. AB CarVal does not participate in directed brokerage commission arrangements and does not accept directed brokerage instructions from any Investor. Principal & Cross Trades On occasion, AB CarVal may determine that it is appropriate and in the best interests of Funds if a Fund purchases an investment from another Fund or AB CarVal. Internal review and approval is required for any proposed principal or cross trade. AB CarVal may seek, when appropriate or required, Investor pre-approval for such transactions consistent with the respective Funds’ Offering Documents and in accordance with Section 206(3) of the Investment Advisers Act of 1940. AB CarVal will also adhere to other legal restrictions on principal and cross trades including, if applicable, Section 17(a) of the Investment Company Act of 1940 and ERISA. To the extent AB CarVal determines to engage in any cross trades, it will do so only upon a determination that such transaction is in the best interests of each of the participating advisory client accounts and with the consent of the relevant advisory client if consent is required by applicable law, contract or in other appropriate circumstances as determined by AB CarVal. In addition, any cross trades affecting RICs are subject to the requirements of Rule 17a-7 under the Investment Company Act of 1940, as amended. In connection with seeking such approvals, AB CarVal, to the extent it deems practicable, will seek third-party valuation or verification of values for the securities involved in any principal or cross transaction and will make the relevant valuation data available to Investors in connection with seeking their consent. Given the restrictions imposed by ERISA

on engaging in cross trades, AB CarVal does not include ERISA accounts in cross trades even where AB CarVal could achieve reduced transaction costs for its clients by doing so. Allocation of Investment Opportunities In some circumstances, Funds with similar objectives may invest in the same investment opportunities at the same time. As set forth in greater detail in Item 11—COE, Participation or Interest in Client Transactions & Personal Trading, AB CarVal allocates investment and trading opportunities among the Funds in a manner believed by AB CarVal to be fair and equitable to each Fund over time. However, there can be no guarantee that a Fund will participate in any particular investment opportunity on an equal or pro rata basis with other Funds. In making these allocation decisions, AB CarVal considers a number of factors in an effort to construct balanced investment portfolios for each of the Funds that will provide appropriate risk adjusted returns to the Investors. These factors may include, along with other relevant factors relating to the particular investment and particular funds, any of the following for each respective Fund: (a) investment objectives and guidelines, (b) current and prospective liquidity, (c) overall size, (d) remaining period to make new investments, (e) overall current exposure to investments of a similar nature, (f) ramp-up or wind-down period, and/or (g) appetite or tolerance for risk/volatility. AB CarVal may determine that certain investments should be made by some and not by other Funds. AB CarVal may cause certain Funds to participate in the same investments in a different manner from other Funds. AB CarVal may also determine that an investment which is allocable to multiple Funds, for legal, regulatory, operational, tax or a similar reason, will only be allocated to one Fund, with the understanding that AB CarVal will endeavor to share similar investment opportunities in the future with other eligible Funds in a fair and equitable manner. Due to the different manner in which they participate, there may be different economic consequences to different Funds participating in the same investment opportunity. Additionally, Funds may invest in different levels of an issuer’s capital structure. See description of Investments in Multiple Positions Within One Issuer in response to Item 11— COE, Participation or interest in Client Transactions & Personal Trading. Consequently, AB CarVal may determine that the sale of such investments by certain Funds may not be appropriate for a number of reasons, including if such sale could be detrimental to other Funds. In such instances, AB CarVal will not be required to act only in the best interests of any one Fund. In addition, the Investment Company Act of 1940 imposes significant limits on the ability of a registered investment company to co-invest with its affiliates, including other funds managed by the same investment adviser. AB CarVal and the registered investment company it advises have received an exemptive order from the SEC that permits the registered investment company to co-invest alongside its affiliates in investments, subject to certain conditions that limit or restrict the registered investment company’s ability to participate in such investments.

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AB CarVal utilizes third-party placement agents or solicitors in connection with the sale of interests in certain Funds to underlying Investors and compensates such third parties for their services. Such third-party placement agents typically receive a retainer fee and/or fees based on aggregate capital commitment or capital contributions to the relevant Funds. The amount of such compensation may be greater if the applicable Fund accepts greater amounts of Investor commitments and invests a greater amount of capital. AB CarVal utilizes firms including certain affiliated firms in connection with fundraising. Any compensation paid to third-party placement agents or solicitors in connection with the sale of interests in certain Funds to underlying Investors is ultimately borne by AB CarVal.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to an evaluation of each of the Registrants or the integrity of their management. The Registrants have no legal or disciplinary events that they believe would be material to an Investor’s or prospective Investor’s evaluation of the Registrants’ business or the integrity of their management. AB CarVal is a wholly owned subsidiary of AB. Please refer to AllianceBernstein L.P. ADV (CRD # 108477/SEC#:801-56720) Part 2: Item 9– Disciplinary Information for more information on AB’s disciplinary history.

Account Review AB CarVal’s investment professionals are responsible for ongoing diligence and reviews of investments entered into on behalf of the Funds. These investment professionals review investments on a periodic basis, and in some cases as frequently as daily. Key items reviewed include comparing an investment’s actual performance versus its anticipated performance. AB CarVal maintains an investment supervisory structure and escalation procedure with respect to investment limits. AB CarVal also maintains a portfolio investment committee that includes AB CarVal’s managing principals, risk manager, general counsel, and chief operating officer. While investment professionals are generally responsible for making investment determinations on behalf of the Funds, the portfolio investment committee establishes investment limits, as necessary, and performs a monthly review of investments made on behalf of the Funds, which may include allocation determinations, established thresholds, and limits. In some circumstances, the committee reviews and approves transactions prior to the transaction. Such review and approval is conducted by a sub-committee consisting of the portfolio investment committee members as well as the senior leaders for the relevant investment team. An independent auditor annually audits each Fund’s financial statements. As described in previous sections, AB CarVal advises Funds on a wide variety of investments. Many of these investments require regular asset management and oversight to ensure that valuation projections, which are determined at asset acquisition, are being realized. Such positions are often monitored through

proprietary models, which enable AB CarVal to identify variations from valuation projections and take appropriate measures as necessary. For other investments, such as those in corporate securities and equity markets, AB CarVal from time to time utilizes, among other things, directional and relative value strategies based on macroeconomic fundamental analysis and market momentum analysis to monitor investments. Nature and Frequency of Regular Reports Investors receive an individual statement of capital account prepared by AB CarVal on a monthly or quarterly basis as determined by the requirements of each Fund. In addition, AB CarVal may prepare and communicate estimated monthly performance figures to Investors if required by the Offering Documents of a Fund. Currently, some of the regular reports are prepared by a third-party administrator. Portfolio reports and unaudited financial statements are provided on a quarterly basis. On an annual basis and to the extent applicable, Investors also receive an individual tax form and a copy of the audited financial statement for the Fund(s) in which the Investor has invested. Single investor vehicles, if any, will generally receive reports with the same frequency as the other Funds or as otherwise determined on a case-by-case basis and may also be reviewed by an independent public accountant, resulting in the production of annual audited financial statements. For additional information related to the types and frequency of reports provided to Funds and single investor vehicles, please see the relevant Offering Documents, to the extent applicable. Certain Investors may receive supplemental or additional information from time to time, either upon request or pursuant to side letter arrangements. AB CarVal CLO investors may access periodic reports from the AB CarVal CLO trustees, generally using a web-based portal. These reports will include detailed information about the AB CarVal CLOs’ portfolio holdings as well as the performance of the securities issued by such AB CarVal CLOs.

AB CarVal does not serve as the qualified custodian of any of the assets owned by the Funds and does not maintain physical custody of any certificated securities or cash owned by the Funds. However, in connection with the services AB CarVal provides to its Funds, AB CarVal or entities that are wholly owned by AB CarVal may, among other things, act as a general partner of a Fund or have investment discretion with respect to a Fund investment. As a result of such powers, AB CarVal is deemed by the applicable regulatory rules to have constructive custody of the assets of each Fund for purposes of the custody rule of the Investment Advisers Act. AB CarVal satisfies the applicable regulatory requirements related to custody by, among other things, ensuring that 1) each Fund is subject to an annual audit by an independent accounting firm that is registered and examined by the Public Company Accounting Oversight Board, and 2) audited financial statements for each Fund are delivered to the Investors in the Funds within the applicable required time frame.

AB CarVal votes proxies for the exclusive benefit of and in the best economic interest of the relevant Fund, as determined by AB CarVal in good faith. Proxies are an asset which will be treated by AB CarVal with the same care, diligence, and loyalty as any other asset. While AB CarVal is not required to vote every proxy, AB CarVal exercises its voting responsibilities in a manner that is consistent with its fiduciary duties to the Funds. Consideration is given to both the short- and long-term implications of the proposal to be voted on when considering the optimal vote. There may be times when refraining from voting is in the best interest of a Fund, such as when AB CarVal’s analysis of a particular proxy reveals that the cost of voting the proxy may exceed the expected benefit to the Fund. Before voting, AB CarVal shall reasonably assess any material conflicts between AB CarVal’s interests and those of its Funds with respect to proxy voting. If a conflict of interest arises in respect to voting a proxy, the investment team and the Compliance Department will evaluate the proposal to determine the appropriate vote which is in the best interest of the respective Fund.

CCML does not have custody of the assets of AB CarVal CLOs.

Item 16—Investment Discretion With respect to the majority of its assets under management, AB CarVal has full discretion and authority to make all investment decisions with respect to the types and amounts of securities to be bought or sold for its Funds, except that such discretion is to be exercised in a manner consistent with the stated investment objectives and guidelines for the particular Fund. When selecting securities and determining amounts, AB CarVal observes the investment policies, limitations and restrictions of the Funds. The Funds’ Offering Documents and/or LPAs may place limits on the types of securities, issuers or industries in the portfolio or the types of investment techniques that may be used in managing the Fund portfolio. The exercise of AB CarVal’s investment discretion includes, but is not limited to, the determination of: • When to buy or sell. • Which investments to buy or sell. • The total amount of investments to buy or sell. • The broker, dealer or other institution through which investments are bought, sold or managed. • The prices at which investments are to be bought or sold, which may include spreads, mark-ups, fees and transaction costs payable to one or more third parties.

If class action documents are received by AB CarVal on behalf of its Funds, AB CarVal will ensure that the Funds either participate in or opt out of any class action settlements. The process for determining actions to be taken in response to class actions is carried out pursuant to a policy maintained by AB CarVal, with responsibilities lying with AB CarVal and the Funds’ custodian. A copy of AB CarVal’s Proxy Policy and information on how proxies were voted may be obtained by contacting AB CarVal at ADVrequests@abcarval.com.

Each registered investment adviser is required to disclose whether it has any financial condition that could impair its ability to meet its contractual commitments to its clients, and whether it has been the subject of a bankruptcy proceeding. The Registrants do not have any adverse financial conditions to disclose and have not been the subject of a bankruptcy petition at any time during the past ten years. The Registrants do not charge or solicit pre-payment of more than $1,200 in fees per Client, six months or more in advance. Accordingly, the Registrants are not required to include a balance sheet for their most recent fiscal year.

• How to manage the investments after acquisition, including, for example, whether to engage an asset manager or other third-party service provider. Certain Funds and accounts managed by AB CarVal are non-discretionary. In the case of single investor vehicles, AB CarVal may have full discretion as described above, may share discretion, or may manage such accounts on a non-discretionary basis. For the AB CarVal CLOs, CCLM is granted discretionary authority through the relevant vehicle’s governing documents.

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