Eagle Point Credit Management LLC

General Eagle Point Credit Management LLC (“Eagle Point” or the “Firm”) was established in November 2012 and has been registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser since March 2013. Eagle Point provides investment advisory services to (1) privately offered pooled investment vehicles, (2) separately managed accounts, and (3) closed-end registered investment companies (collectively, the “Accounts”), pursuant to separate investment advisory agreements between Eagle Point and each applicable client. The investment advisory services provided by Eagle Point are generally discretionary in nature; however, Eagle Point may provide non-discretionary investment advisory services to one or more Accounts from time to time. Eagle Point’s investment advisory services primarily relate to, and are primarily limited to, the following types of investments: (1) equity and debt tranches of CLOs and similar securitization vehicles (including loan accumulation facilities); (2) debt and preferred equity securities, and similar instruments, issued by various types of pooled investment vehicles, including business development companies, registered closed-end investment companies, unregistered private funds, REITs, collateralized fund obligations and other similar investment vehicles and companies, as well as sponsors of such vehicles (generally referred to as “Portfolio Debt Securities” herein); (3) direct investments in corporate debt securities or other credit-oriented obligations (including loans, high yield bonds, and distressed securities, among other types of instruments); (4) regulatory capital relief investments, such as significant risk transfer securities and credit risk transfer securities issued by banks or other financial institutions; (5) credit-related investments tied to the U.S. infrastructure industry and related investments, such as senior lending opportunities for infrastructure and infrastructure aligned borrowers; and (6) investments that Eagle Point believes are related to or consistent with the foregoing. These services are described further below.

Eagle Point’s Ownership Eagle Point is ultimately wholly owned by Eagle Point Holdings LP (“EP Holdings”) through intermediary holding companies. EP Holdings, in turn, is majority-owned by certain of the “Trident Funds” (including certain affiliates, collectively, the “Trident Funds”), which are a series of private equity funds managed by Stone Point Capital LLC (“Stone Point”), an SEC-registered investment adviser. The Trident Funds hold interests in Eagle Point through various intermediary holding companies. The Trident Funds and Stone Point are described further under “Item 10 – Other Financial Industry Activities and Affiliations.” Certain Eagle Point’s employees also hold indirect economic interests in Eagle Point. Eagle Point is ultimately governed through intermediary holding companies by a board of managers which includes Thomas Majewski and certain principals of Stone Point.

Advisory Services Eagle Point offers discretionary investment advisory services through a variety of vehicles and accounts (as discussed more fully under “Item 7 – Types of Clients”), including: •

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pooled investment vehicles which are excepted from registration under the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”), pursuant to Section 3(c)(7) thereof (“Private Funds”); separately managed accounts, managed on behalf of institutional investors or high net worth individuals; and externally managed closed-end management investment companies registered under the Investment Company Act (“Registered Funds”).

Strategies Eagle Point may employ one or more of the following strategies on behalf of a particular investment vehicle or account: CLOs and Related Investments Generally, CLOs are securitization vehicles that pool portfolios of primarily below investment grade U.S. senior secured loans and issue securities in the form of multiple, primarily floating-rate, debt tranches, as well as a subordinated tranche, commonly referred to as the “equity” tranche. Loan accumulation facilities are short- to medium-term facilities often provided by the bank that will serve as the placement agent or arranger on a CLO transaction. In addition, subject to the applicable Account mandate, Eagle Point also invests directly in underlying loans and other types of assets held by CLOs. Eagle Point also invests in other related securities and instruments, including collateralized debt obligations, collateralized bond obligations, and securities issued by other types of securitization vehicles. Portfolio Debt Securities Portfolio Debt Securities are primarily debt (including convertible debt) or preferred equity securities or instruments issued by funds and investment vehicles, such as business development companies, registered closed-end investment companies, unregistered private funds, REITs, collateralized fund obligations and similar investment vehicles and companies, and sponsors of such vehicles, to finance a portion of their underlying investment portfolios. Portfolio Debt Securities may also include loans under which such a fund or investment vehicle (or special purpose vehicle thereof) is a borrower, and other securities and instruments that are consistent with the foregoing as determined by Eagle Point in its discretion. The Firm refers to its strategy of investing primarily in Portfolio Debt Securities as the “Defensive Income Strategy.” Opportunistic and Strategic Credit-Related Investments Eagle Point also employs other flexible credit-oriented strategies, which involve investments in (i) high yield, investment grade and distressed corporate bonds, (ii) corporate loans (including, without limitation, senior secured loans, mezzanine loans, revolving loans, delayed draw loans, distressed loans, infrastructure credit investments and DIP financings), (iii) common stock and other securities or instruments issued by business development companies, REITs, operating companies, and other similar issuers, (iv) credit-related exchange traded funds, (v) credit default swaps and other credit derivatives, (vi) commodity-related investments, (vii) securities issued by asset-backed and similar securitization vehicles (including, without limitation, collateralized bond obligations, mortgage-backed securitizations, credit-linked notes, and small business loan pool certificates), (viii) regulatory capital relief investments, such as significant risk transfer securities and credit risk transfer securities issued by banks or other financial institutions, (ix) credit-related investments tied to the U.S. infrastructure industry and related investments, such as senior lending opportunities within private credit for infrastructure and infrastructure aligned borrowers and originated or syndicated credit investments in infrastructure-focused business or assets, and (x) derivative instruments on any of the foregoing. Depending on an Account’s particular investment mandate, Eagle Point may also provide investment advisory services with respect to other types of investments. Eagle Point’s investment strategies are described further under “Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss.”

Generally Applicable Investment Terms Eagle Point provides investment advice to each Account using the strategy and investment restrictions applicable to that Account as outlined in the applicable investment advisory agreement or, in the case of the Private Funds and Registered Funds, a fund’s applicable disclosure documents. In the case of the Private Funds and the Registered Funds, Eagle Point does not tailor its advisory services to the individual investment objectives and strategies of the underlying investors, limited partners or shareholders. An investment in a Private Fund or a Registered Fund does not, in and of itself, create an advisory relationship between the investor and Eagle Point, although Eagle Point may enter into separate advisory arrangements with

any such investor pursuant to a separately executed investment advisory agreement. Therefore, each investor must consider for itself whether a Private Fund or a Registered Fund meets the investor’s investment objectives and risk tolerance before investing. Each Private Fund imposes certain terms and conditions on investments which may include minimum investment requirements and restrictions on liquidity and withdrawal rights, such as lockups, gates, and notice and periodicity requirements, all as set forth in a Private Fund’s Governing Documents. In addition, separately managed accounts, which are separately negotiated with individual clients, may be subject to terms and conditions similar to those described above as set forth in the applicable investment advisory agreement.

Variation of Investment Terms Eagle Point and its affiliates (including each general partner of a Private Fund (each, a “General Partner”)) are not restricted from entering into, and have and may enter into from time to time, separate agreements, commonly referred to as “side letters,” or other similar agreements or arrangements with a particular limited partner of a Private Fund in connection with such limited partner’s admission to a Private Fund (or otherwise) without the approval of any other limited partner. These agreements generally have the effect of establishing rights under, or supplementing the terms of, a Private Fund’s partnership agreement with respect to that limited partner in a manner more favorable than those applicable to other limited partners. The rights or terms in any such side letter or other similar agreement may include, without limitation (1) reporting obligations of the General Partner and other information concerning the applicable Private Fund, (2) waiver of certain confidentiality obligations, (3) reduction of fees applicable to such limited partner and/or performance allocations made with respect to such limited partners, (4) waiver of certain restrictions on the ability of the limited partner to withdraw all or part of its investment, (5) consent of the General Partner to certain transfers by the limited partner, (6) rights or terms necessary in light of particular legal, regulatory or public policy characteristics of a limited partner, (7) rights to participate in certain limited partner advisory committees or sub-committees thereof, (8) the ability to co-invest alongside a Private Fund in certain underlying investments, or (9) rights to participate in certain strategic transactions or other investment opportunities alongside Eagle Point. Certain limited partners that have the benefits of a “most favored nation” provision are given the opportunity to elect the rights and terms in any side letter or other similar agreement that are applicable to other limited partners. As a result, some investors are expected to have more favorable investment terms, including those relating to fees, information and liquidity, than others. If Eagle Point were to grant increased liquidity to an investor, particularly where such an agreement is accompanied by enhanced information about a Private Fund’s operations or investments (often referred to as “transparency rights”), other investors could be disadvantaged. Eagle Point, in its sole discretion, may offer more favorable terms (e.g., lower investment minimums or reduced or eliminated fees) to its personnel, related persons or others, including with respect to dedicated vehicles that invest in or alongside a Private Fund. Similarly, one or more separately managed accounts or Private Funds managed by Eagle Point that pursue the same or a substantially similar strategy as other Private Funds or other separately managed accounts generally have different terms, including different fee arrangements, liquidity terms, reporting requirements and/or other terms similar to those described above, than the relevant Private Fund or other similarly situated Accounts.

Designated Investments From time to time, a Private Fund may be invested, directly or through a special purpose vehicle, in assets that are illiquid or otherwise difficult to value. The Firm may determine to segregate such investments from the Private Fund’s main portfolio through the use of “designated investments,” or “side pockets.” For fee purposes, that portion of an investor’s capital account attributable to assets committed to a designated investment are assessed fees at the rate and timing as set forth in the applicable Private Fund’s Governing Documents.

Management of Client Assets As of December 31, 2025, Eagle Point had approximately $13 billion in discretionary client assets under management, inclusive of unfunded capital commitments made to the Accounts and assets managed by certain of its affiliates (and exclusive of any feeder funds’ investment into a master fund so as to avoid double counting of assets).

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General Eagle Point generally receives advisory fees in connection with the investment management services it provides to the Accounts. In addition, with respect to certain Accounts, including certain Private Funds and the Registered Funds, Eagle Point and/or the applicable General Partner is entitled to receive certain performance-based allocations or payments (generally referred to in this Brochure as “incentive allocations”). The particular fees applicable to an Account are set forth in the investment advisory agreement applicable to such Account or, in the case of a Private Fund or a Registered Fund, are also described in the applicable Governing Documents or disclosure documents, as applicable. Prospective investors and clients should be aware that Eagle Point’s fees change over time and that different fee schedules will likely apply if Eagle Point adopts new investment strategies or establishes additional Accounts in an existing strategy, or a prospective investor or client negotiates a different fee schedule. Specific fee arrangements applicable to any Account are generally subject to negotiation in Eagle Point’s sole discretion based

on, among other factors, the nature of the strategy and services to be provided by Eagle Point, total dollar amount invested (or the amount committed to be invested) with Eagle Point or its affiliates, regulatory and reporting requirements, the time that a particular Account commences operations, requested customization, and any other relevant factors, including employment or familial relationships with Eagle Point, its affiliates or the principals thereof. As such, one or more separately managed accounts or other Private Funds managed by Eagle Point that pursue the same or a substantially similar strategy as a Private Fund or other Account could likely have different fee arrangements, which difference could be material. In addition, a General Partner may waive or reduce management fees and/or incentive allocations in respect of an investor’s investment in a Private Fund or other Account in its sole discretion. It is important that clients refer to the respective Governing Documents, Account agreements or other disclosure documents, as applicable, for a complete understanding of fees and other forms of compensation. The information contained herein is a summary only and is qualified in its entirety by such materials.

Fees Eagle Point does not maintain a fixed fee schedule for client Accounts. Generally, an Account may pay a management fee of up to 2.25% (on an annualized basis) based on a percentage of either the net asset value of an Account, the gross asset value of an Account, the capital committed by a client to an Account, the capital invested by a client, or such other reference amount as negotiated with a client. The management fee is generally payable on a quarterly basis and may be deducted from an Account or otherwise billed to a client as set forth in the applicable investment advisory agreement. Management fees are generally payable in arrears. However, in the event that an Account pays fees to Eagle Point in advance, a pro rata portion of such fees will be refunded in the event that an Account is terminated prior to the end of the applicable billing period based on the number of days elapsed during such period. The management fees payable by the Private Funds and Registered Funds are set forth in their applicable Governing Documents or public filings, as applicable. In addition, certain Accounts, including the Private Funds and the Registered Funds, are assessed an incentive allocation of up to 20% (or such other percentage if agreed by a client) of all net profits (or, in the case of a Registered Fund, net investment income) allocable to the Account during a particular performance period, which may be quarterly or annually or may extend to the life of the Account. Such incentive allocation may be, and in the case of the Private Funds and the Registered Funds is, subject to certain specified preferred returns or hurdle amounts. Further, in the case of certain Private Funds or Accounts, such incentive allocation is also subject to a loss recovery account, or “high water mark.” As with the other fees applicable to an Account, the incentive allocation applicable to an Account is described in the applicable investment advisory agreement and/or Governing Documents (or other similar disclosure document).

Expenses of the Investment Manager Eagle Point is generally responsible for the payment of its normal operating overhead and administrative expenses, including, but not limited to, the compensation of its employees, office rental, secretarial, clerical and bookkeeping expenses and travel and entertainment expenses (excluding investment-related travel expenses).

Other Expenses Each Account, including each Private Fund and Registered Fund, pays certain other fees, expenses and costs (in addition to the Firm’s management fee and incentive allocation), which may include, among others: (1) organizational and offering expenses (including expenses associated with the organization of investment subsidiaries or other subsidiaries); (2) fees, costs and expenses related to the origination, purchase, holding, monitoring, transfer and disposition of assets (to the extent not reimbursed); (3) costs and expenses related to borrowings or other forms of indebtedness incurred by the Accounts; (4) fees, costs and expenses related to CLOs, loan accumulation facilities or other financing vehicles, and other types of pooled investment vehicles (including, for example, any management or similar fees payable to a CLO’s collateral manager or a fund’s

investment adviser), to the extent that an Account has a direct or indirect equity interest therein; (5) taxes, fees or other governmental charges levied against an Account; (6) other investment-related expenses (including, as applicable, “broken deal” expenses); (7) auditing and tax preparation expenses; (8) custodial expenses; (9) brokerage commissions or fees; (10) fees and expenses of external accountants, external counsel and other thirdparty professionals (including, if applicable, fees incurred in connection with specific transactions, whether consummated or not); (11) third-party administration fees and third-party valuation fees; (12) fees paid to the agent (which may be Eagle Point or its affiliate) on certain loan or other debt transactions; (13) costs of insurance; (14) litigation and indemnity expenses; (15) costs of dissolving and winding up; and (16) extraordinary expenses. In addition, each Private Fund that is a feeder fund generally bears, indirectly, its pro rata share of legal and other expenses incurred in the formation of the relevant master fund and each other feeder fund that invests in the same master fund, and the offering of interests in each. A more detailed description of the expenses borne by a Private Fund or a Registered Fund is included in such Private Fund’s Governing Documents or Registered Fund’s public filings, as applicable. A more detailed description of the expenses borne by other Accounts is set forth in each such Account’s investment advisory agreement. Certain of the expenses borne by an Account are also typically incurred by, or allocable to, other Accounts or Eagle Point or its affiliates. Therefore, from time to time, Eagle Point will be required to determine in its sole discretion how certain costs and expenses are to be allocated among multiple Accounts and/or Eagle Point and its affiliates. To the extent an Account, on the one hand, and Eagle Point, its affiliates and/or one or more other Accounts, on the other hand, incur costs or expenses that are applicable to more than one of them, Eagle Point will allocate such costs and expenses in a manner that it determines to be fair and reasonable, notwithstanding its interest in the outcome. Eagle Point may also make corrective allocations should it determine that such corrections are necessary or advisable. In such cases, Eagle Point negotiates any such arrangement on an arm’slength basis, taking into account the market for the applicable services. Further, Eagle Point and its affiliates, and their respective personnel and the investment funds and accounts managed by such persons, have interests in companies that provide services to asset management firms such as Eagle Point, and to other businesses. Because of these relationships, such persons have a conflict of interest when considering and selecting service providers with respect to an Account and have an incentive to select those service providers in which such persons have an interest. The selection of such a service provider would result in an Account bearing fees and expenses paid to a service provider that is affiliated with, or otherwise has a relationship with, Eagle Point or its affiliates. In addition, Eagle Point has a conflict of interest where a service provider (e.g., legal counsel or accountants) provides services directly to Eagle Point or one of its affiliates, and separately provides services to one or more Accounts, in that Eagle Point or an affiliate thereof may potentially obtain services at a lower cost than it otherwise could have as a result of the service provider’s work performed on behalf of, and the compensation paid to the service provider by, such Accounts. In particular, unless inconsistent with applicable governing documents, costs associated with services rendered to the benefit of an Account are generally borne by such Account. Eagle Point and its affiliates sometimes also use some of the same service providers as are retained on behalf of one or more Accounts and, in some cases, fee rates, amounts or discounts may be offered to Eagle Point and its affiliates by a third party service provider which differ from those offered to an Account as a result of scheduled or ad hoc rate changes, differences in the scope, type or nature of the service or transaction, alternative fee arrangements and negotiation. Eagle Point may also receive fees for serving as named agent on certain lending transactions (primarily loan transactions sourced by Eagle Point in connection with the Defensive Income Strategy). Eagle Point may retain a third party to serve as sub-agent on certain of these transactions. Eagle Point generally expects to pass on any fees it receives for serving as named agent to the Accounts participating in the applicable transaction (net of any fees paid to a sub-agent, if applicable) in accordance with an Account’s Governing Documents or other agreements.

Special or Additional Fee Arrangements In the event that Eagle Point establishes different or additional strategies, offers new Private Funds in an existing strategy, or otherwise negotiates fees with separate account clients, new fee schedules may be established which may or may not be based on the general fee structures set forth above, as circumstances warrant, or which may be open to negotiation without a stated fee schedule.

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Below is a general summary of the Accounts’ investment strategies, methods of analysis and material risks. The information contained in this Brochure is only a summary, and it is qualified in its entirety with respect to the Private Funds and the Registered Funds by the relevant Governing Documents or filings, as the case may be. In addition, as noted above, and from time to time, Eagle Point may manage investment strategies on behalf of an Account that differ from those described below. The methods of analysis used, and material risks applicable to, any such different strategy will vary from those summarized herein.

Methods of Analysis and Investment Strategies Generally, Accounts managed by Eagle Point primarily seek current income or to maximize total returns and may also secondarily seek capital appreciation. Certain Accounts also seek to outperform a specified reference index. As noted above, Eagle Point’s investment advisory services primarily involve the types of investments described above in “Item 4 – Advisory Business – Strategies.” Investments may be made directly by an Account or may be made indirectly through one or more subsidiaries or affiliated entities of an Account (e.g., in the case of a Private Fund). Certain Accounts may also invest in derivative financial instruments and may use leverage in connection with their investment program, subject to any applicable limitations set forth in an Account’s Governing Documents. Eagle Point’s investment team is responsible for identifying investment opportunities for each Account in accordance with the Account’s stated investment objectives and strategies, although investments are reviewed by the applicable investment committee or its delegates as described in “Item 13 – Review of Accounts.” Eagle Point’s investment team utilizes a variety of methods to proactively source and analyze investments, including leveraging its management team’s industry experience, using the investment team’s professional networks, performing due diligence on issuers and their management, and utilizing third party and, in some cases, proprietary, quantitatively-based financial and analytical models to aid in the selection and monitoring of investments (both those made on behalf of Accounts and those in the Firm’s investible universe of securities more generally).

Risk of Loss While Eagle Point seeks to manage each Account so that risks are appropriate to the return potential for the strategy employed by the Account, it is often not possible or desirable to fully mitigate risks. Any investment includes the risk of loss and there can be no guarantee that a particular level of return will be achieved or that the investment approach will be successful. Investors and clients should also be aware that the investment strategies managed by Eagle Point are limited to certain types of securities and are not diversified in this respect. In addition, an Account’s investment strategies may present a high degree of risk that investors should be prepared to bear. Investors and clients should understand that they could lose some or all of their investment and should be prepared to bear the risk of such potential losses. In particular, there is a risk that the Private Funds may be wound up earlier than anticipated if they fail to meet their investment objectives or for any other reason in the discretion of the General Partner.

An Account managed by Eagle Point is not intended to provide a complete investment program and Eagle Point expects that assets invested in an Account it manages do not represent all of a client's or investor's assets. Investors and clients are responsible for appropriately diversifying their assets to guard against the risk of loss. Set forth below is a summary of certain material risks applicable to investments in which Eagle Point primarily invests. The discussion below does not purport to be a complete description of all risks applicable to such investments. More detailed information regarding each Private Fund’s investment strategy and related risks is included in a Private Fund’s Governing Documents as appropriate. Similarly, more detailed information on a Registered Fund’s investment strategy and related risks is included in that fund’s filings with the SEC. Investors in a Private Fund or Registered Fund, or otherwise in an Account, should not solely rely on the summary set forth in this Brochure.

General and Investment Risks Each Account is subject to certain general risks such as liquidity risk, operational risk, portfolio turnover risk, regulatory risk, and economic risk among others. In addition to these general risks, the investments made by an Account are subject to certain investment-related risks as described below.

General Economic Activity and Market Risk Certain events particular to a specific market, as well as changes in general economic and political conditions, may have a significant negative impact on the operations and profitability of an Account’s investments (including an investment’s underlying obligors, as applicable) and/or on the fair value of an Account’s investments. Such events could include governmental actions, inflation, unemployment, trade disputes, technological developments, political events, and numerous other factors beyond Eagle Point’s or an Account’s control. The likelihood that such events may occur and the potential effect on an Account cannot be predicted. Any impact on the financial condition of an investment’s underlying obligors could impair such obligors’ ability to make payments of principal and interest to the issuer and thereby limit the issuer’s ability to make payments on the security or other instrument held by an Account. Depending on an Account’s particular investment mandate, general fluctuations in economic conditions and market prices of securities could also reduce the availability of suitable investment opportunities. Unexpected volatility, illiquidity, governmental action, currency devaluation or other events in the global markets in which an Account directly or indirectly holds positions could impair the Account’s ability to carry out its business and could cause the Account to incur substantial losses. There is significant uncertainty with respect to legislation, regulation and government policy at the federal level, as well as the state and local levels. Recent events have created a climate of heightened uncertainty and introduced new and difficult-to-quantify macroeconomic and political risks with potentially far-reaching implications. The presidential administration’s changes to U.S. policy may impact, among other things, the U.S. and global economy, international trade and relations, unemployment, immigration, taxes, healthcare, the U.S. regulatory environment, inflation and other areas. Eagle Point cannot predict the impact, if any, of these changes to the Firm’s business, and they could adversely affect the Firm or an Account’s investments business, financial condition, operating results and cash flows. Until we know what policy changes are made and how those changes impact our business and the business of an Account’s investments over the long term, Eagle Point will not know if, overall, it will benefit or be negatively affected by them. Inflation and rapid fluctuations in inflation rates, as has occurred in the U.S., have had in the past, and may in the future have, negative effects on economies and financial markets. Wage and price controls have been imposed at times in certain countries in an attempt to control inflation, which could significantly affect the operation of the issuers of securities or other investments in which an Account invests. Governmental efforts to curb inflation often have negative effects on the level of economic activity. As such, inflation and rapid fluctuations in inflation rates can adversely affect the financial performance of any Account. In addition, the market value of the Accounts’ investments may decline in times of higher inflation rates given that the most commonly used methodologies for valuing investments (e.g., discounted cash flow analysis) are sensitive to rising inflation and real interest rates. There can be no assurance that inflation will not have an adverse impact on the performance of the Account and

its investments. Were significant inflation to occur, the effect on Eagle Point’s strategy could be materially adverse. Further, there is a risk of terrorist attacks in the United States and elsewhere, acts of war causing significant loss of life and property damage and disruptions in the local or global market, or other events that significantly disrupt markets in the United States or elsewhere. Economic and diplomatic sanctions may be in place or imposed on certain states and military action may be commenced. Natural disasters and epidemics, pandemics or other outbreaks of serious contagious diseases may have similarly disruptive impacts. The occurrence of a natural disaster or epidemic could adversely affect and severely disrupt the business operations, economies and financial markets of many countries (even beyond the site of the natural disaster or epidemic). Future terrorist activities, military or security operations, natural disasters or similar events could further weaken the domestic/global economies and create additional uncertainties, which may adversely impact the businesses to which Eagle Point obtains exposure either directly or indirectly and, in turn, could have a material adverse impact on an Account’s results. Such events have created, and continue to create, economic and political uncertainties and have contributed to global economic instability. Losses from such events are generally uninsurable. Ultimately, the potential impact of such events is unclear, but such events could have a material effect on general economic conditions, market liquidity or the operations of Eagle Point or an Account.

General Risks of Investing in U.S. Senior Secured Loans Accounts may obtain exposure to U.S. senior secured loans directly or indirectly through investments in CLOs, Portfolio Debt Securities, or other securities of issuers who invest in such loans, or through other financial instruments. Such loans may become nonperforming or impaired for a variety of reasons. Nonperforming or impaired loans may require substantial workout negotiations or restructuring that may entail a substantial reduction in the interest rate and/or a substantial write-down of the principal of the loan. In addition, because of the unique and customized nature of a loan agreement and the private syndication of a loan, certain loans may not be purchased or sold as easily as publicly traded securities, and, historically, the trading volume in the loan market has been small relative to other markets. Loans may encounter trading delays due to their unique and customized nature, and transfers may require the consent of an agent bank and/or borrower. Risks associated with senior secured loans also include the fact that prepayments generally may occur at any time without premium or penalty.

General Risks of Investing in CLOs Investments in CLO securities and other related structured finance securities involve many risks. CLOs and structured finance securities are generally backed by an asset or a pool of assets (typically senior secured loans and other credit-related assets in the case of a CLO) which serve as collateral. Investors in CLO and related structured finance securities ultimately bear the credit risk of the underlying collateral. In the case of most CLOs, the structured finance securities are issued in multiple tranches, offering investors various maturity and credit risk characteristics, often categorized as senior, mezzanine and subordinated/equity according to their degree of risk. If there are defaults or the relevant collateral otherwise underperforms, scheduled payments to senior tranches of such securities take precedence over those of mezzanine tranches, and scheduled payments to mezzanine tranches have a priority in right of payment to subordinated/equity tranches. In light of the above considerations, CLO and other structured finance securities may present risks similar to those of other types of debt obligations and, in fact, such risks may be of greater significance in the case of CLO and other structured finance securities. For example, investments in structured vehicles, including equity and junior debt securities issued by CLOs, involve risks, including credit risk and market risk. Changes in interest rates and credit quality may cause significant price fluctuations. In addition to the general risks associated with investing in debt securities, CLO securities carry additional risks, including, but not limited to: (1) the possibility that distributions from collateral assets will not be adequate to make interest or other payments; (2) the quality of the collateral may decline in value or default; (3) the fact that investments in CLO equity and junior debt tranches will likely be subordinate in right of payment to other senior

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As discussed in “Item 4 – Advisory Business,” Eagle Point currently provides discretionary investment management services to the Accounts. As described above, the terms and conditions of the Accounts vary depending on the type of services provided or the type of client, and these terms and conditions also vary among Accounts. The minimum investment applicable to an Account is subject to negotiation between Eagle Point and the applicable client. In addition, the Private Funds generally impose a minimum initial investment (or capital commitment) of $5,000,000 for most institutional investors. In certain circumstances, such investment minimums may be reduced by the applicable General Partner in its sole discretion. Because each of the Private Funds is exempt from registration under the Investment Company Act pursuant to Section 3(c)(7) thereof, interests in the Private Funds are restricted to certain investors. Specifically, investors who are eligible to invest in the Private Funds must be (1) persons who are not “U.S. persons” as defined in Regulation S under the Securities Act of 1933, as amended (“Securities Act”), who are also “Non-United States Persons” as defined in Commodity Futures Trading Commission Rule 4.7, or (2) persons who are both “accredited

investors” (as defined in Regulation D under the Securities Act) and “qualified purchasers” or “knowledgeable employees” of the Firm (each as defined under the Investment Company Act). Separately managed accounts are generally managed on behalf of institutional investors or high net worth individuals. In such cases, clients must generally qualify as one or more of the following: (1) a “qualified purchaser” as defined under the Investment Company Act; (2) a “qualified institutional buyer” as defined under Rule 144A under the Securities Act; and/or (3) a “qualified client” as defined under the Advisers Act.

Performance-based fees and incentive allocations are described in the investment advisory agreement applicable to each Account that is subject to such fees and allocations and are also described in the applicable Governing Documents or other disclosure document. See also “Item 5 – Fees and Compensation” above. Eagle Point’s receipt of performance-based fees and incentive allocations raises certain conflicts of interest, including, but not limited to, those described below.

Investment Selection Incentive allocations and other arrangements where the incentive to achieve gains may exceed the disincentive to suffer losses may cause Eagle Point to choose investments that are riskier or more speculative than might otherwise have been chosen, or than would otherwise be prudent, in an effort to generate higher performancebased compensation. As discussed in “Aggregation of Orders and Allocation of Investment Opportunities Across Accounts” under “Item 12 – Brokerage Practices” below, Eagle Point will review the allocation of investment opportunities across Accounts in such cases where a conflict may arise and follow the Firm’s policies and procedures regarding the allocation of investment opportunities.

Valuation In addition to the discussion of valuation above in “Item 5 – Fees and Compensation,” investors in a Private Fund and clients of Accounts that may be assessed an incentive allocation should note that under certain incentive allocation and performance-based fee arrangements, including those based on appreciation of net asset value, Eagle Point receives an incentive allocation that is attributable in part to unrealized appreciation of the securities held in an Account’s portfolio. This creates an incentive for Eagle Point to adopt higher valuations in respect of such securities. In addition, there is generally no provision for adjustment or refund of incentive allocations

charged on the basis of unrealized appreciation should incentive allocations with such unrealized appreciation taken into account not match the appreciation ultimately realized.

Side-by-Side Management From time to time, certain Accounts managed by Eagle Point may not be subject to an incentive allocation. In addition, some Accounts that are subject to an incentive allocation may be subject to the operation of loss recovery accounts, or a “high water mark,” or have different calculation methodologies from other such Accounts (e.g., certain accounts may be subject to a “preferred return” or “hurdle” amount). To the extent Eagle Point manages multiple Accounts with different high water marks, levels of incentive allocations or preferred returns or hurdle amounts, or manages one or more Accounts that are not subject to an incentive allocation, Eagle Point has an incentive to favor Accounts that are subject to an incentive allocation (or a higher incentive allocation) and that are above their respective high water marks (and therefore required to pay incentive allocations), or that otherwise have more achievable preferred returns or hurdle amounts, over those Accounts that are not subject to an incentive allocation or that are below their respective high water marks (and therefore are not required to pay incentive allocations until such Accounts return to their applicable high water marks), or that are not otherwise subject to a preferred return or hurdle amount. This conflict is most apparent where two Accounts follow the same, or a similar, investment strategy. Further, Eagle Point, its affiliates, and their personnel have differing investment or pecuniary interests in various Accounts, particularly where Eagle Point, an affiliate, or their personnel hold a significant investment in an Account. Eagle Point faces a conflict of interest when (1) the actions taken on behalf of one Account impact other similar or different Accounts (e.g., because such Accounts have the same or similar investment strategies or otherwise compete for investment opportunities, have potentially conflicting investment strategies or investments, or have differing ability to engage in short sales and economically similar transactions), and (2) Eagle Point and its personnel have differential interests in such Accounts. In such case, Eagle Point has an incentive to favor certain Accounts over others that may be less lucrative to the Firm, its affiliates or their personnel. Such conflicts present particular concern when, for example, Eagle Point places or allocates the results of transactions that Eagle Point believes could more likely result in favorable performance or when Eagle Point engages in a cross transaction. Additional information on such conflicts of interest is included in “Item 10 – Other Financial Industry Activities and Affiliations” and “Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.” To mitigate the conflicts discussed in this Item 6, Eagle Point’s policies and procedures seek to provide that investment decisions are made in accordance with the fiduciary duties owed by Eagle Point to its client Accounts and in accordance with applicable law, without consideration of Eagle Point’s (or its affiliates’ or personnel’s) pecuniary, investment or other financial interests.

Other Financial Industry Affiliations The organizational, ownership and investment structure of Eagle Point and certain Accounts create significant conflicts of interest that may be resolved in a manner that is not always in the best interests of the Accounts or other clients or investors. Eagle Point is affiliated with other entities engaged in the financial services business. In particular, Eagle Point is affiliated with the General Partners through common ownership. In addition, Eagle Point currently is under common control with four additional investment advisers, which are separately registered as investment advisers with the U.S. Securities and Exchange Commission: (1) Eagle Point Income Management LLC (“EPIM”), which serves as the investment adviser to Eagle Point Income Company Inc., a closed-end management investment company that is registered as an investment company under the Investment Company Act and trades on the New York Stock Exchange under the symbol “EIC,” (2) Eagle Point Enhanced Income Management LLC (“EPEIM”), which serves as the investment adviser to Eagle Point Enhanced Income Trust, a non-diversified, closed-end management investment company that is registered as an investment company under the Investment Company Act, (3) Eagle Point Defensive Income Management LLC (“EPDIM”), which serves as the investment adviser to Eagle Point Defensive Income Trust, a non-diversified, closed-end management investment company that is registered as an investment company under the Investment Company Act, and (4) Mountain Point Credit Management LLC (“Mountain Point”) which focuses its investment advisory services on

the management of U.S. senior secured bank loans and related investments. Additionally, Eagle Point Infrastructure Management LLC (“EP Infrastructure Management”) is an affiliate of the Firm which operates as a relying adviser under the Firm’s registration on Form ADV. Eagle Point is also under common control with (1) Valitana LLC, a software analytics company that provides data and similar services to investors active in the CLO market, and (2) Eagle Point Securities LLC, a broker-dealer registered with the SEC and a member of FINRA and SIPC whose primary purpose is currently to manage the wholesale distribution of certain Registered Funds. Eagle Point is also affiliated with Stone Point and certain members of the Firm’s ultimate board of managers are principals of Stone Point. Because Eagle Point receives compensation from the Accounts, these relationships create certain conflicts of interest and may result in future conflicts of interest that may not be foreseen, in which conflicts may not be resolved in a manner that is always or exclusively in the best interest of the Accounts. Pursuant to certain management agreements, Stone Point has received delegated authority to act as the investment manager of the Trident Funds. Certain of the Trident Funds are indirect limited partners in certain Private Funds managed by Eagle Point and hold shares of common stock of a Registered Fund. Further, Stone Point itself is affiliated with Stone Point Credit Adviser LLC, an SEC-registered investment adviser, and SPC Capital Markets LLC, a registered broker-dealer. The Trident Funds also indirectly hold a controlling interest in Eagle Point and in the General Partners. The Trident Funds and other private equity funds managed by Stone Point invest in financial services companies. From time to time, Eagle Point provides investment advisory services to accounts held by the Trident Funds, or other investment funds or portfolio companies of private equity funds managed by Stone Point, and certain of these accounts may invest in Accounts managed by Eagle Point or its affiliates. The foregoing relationships could cause Eagle Point or certain of its affiliates’ interests to diverge from the interests of an Account or the investors in a Private Fund or a Registered Fund. In the ordinary course of business, an Account may enter into transactions with persons who are affiliated or associated with Eagle Point, resulting in compensation to such persons from an Account (or from an issuer in which an Account invests), subject to any limitations under applicable law. In this respect, the Firm and its affiliates engage, and may in the future engage, in a variety of business activities, including investment management, financing, broker-dealer activities, and software analytics. As such, the Firm or its affiliates may have multiple business relationships with various counterparties, including other CLO collateral managers and investment advisers, that encompass a range of activities, such as investing in Portfolio Debt Securities by an issuer sponsored by such sponsor or CLOs managed by a CLO collateral manager on behalf of certain Accounts, financing, or investing in other securities issued by, other vehicles managed by such sponsor or CLO collateral manager or other investment adviser (or an affiliate thereof), or otherwise providing advisory, research or data services to such other person for compensation. Any of these potential transactions and activities could result in conflicts of interest that cannot be foreseen or may not be resolved in a manner that is always or exclusively in the best interest of the Accounts or, in the case of a Private Fund or Registered Fund, such fund’s investors. Should conflicts of interest arise in the context of these relationships (including those described below), the Chief Compliance Officer and senior management of Eagle Point will address them in accordance with the Code of Ethics and the Firm’s policies and procedures as described in further detail in “Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading” below.

Investment Opportunities Eagle Point is responsible for the investment decisions made on behalf of the Accounts. There are no restrictions on the ability of Eagle Point and certain of its affiliates (including Mountain Point and Stone Point) to manage accounts for multiple clients, including accounts for affiliates of Eagle Point or their directors, officers or employees, following the same, similar or different investment objectives, philosophies and strategies as those used for the Accounts. In these situations, Eagle Point and its affiliates have conflicts of interest in allocating investment opportunities between the Accounts and any other account managed by such person. See “Aggregation of Orders and Allocation of Investment Opportunities Across Accounts” under “Item 12 – Brokerage

Practices” below. Such conflicts of interest would be expected to be heightened to the extent Eagle Point manages an Account for an affiliate or its directors, officers or employees or where any such persons are investors or otherwise have a pecuniary interest. Additionally, Accounts managed by Eagle Point or certain of its affiliates from time-to-time hold securities issued by an issuer that are of a different class or type than the class or type held by other Accounts or other persons or entities affiliated with Eagle Point. For example, an Account may hold an interest in an issuer’s debt or equity securities which are senior or junior to the securities held by other Accounts or other persons related to Eagle Point. In such a scenario, the Account would be entitled to different payments or other investor rights and its recovery in a workout or other distressed scenario may be more or less than other Accounts or other Eagle Point persons which hold other classes or types of securities. Similarly, Accounts can hold, and may in the future be allocated, certain investments in CLOs (including CLOs in which the other Account invests), such as equity tranches, that conflict with the positions held by the other Account in those CLOs, such as debt tranches, or vice versa. In such cases, when exercising the rights of each Account with respect to such investments, Eagle Point and/or its affiliate will have a conflict of interest as actions on behalf of one Account could have an adverse effect on another Account managed by Eagle Point or such affiliate. From time to time, an Account can invest in the same underlying investment through commingled, special purpose vehicles alongside other Accounts managed by Eagle Point. Although Eagle Point does not separately assess management fees or incentive allocation at such special purpose vehicle-level, different participating Accounts in such a special purpose vehicle may have conflicts of interest in respect of their investments therein (e.g., in respect of the timing of withdrawals or subscriptions therein). In such cases, such conflicts may not be resolved in a manner that is always or exclusively in the best interest of all applicable Accounts. In addition, from time to time, Eagle Point may agree with one or more investors, prospective investors, clients or other third-party persons to notify such persons of potential opportunities to co-invest in investments in which one or more Accounts directly or indirectly invest or otherwise notify any such person of such opportunity. In such cases, Eagle Point generally does so in its sole discretion, subject to any such agreement which may, for example, require notification, including, for example, on the basis of the size of an investor’s investment or commitment to Accounts managed by Eagle Point and/or its affiliates, as a well as a broad range of other considerations, including, without limitation, a person’s stated desire to participate in such opportunities. It should be noted that there can be no assurances with respect to the amount of any such investment opportunity available for any particular person and, if available, such opportunities will typically be offered to only some (and not other) persons. Any such co-investments could have the effect of reducing the size of an Account’s investment in the applicable investment opportunity, which, if such investment is successful, result in the Account foregoing returns on any additional investment therein. Further, in the case of a potential co-investment that does not close (a “broken deal”), unless otherwise expressly agreed with a co-investor, an Account could bear a disproportionate share of expenses attributable to the broken deal if co-investors would have otherwise participated in such transaction since, as a result of not so participating, such co-investors may not otherwise be required to bear their proportionate share of such expenses. Further, Stone Point and its affiliates, and the investment funds managed by Stone Point and such affiliates, may also invest from time to time in companies competing with Eagle Point. In such cases, such companies would generally be expected to manage other accounts and funds competing for investment opportunities with the Accounts.

Firm-Related Investments From time to time an Account may directly or indirectly make investments (1) that Eagle Point and/or an affiliate originated or structured, (2) in an issuer related to Eagle Point and from which Eagle Point or an affiliate, as applicable, receives or received compensation as arranger, broker-dealer, investment manager, or otherwise, (3) in which Eagle Point, its affiliates, or its personnel have a pecuniary interest, or (4) that otherwise involve the participation of Eagle Point or an affiliate. Any such investment could (and any investment described in clause (2) of the preceding sentence will) result in Eagle Point or such other person receiving compensation in addition to the fees and allocations incurred by the applicable Account under its applicable investment advisory agreement. To the extent any transaction constitutes a principal transaction subject to Section 206(3) under the Advisers Act,

Eagle Point will comply with the requirements of that section, including the requirement to obtain the consent and approval of the applicable client. An Account may invest, in the primary or secondary markets, in securities or instruments issued by (1) CLOs for which affiliates of Eagle Point (such as Mountain Point) serve as collateral manager and (2) issuers for which portfolio companies owned by funds managed by Stone Point or its affiliates may engage in lending activities, which could result in an Account investing in, directly or indirectly, loans underwritten by such portfolio companies or affiliates. Similarly, given the breadth of the Stone Point platform, an Account may invest in, directly or indirectly, debt obligations of portfolio companies owned by funds managed by Stone Point or other affiliates of Stone Point. In addition to the above, because portfolio companies of such investment funds engage in a wide range of businesses, such entities may engage in other activities now or in the future that create a conflict of interest for Eagle Point with respect to its management of the Accounts. Any of these potential transactions and activities could create conflicts of interest that cannot be foreseen or may not be resolved in a manner that is always or exclusively in the best interest of the Accounts or, in the case of the Private Funds and the Registered Funds, such funds’ investors.

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Code of Ethics Eagle Point has adopted a Code of Ethics (the “Code”) designed to meet the requirements of Rule 204A-1 of the Advisers Act. The Code requires Eagle Point employees to act in the best interests of Eagle Point and the Accounts. In addition, it requires personnel to act in good faith and ethical manner, avoid conflicts of interest with the Accounts to the extent reasonably possible and identify and manage conflicts of interest. Eagle Point employees are required to comply with the applicable provisions of federal securities laws and make prompt reports to Eagle Point or another appropriate party of any actual or suspected violations of law by Eagle Point, its employees or affiliates. In order to mitigate conflicts of interest with the Firm’s investment activities on behalf of Accounts and the personal investment activities of Eagle Point personnel, the Code sets forth formal policies and procedures with respect to personal securities trading of Eagle Point supervised persons. For example, the Code requires employees to pre-clear certain personal securities transactions and periodically report certain securities transactions and holdings. In addition to the Code, Eagle Point’s Compliance Manual contains other policies and procedures reasonably designed to address conflicts of interest with respect to, among other things, gifts and entertainment, outside business activities and political contributions. The Compliance Manual also includes policies reasonably designed to prevent insider trading, tipping, and anti-money laundering, among other matters. All employees receive periodic training regarding Eagle Point’s personal trading policies and related compliance matters. In addition, employees must confirm upon commencement of employment and annually thereafter they have read, understood, and complied with the policies and procedures set forth in the Code and Compliance Manual. Employees are also required to provide quarterly certifications of compliance with certain provisions in the Code and Compliance Manual. Upon request, Eagle Point will provide a copy of the Code to clients, investors in a Private Fund or to prospective investors. Eagle Point’s Code of Ethics is also publicly filed with the SEC by each Registered Fund and is available on the SEC’s website (www.sec.gov). Requests for a copy of the Code can be directed to Eagle Point’s Chief Compliance Officer at the address on the front cover of this Brochure.

Participation or Interest in Client Transactions Eagle Point may affect principal transactions with respect to an Account, including where an Account may acquire securities from, or sell securities to, accounts primarily owned by Eagle Point or its affiliates. Eagle Point will provide disclosures to and obtain the consent and approval of the client or the client’s designated representative in accordance with Section 206(3) of the Advisers Act for such principal transactions. Further, clients for whom Eagle Point manages Accounts may also be invested in a Private Fund and/or a Registered Fund to the extent consistent with an Account’s investment objective and guidelines. To the extent any such investment is made for an Account, an Account would generally be expected to bear fees and expenses of the applicable Private Fund or Registered Fund as an investor therein. Eagle Point and its principals, affiliates and employees trade in the securities and derivatives markets for their own accounts and the accounts of their clients as described herein. In doing so, such persons may take positions opposite to, or ahead of, those held by an Account or may be competing with an Account for positions in the

marketplace. Such trading could result in competition for investment opportunities or create other conflicts of interest on behalf of one or more such persons in respect of their obligations to an Account. To mitigate such conflicts, Eagle Point has adopted a Code of Ethics as described above.

Material Non-Public Information By reason of the advisory and/or other activities of Eagle Point, its personnel and its affiliates, including Mountain Point, the Firm may acquire confidential or material non-public information, or be restricted from initiating transactions in certain securities. Eagle Point will not be free to divulge, or to act upon, any such confidential or material non- public information and, due to these restrictions, it may not be able to initiate a transaction for an Account that it otherwise might have initiated. As a result, an Account may be frozen in an investment position that it otherwise might have liquidated or closed out or may not be able to acquire a position that it might otherwise have acquired.

Eagle Point and certain Accounts regularly make investments in securities that are not offered publicly and that are sold through only a single broker dealer at any given time. In some instances, Eagle Point will be in a position to select or influence the selection of the applicable broker-dealer. In such cases, Eagle Point will base its selection or recommendation on a number of factors, including price (discount or commission rate), expertise in the applicable security, distribution capabilities, and other relevant factors. Where a purchase or sale is completed in the secondary market, broker-dealers are generally selected as a function of who, in the case of a purchase, has inventory and/or is willing to transact at attractive prices or, in the case of a sale, is willing to pay the best price for the security an Account is looking to sell. In such cases, Eagle Point seeks best execution of any secondary transaction as described below.

Best Execution and Soft Dollars To the extent that Eagle Point transacts in public securities or other non-private investments, and when executing in the secondary market for securities that are offered or sold through multiple broker-dealers, Eagle Point seeks to select brokers and counterparties based upon the firm’s view of the broker’s or counterparty’s ability to provide best execution for an Account (i.e., the best net price considering all relevant factors). In this regard, Eagle Point considers a variety of factors including, but not limited to, the broker-dealer’s or counterparty’s (1) ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); (2) operational efficiency with which transactions are effected (such as prompt and accurate confirmation and delivery), taking into account the size of the order and difficulty of execution; (3) financial strength, integrity and stability; (4) competitiveness of commission rates in comparison with other broker-dealers; and (5) research products/services. Although Eagle Point generally seeks competitive commission rates and commission equivalents, it will not necessarily pay the lowest commission or markup/markdown or otherwise transact on the basis of the lowest pricing. In addition, certain transactions may involve specialized services on the part of a broker-dealer, which may justify higher compensation than would be the case for more routine services. From time to time, a client may direct Eagle Point to cause brokerage transactions to be executed with respect to an Account by a particular member of a national securities exchange, broker or dealer. In such cases, Eagle Point will seek to achieve the most favorable price and best execution in light of such direction and, as a result, may not be able to achieve the most favorable execution under the circumstances. In particular, in such cases, an Account may bear higher execution costs than had Eagle Point not been directed as to the applicable broker or dealer since, among other things, Eagle Point may not be able to aggregate the Account’s order with those of other accounts or the dealer or broker selected by the client may have less favorable prices. Eagle Point does not currently utilize formal soft dollar arrangements in connection with brokerage transactions; however, Eagle Point generally has access to research provided by broker-dealers used for transactions. Eagle Point does not separately compensate such broker dealers for the research. To the extent Eagle Point has access to broker research, Eagle Point does so in a manner consistent with the safe harbor under Section 28(e) of the Securities Exchange Act of 1934. While Eagle Point believes that it does not “pay up” for broker-dealer services in

connection with such research, because brokers generally will not separately disclose their costs in providing such research, clients should be aware that more favorable pricing may be available from a different broker-dealer who offers no research services and/or minimal securities transaction assistance. Because Eagle Point does not have to produce or incur the expense associated with the research received from a broker, an incentive may exist to select or favor a broker-dealer because of the research provided (which may constitute a soft dollar benefit). Such an incentive is inconsistent with client interests in receiving the most favorable execution of trades. Accordingly, at all times, Eagle Point’s acceptance of soft dollar benefits (if any) in a particular transaction is made only after a good faith determination that the amount of commission or bid-ask spread in the transaction is fair and reasonable in relation to the value of the soft dollar brokerage and research services provided when viewed in the context of the particular transaction and Eagle Point’s fiduciary duty to its clients. Soft dollar benefits may be used in serving all Accounts. Thus, certain Accounts that did not generate soft dollars may nevertheless share in the soft dollar benefits generated by other Accounts. Eagle Point expects that the research it acquires from brokers will include both proprietary research (research created or developed by the broker-dealer providing the research) and third-party research (research developed or created by a third-party) that aid in Eagle Point’s investment decision making. Such research may include information on the economy, industries and asset classes, statistical information and market data, pricing services, credit analysis and other information regarding matters that may affect the markets in which Eagle Point invests.

Aggregation of Orders and Allocation of Investment Opportunities across Accounts If Eagle Point determines that the purchase or sale of the same investment security is in the best interest of more than one Account, Eagle Point typically aggregates orders (but is not obligated to do so) in order to seek to obtain improved execution and reduce transaction costs to the extent permitted by law. Such orders will be placed, and associated transaction costs allocated, in a fair and equitable manner, in accordance with the applicable Governing Documents for the clients involved. To the extent Eagle Point determines to aggregate transactions for an Account and one or more other Accounts, such participating Accounts will generally be allocated positions based on the average price (if there is more than one price) achieved for such transactions to the extent feasible. While Eagle Point believes the aggregation of orders is generally fair and equitable to all of its Accounts, in certain circumstances, the aggregation of orders may result in one Account’s transaction at less advantageous prices or commissions than if it had traded on its own. In addition, Eagle Point may, from time to time, be presented with investment opportunities that fall within the investment objectives of one or more Accounts (and/or one or more accounts managed by Affiliates of Eagle Point, including EPIM, EPEIM, EPDIM and EP Infrastructure Management), and in such circumstances, Eagle Point expects to allocate such opportunities among such Accounts (and, as applicable, such other accounts managed by such other affiliates) in accordance with Eagle Point’s investment allocation policy and on a basis that Eagle Point determines in good faith is appropriate taking into consideration such factors as (1) the fiduciary duties owed by Eagle Point to the Accounts, (2) the investment mandates and focus of the Accounts, (3) the capital available to the Accounts on a trade date and settlement date basis, the size of each Account and the level to which an Account is already invested, (4) any investment restrictions applicable to an Account whether by contract, client instruction, regulation, tax considerations, or otherwise, (5) the sourcing of the transaction, (6) the size of the transaction, (7) the amount of potential follow-on investment that may be required for such investment in light of the capital available for each Account, (8) reasons of portfolio balance and rebalancing (e.g., for diversification purposes), (9) the perceived liquidity of an investment, (10) whether an Account is recently funded and is ramping an investment portfolio, and (11) any other consideration deemed relevant by Eagle Point in good faith. An Account may be prevented from being able to participate in all or a portion of an investment opportunity as a result of regulatory, tax or legal requirements. In allocating investment opportunities, Eagle Point may use rotational, percentage or other allocation methods provided that doing so is consistent with (1) Eagle Point’s internal conflict of interest and allocation policies, (2) the requirements of the Advisers Act, and (3) any applicable orders issued by the SEC, including orders relating to co-investments across certain Accounts and a Registered Fund. Eagle Point seeks to allocate investment opportunities among Accounts in a manner that is fair and equitable over time. However, there is no assurance

that such investment opportunities will be allocated to an Account fairly or equitably in the short-term and there can be no assurance that an Account will be able to participate in any particular investment opportunities that are suitable for it. Further, due to the tax treatment of certain Accounts (“Non-Participating Accounts”), other Accounts (“Participating Accounts”) may acquire a greater portion of certain loan and other credit-related investments than they otherwise would have acquired had Non-Participating Accounts been able to participate in the applicable investments, and such Participating Accounts may, at a later date, seek to sell such excess portion to one or more Non-Participating Accounts, all as described in an Account’s governing documents. There can be no assurance that a Participating Account will be able to affect any such sale and, as such, the Participating Account may continue to hold a larger portion of the applicable investment than it otherwise would have (in some cases, until the investment matures or is otherwise repaid by the issuer). In this case, the Participating Account would be subject to heightened portfolio concentration risk and other risks associated with the applicable investment.

Cross Transactions In certain circumstances, one or more Accounts managed by Eagle Point may seek to dispose of certain securities that may be desirable for other Accounts with available cash or liquidity (e.g., where one Account experiences a redemption while another has inflows, available cash or positions that Eagle Point desires to sell), or vice versa. Where permissible, Eagle Point may, but shall not be obligated to, cause an Account to purchase or sell securities from or to, as the case may be, another Account in a “cross trade” consistent with Eagle Point’s duty to seek best execution, its applicable policies and procedures reasonably designed to assure that all participating Accounts are treated fairly and that an appropriate price is assigned to the crossed security, and all applicable laws and regulations. Participating Accounts may pay full, reduced or no commissions or mark ups (or mark downs) in connection with a cross trade. In some cases, commissions may be paid to Eagle Point or an Eagle Point affiliate (unless prohibited by the relevant Account’s investment advisory agreement, Governing Documents, or other applicable disclosure documents or by law). Cross trades may reduce execution-related costs and/or improve execution quality for participating Accounts. In the event that an Eagle Point proprietary account participates in a cross trade with another Account, Eagle Point will seek appropriate consent in accordance with Section 206(3) of the Advisers Act as described in “Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.” Additionally, one or more Accounts managed by Eagle Point may engage in certain cross trades, if deemed appropriate for such Accounts, in connection with the inception of a new Account, for portfolio rebalancing purposes, for tax purposes, or for other business purposes. For example, Eagle Point may independently determine that securities sought to be disposed of by one or more Accounts may be desirable for a new Account and, accordingly, such new Account may acquire such securities in a cross trade consistent with the parameters described above. In addition, such transactions may occur in connection with the conversion of a loan accumulation facility to a CLO transaction.

No person or source, other than client Accounts, provides an economic benefit to Eagle Point for providing investment advice or other advisory services to the Accounts. From time to time, Eagle Point and/or a Private Fund compensate one or more placement agents for referrals of investors in a Private Fund. Such placement agents could be limited partners of a Private Fund or may also seek to do business with, and earn fees or commissions from, Eagle Point and/or its affiliates. While Eagle Point does not currently compensate persons for referrals of advisory clients in the United States, Eagle Point does maintain certain placement agent relationships for jurisdictions outside the United States and may in the future engage third party solicitors for separately management accounts in the United States. Compensation pursuant to such arrangements varies based on negotiations between the parties but generally is expected to include one or more of the following: (1) an upfront fee expressed as a percentage of either (a) assets raised by any such placement agent or (b) fees collected by Eagle Point and/or its affiliates resulting from such assets raised, (2) an ongoing fee expressed as a percentage of either (a) assets raised by any such placement agent or (b) fees collected by Eagle Point and/or its affiliates resulting from such assets raised, in each case for a fixed period of time (e.g., so long as the client referred by such agent remains a client of Eagle Point), and/or (3) a retainer-style compensation arrangement. Any such arrangement will comply with the requirements of the Advisers Act, including Rule 206(4)1 thereunder.

To the best of our knowledge, there are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Eagle Pont’s advisory business or the integrity of Eagle Point or its management personnel.

In general, an investment committee at the Firm retains authority to approve investment decisions for various Accounts, subject to any such committee’s delegation of certain investment decision making authority to senior investment team members. As of the date of this Brochure, the investment committee responsible for overseeing the Firm’s investments is comprised of certain Senior Principals of Eagle Point. Eagle Point’s investment personnel discuss investment ideas, implement investment decisions and review investments held by the Accounts through regular meetings among the Firm’s investment team and on a more informal basis in the ordinary course. These discussions and reviews are designed in part to monitor and analyze transactions, investment positions, investment levels, and overall portfolio risk, as well as global market conditions, risks and potential risks in the capital markets.

The applicable investment committee reviews potential investments for which authority has not been delegated as and when such investment opportunities arise and are recommended by the Firm’s investment team. Certain members of an investment committee also receive updates regarding valuations of investments held in certain Accounts, investment performance and general market developments. Furthermore, Eagle Point’s investment personnel and compliance professionals monitor and analyze the transactions, positions, and investment levels of the Accounts with a view to ensuring that they conform with the investment objectives and guidelines stated in the Accounts’ governing documents. Investors in the Private Funds and Registered Funds receive regular reports relating to the management and operations of the funds, including annual audited financial statements and periodic portfolio updates. Other Account holders receive such information as is agreed between the applicable client and Eagle Point, and such other information as may be required under applicable law.

Eagle Point has adopted policies and procedures to comply with Rule 206(4)-2 under the Advisers Act (the “Custody Rule”) and maintains cash and securities for which Eagle Point is deemed to have custody with one or more qualified custodians, unless an exception to such requirement is available under the Custody Rule. With respect to the Private Funds, upon completion of the Private Funds annual audit by an independent auditor registered with, an subject to inspection by, the Public Company Accounting Oversight Board (PCAOB), Eagle Point distributes independently audited financial statements to each Private Fund’s investors not later than 120 days after the end of the Private Fund’s fiscal year (i.e., generally by April 30 of each year). An investor in a Private Fund should contact Eagle Point if the investor does not receive audited financial statements on an annual basis as described herein. Investors should carefully review all statements received. Further, where Eagle Point manages client assets through a separately managed account, Eagle Point may from time to time be deemed to have “custody” of such accounts within the meaning of the Custody Rule due to Eagle Point having access to, or authority over, client funds and securities for purposes other than issuing trading instructions. While Eagle Point does not currently have custody over any such account, if Eagle Point is deemed to have custody over a separately managed account in the future, the applicable custodian will send the relevant client periodic account statements (generally on a quarterly basis) disclosing the amounts of any funds or securities in the account as of the end of the statement period and any transactions in the account during the

statement period. These statements should be reviewed carefully. In such cases, a separate account client should contact Eagle Point if it does not receive account statements from the custodian on at least a quarterly basis.

Eagle Point accepts discretionary authority to manage securities accounts on behalf of Accounts through an investment advisory agreement with each applicable client, which agreement may include investment limitations and restrictions. With respect to the Private Funds and the Registered Funds, this discretionary authority has no limitations but is subject to the investment guidelines and other terms and conditions contained in each such fund’s Governing Documents and/or other disclosure documents and agreements.

In compliance with Rule 206(4)-6 under the Advisers Act (the “Proxy Voting Rule”), Eagle Point has adopted proxy voting policies and procedures. It is Eagle Point’s general policy to exercise an Account’s voting or consent rights in a manner that serves the interests of the Account in line with the Account’s investment objective. Eagle Point may occasionally be subject to material conflicts of interest in exercising these rights due to business or personal relationships Eagle Point maintains with persons having an interest in the outcome of certain matters. If at any time Eagle Point becomes aware of a material conflict of interest relating to a particular proposal, the Firm’s Chief Compliance Officer will review the proposal and determine the action to take with respect to the proposal in a manner consistent with interests of the applicable Accounts. Clients who wish to obtain either a copy of Eagle Point’s proxy voting policies and procedures, or information as to how Eagle Point voted proxies with respect to their Account, can submit their request to Eagle Point’s Chief Compliance Officer at the address on the front cover of the Brochure.

Eagle Point does not require the payment of management fees or other compensation six months or more in advance. As such, we are not required to include a balance sheet for our most recent fiscal year. Eagle Point has never been the subject of a bankruptcy petition and does not believe that there are any conditions that are reasonably likely to impair its ability to meet its contractual commitments to clients. * * *