EJF Capital LP

The Company EJF is a majority employee-owned alternative asset management firm headquartered outside of Washington, DC. EJF manages assets across a diverse group of alternative asset strategies that specialize in the financial industry. EJF was founded in 2005 by Emanuel J. Friedman and Neal Wilson along with a small team of professionals from Friedman, Billings, Ramsey Group, Inc. (“FBR”). EJF and its subsidiaries currently employ over 40 professionals across two offices globally (Arlington, VA and London, United Kingdom). Prior to launching EJF, Mr. Friedman was the co-founder and Co-Chief Executive Officer of FBR for more than 15 years. Mr. Friedman possesses more than 40 years of experience in the U.S. securities industry with a particular expertise in banks and financials. Mr. Wilson previously managed both the Alternative Asset Investments and the Private Wealth Management groups at FBR and served as a Branch Chief with the U.S. Securities and Exchange Commission in Washington, DC. EJF is an investment advisory firm that started its investment advisory operations in September 2005. EJF is a Delaware limited partnership that converted from a Delaware limited liability company on January 1, 2026. Emanuel Friedman, Neal Wilson and Jason Ruggiero are the management members of EJF Capital GP LLC, the general partner of the Firm. A third-party investor, Kudu Investment Management LLC (“Kudu”), which is registered with the SEC as an investment adviser, owns a minority economic stake in EJF. EJF has one affiliated entity located in London, United Kingdom. EJF also has three relying advisers. Contact information for EJF’s headquarters, its affiliated entities, and the relying advisers is as follows: EJF Capital LP 2107 Wilson Boulevard, Suite 410 Arlington VA 22201 EJF Capital Ltd. 16 Berkeley Street London, UK W1J 8DZ EJF CDO Manager LLC 2107 Wilson Blvd, Suite 410 Arlington, VA 22201

EJF Investments Manager LLC 2107 Wilson Blvd, Suite 410 Arlington, VA 22201 Armadillo Financial Partners LLC 2107 Wilson Boulevard, Suite 410 Arlington, VA 22201 Types of Advisory Services EJF provides discretionary investment advisory services and sub-investment advisory services to pooled investment vehicles and single investor funds (each, a “Fund”, and collectively, the “Funds”). EJF serves as the manager for the Funds and is responsible for the Funds’ trading and other day-to-day activities. Armadillo Financial Partners LLC (“Armadillo”) provides portfolio management services to certain Funds that invest in loans and other financing transactions with law firms. EJF Investments Manager LLC (“EJFIM”) provides portfolio management services to certain Funds that invest in collateralized debt obligations (“CDOs”). EJF CDO Manager LLC (“CDO Manager”) provides collateral and portfolio management services to securitized asset funds and CDOs. Each of Armadillo, EJFIM and CDO Manager are included in Form ADV, Schedule R, as relying advisers. EJF does not tailor its advisory services to the individual needs of investors in its commingled Funds. EJF is subject to investment guidelines and limitations with respect to some of the Funds. These investment guidelines and limitations (if any) are described in each Fund’s offering documents (or a separate document) and monitored in EJF’s portfolio management system (to the extent practicable). EJF also provides discretionary and non-discretionary investment advisory services and subinvestment advisory services to separately managed accounts (“SMAs,” together with Funds, each a “Client”, and collectively “Clients”) and single investor Funds. With regard to SMAs, the advisory accounts are managed according to the Client’s investment guidelines and limitations as they appear in the Client’s investment management agreement or a separate document. EJF develops and maintains model portfolios and securities baskets that are comprised of securities. These models and baskets are licensed or otherwise made available (including through

the wrap program in which EJF participates) to third party investment advisers and intermediaries. Other than the Wrap Program Clients (defined below), the end-users of the model portfolio and/or basket data are granted a limited license to utilize the data for their own business purposes, which may involve utilizing such data as an investment strategy for their own investment portfolios and/or their underlying client accounts. Wrap Program EJF provides discretionary model management services as part of a wrap-fee program (“Wrap Program”) offered by an investment adviser/broker-dealer (“Sponsor”). A wrap fee program is a program where a client is charged a specified “bundled” fee (generally, a percentage of assets under management) for discretionary investment management services and trade execution costs and sometimes other services such as custody, record keeping and reporting. In connection with the Wrap Program, EJF provides model portfolio recommendations via the Sponsor’s platform, but has no discretionary authority or responsibility for asset allocation or securities selection on behalf of any account on the platform. EJF does not act as Sponsor for the Wrap Program and is not an affiliate of the Sponsor. The Sponsor provides various services to its clients (“Wrap Program Clients”), which typically include portfolio management, trade execution, custody, performance monitoring, reporting, and other services for an all-inclusive fee (“Wrap Fee”). The model management services EJF provides to Wrap Program Clients are only available to clients of the Sponsor who have opened an investment account with Sponsor or one of its affiliates who also offer the Wrap Program. The Sponsor pays EJF a portion of the Wrap Fee received by the Sponsor from those Wrap Program Clients whose accounts utilize the model managed by EJF. Under the Wrap Program, the Sponsor retains discretionary responsibility for the asset allocation and securities selection on behalf of Wrap Program Clients and is responsible for defining the Wrap Program Client’s overall investment objectives, making suitability assessments, executing transactions, contacting the Wrap Program Clients to ascertain whether there has been any change in their financial circumstances or objectives and communicating this information to EJF. EJF utilizes a third-party service provider to execute certain purchases and sales, subject to the general oversight of the Sponsor. In addition, EJF makes itself reasonably available to the Sponsor and the Wrap Program Clients for joint consultations. EJF does not offer or provide the same or similar model management services to any Clients other than the Wrap Program Clients. The model management services EJF provides for Wrap Program Clients do not reflect the impact that material economic, market and other factors would have had on EJF’s decision making if EJF were managing a portfolio of assets pursuant to a particular model. Unlike for its other Clients, EJF also does not recommend cash management activities or

include money market or cash-equivalent investments as part of its model management services. The investment results achieved utilizing EJF’s model management services at any given time could and will differ from the investment results achieved for EJF’s Funds and other Clients, including for the same or similar investments. Assets Under Management As of December 31, 2025, EJF managed client assets on a discretionary basis in the approximate amount of $6,036,600,141. As of December 31, 2025, EJF managed client assets on a nondiscretionary basis in the approximate amount of $64,675,177.

The fees and compensation applicable to each Client is set forth in detail in each Client’s offering documents or investment management agreement, as amended from time to time. A brief summary of such fees is provided below. Clients generally pay an asset-based management fee in connection with EJF’s advisory services. Clients may also pay performance-based compensation, generally at the end of each calendar year or at the termination of a Fund’s term, based on a percentage of the increase in the value of each Client’s investment, subject to certain limitations and discounts. On occasion, certain Clients will pay fees to EJF for investments where other Clients will pay lesser or no fees for the same or substantially similar investments. Funds As the investment adviser responsible for managing the Funds, EJF charges a maximum management fee of 2% based on AUM, and a maximum performance-based compensation of 57.5% of the Funds’ profits, or 25% of the Funds’ profits over a stated preferred rate of return. EJF could agree to charge certain Funds or certain Funds’ investors lower management fees and performance-based compensation, even if the assets are managed in a similar investment style. EJF may also decide to waive all or a portion of the Firm’s negotiated fees for a given period or for a particular Client or investors. For example, EJF may decide to negotiate its management fee because of the timing of an investor’s subscription to a Fund, the amount of investor’s assets within the portfolio, or other relationship to the Firm. Certain Clients are invested in Funds managed by EJF, in which case those Clients will be placed in a non-fee paying class of the Funds in which they are invested (certain EJF employees are in a non-fee paying class). Certain Funds calculate and pay management fees to EJF monthly in arrears, and several Funds calculate management fees on a quarterly basis in arrears. A small number of funds calculate and pay management fees to EJF in advance. In addition, EJF manages several Funds that are closed

to new investors and do not pay any management fees. Certain investors in the Funds have special management fee arrangements that are described in the Funds’ offering documents. In the case where management fees to EJF are advanced and the advisory contract with EJF is terminated before the end of the billing period, investors will receive a prorated refund from the Fund. Investors can request the refund by written notice to the Fund requesting a prorated refund. Certain Funds that are open to new investors calculate and pay performance-based fees at the end of the Fund’s fiscal year and several Funds calculate and pay performance-based fees at the dissolution of the Fund. These fees may be subject to preferred return hurdles, catch-up allocations and/or claw-backs, depending, among other things, on the strategy of the Fund. Funds - Deduction of Management Fees Management fees for all Funds are deducted either monthly, quarterly, or semi-annually from each Fund’s portfolio. Management fees are first segregated into an escrow account by EJF personnel pursuant to EJF’s written money transfer policies and procedures. Management fees remain in the escrow account until the Fund’s administrator verifies the amounts. After the administrator verifies the management fee amounts, the administrator moves the assets to an EJF bank account. Funds - Transaction/Trading Costs Broker-dealers executing Client trades generally charge a brokerage commission on equity securities and a markup or markdown on fixed income securities. For example, fixed income securities trade at a bid/ask spread and have no explicit brokerage expense. Although there is no brokerage commission charged on fixed income securities transactions, the Funds will incur the implicit trading cost reflected in the broker/dealer spreads. For additional information regarding the Firm’s trading practices, see Item 12, Brokerage Practices. Securities transaction costs are paid by the Client, not EJF. In addition to transaction costs, certain Funds also pay expenses that include but are not limited to: organization costs, modeling expenses, custodian fees, legal and audit expenses, taxes, pricing services, and administrative fees. Additional information regarding transaction costs is located in Item 12, Brokerage Practices. Funds - Other Fees or Expenses Charged to the Funds To the extent permitted under the applicable offering documents, as amended from time to time, Funds advised or sub-advised by EJF bear all of their operating expenses, including but not limited to some or all of the following expenses directly or indirectly: (i) fees or expenses associated with structured products or other securities in which the Funds invest, such as management fees associated with collateralized debt obligations, exchange-traded funds, money market mutual funds, or other securities, and, in the case of transactions that are not consummated, broken deal

expenses; (ii) investment expenses (e.g., expenses that the Fund determines to be related to the investment of the assets of the Fund, including, among others, all expenses relating to identifying, monitoring, investigating, researching, purchasing, acquiring, selecting, making, financing, hedging and disposing of investments, due diligence and research expenses (including market research), collateral valuation services, referral fees, origination fees, and costs incurred by EJF principals and employees and third parties in connection with their attendance at conferences (including all lodging, transportation, meal and entertainment expenses), risk analytical software for use by the Fund, investment-related data services (including fees, costs and expenses related to hardware (including Bloomberg terminals), software (including any order management system software) and subscriptions (including Bloomberg subscriptions)), fees or commissions of any futures commission merchant, brokerage commissions custodial fees and expenses, expenses relating to reorganizations, restructurings and workouts involving investments, costs and charges for equipment or services used in communicating information regarding the Fund’s transactions between the general partner and the Fund’s custodian or other agents, bank service fees, interest expenses, borrowing costs, fees and expenses of consultants or experts retained to provide services related to any of the foregoing, investment expenses and extraordinary expenses); (iii) sourcing fees (including referral fees, success fees, origination fees, finder’s fees and other compensation paid to third-party senior advisors, sourcing partners and/or operating partners); (iv) fees and charges of clearing agencies; (v) interest and commitment fees on loans and debit balances; (vi) income taxes, withholding taxes, transfer taxes and other governmental charges and duties (including fees, costs and expenses incurred in connection with governmental and regulatory filings) as well as expenses incurred in connection with tax preparation; (vii) fees of legal advisors (including legal expenses related to investments), independent auditors, accountants, fund administrators, trustees and expenses for oversight, or other third-party service providers that facilitate administrative and portfolio monitoring services, research services or software for the Fund; (viii) professional fees (including fees and expenses of consultants and experts) relating to investments; (ix) board members’, directors’ or advising committee (e.g., of a strategic advisory panel composed of senior attorneys with expertise in mass torts, product liability or other types of litigation and/or such other persons that EJF has determined to have specialized expertise in litigation matters or the claims that serve as collateral for or may otherwise be related to an investment) fees and expenses (including compensation of the members thereof), if any, (x) the costs of any liability insurance, deal-related insurance, or fidelity bonding obtained on behalf of or for the benefit of the Funds; (xi) the costs of maintaining the Funds’ recognition, registered agents and registered offices in a variety of jurisdictions; (xii) costs incurred costs in connection with any claim, litigation, arbitration, mediation, government investigation or dispute in connection with the business of the Fund and the amount of any judgment or settlement paid in connection therewith, or the enforcement of the Fund’s rights against any person; (xiii) the costs of any communications with investors, including providing reports and notices; (xiv) travel expenses, including, but not limited to, all lodging, transportation (including first-class arrangements), meal and other entertainment expenses incurred by employees or principals of EJF and its affiliates or

third parties in furtherance of the Fund’s activities; (xv) any broken-deal expenses; (xvi) initial and ongoing offering expenses, including expenses relating to the Fund’s organizational documents and the subscription agreement or other agreements entered into with any investors (including expenses related to negotiations with investors and potential investors (including with respect to the negotiation and entering into of side letters) and expenses or fees related to electronic subscription agreement products or platforms), as well as expenses relating to the review and processing of subscription agreements and related documentation with respect to prospective subscriptions for interests, any modification to or supplement of such documents, any distribution of such documentation to the investors and prospective investors and certain costs associated with the Fund complying with such agreements or legal requirements, and any printing costs, marketing costs and legal fees;(xvii) fees for escrows, storage, custodians and other out of pocket expenses; (xviii) expenses relating to the transfer, withdrawal or redemption of interests in the Fund; (xix) fees and expenses of a service company retained to provide accounting, administrative and/or bookkeeping services (including fees and expenses incurred in connection with the oversight and/or maintenance of the Fund and its investments); (xx) prime brokerage expenses; (xxi) quotation or valuation expenses (including fees and expenses of any third parties engaged to provide valuation or appraisal services to the Fund); (xxiii) indemnification and contribution expenses as defined in the underlying documents of the Fund or in underlying transaction documents; (xxiv) all costs and expenses incurred as a result of the restructuring, reorganization, dissolution, winding up or termination of the Fund; (xxv) costs and expenses of any third parties retained by EJF in connection with any research, third-party examinations or audits by regulatory or other similar authorities, including the costs associated with the production and review of materials requested in such examination or audit; and (xxvi) historical and ongoing expenses related to the development and licensing of a technology platform used to assist with loan administration and/or due diligence of borrowers’ cases or collateral and the tracking of such collateral, including the fees charged by any consultant retained to assist in the foregoing and any other similar or related fees and expenses. For certain Funds, the Client will pay additional fees for outside service providers, such property managers, operating partners, development or sourcing fees and other investment-related fees, some of which service providers are affiliated with the general partners. These fees and expenses will vary and may or may not be appropriate for you on your Fund. A portion of these operating expenses may be shared with other Clients, EJF or its affiliates. For more information on broken-deal expenses, refer to “Clients – Fee and Expense Allocation Generally”. EJF and its affiliates are permitted to receive transaction fees, breakup fees, “topping” fees, advisory fees, consulting fees, director’s fees (including cash and non-cash compensation) and similar fees in connection with actual or contemplated investments; provided that, in any case, EJF and its affiliates are not permitted to receive compensation that would amounts to accelerated advisory fees or fees for broker-related services. It should be noted that EJF, or its affiliates, acts as administrator for some Clients’ accounts, and it receives a fee for performing such services.

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EJF primarily provides advice regarding private credit investments, structured finance opportunities, and other public and private debt instruments that are supported by pools of loans, fixed income securities or other types of cash-flowing and non-cash flowing assets. EJF also advises Clients in connection with real estate development opportunities as well as public and private equity investments in traditional financial services companies and fintech companies. EJF’s investment ideas are generated from a wide variety of sources it monitors in connection with its overarching focus on anticipating and positioning around new legislation and regulatory shifts in both highly regulated and less regulated industries. EJF generally employs a value-based, fundamental approach to security selection with a macro overlay based on the regulatory environment. Regardless of the strategy utilized, EJF believes that value for Clients is ultimately achieved through a long-term view that focuses on unlocking value in the wake of new legislation and/or regulatory changes.

All Clients utilize one or more of the following strategies in accordance with their respective mandates and governing documents: Public Equity Strategies One of EJF’s equity strategies is designed to pursue absolute returns, and to achieve long-term capital appreciation from investments providing exposure to securities issued by companies primarily within the banking and broader financial services industry operating in certain regions of the world. EJF will generally emphasize individual security selection (“bottom-up” investing) and considers a wide range of factors in determining whether a security is overvalued or undervalued. EJF takes long positions in companies that it believes to be high quality with aboveaverage growth at attractive multiples, and short positions in companies that it believes are underperforming relative to the market. EJF uses an equity long/short strategy for Funds, and long-only strategies for a Fund and sub-advised SMAs, that primarily seek to invest in securities that are listed, quoted, or traded on stock markets domestically and internationally. Another equity-focused strategy seeks to take advantage of tactical investment opportunities primarily in non-bank financial services companies. Investments in this strategy are not limited to equity investments as it involves investing across the capital structure of such companies, however, it is primarily invested in equity securities issued by companies engaging in spin-off transactions and tender offers. The strategy also utilizes constructive engagement with company management teams that can benefit from EJF’s in-house capital markets expertise and historical investment acumen. Securities in this strategy are issued by either domestic or foreign companies. A Fund using this strategy may also invest in securities consisting of packages of securities that have equity-like characteristics or equity-like returns. These securities could include the purchase or sale of put or call option contracts, shorting shares of common stock or debt, and other securities that EJF finds appropriate. Private Equity and Credit Strategies EJF’s private equity focused strategies aims to capitalize on US small and community banks impacted directly or indirectly by: (1) bank and thrift recapitalizations and/or restructurings; (2) merger and acquisition activity; and (3) bank regulatory capital limitations; (4) government financial reform. Equity and debt capital provided to the companies may be used for loan growth, acquisitions, infrastructure and technology buildout or other general corporate purposes including balance sheet restructuring. EJF typically receives board seats, board observation rights and management information rights when investing in these institutions.

A changing regulatory regime has resulted in banks and similar financial institutions deleveraging their portfolios and seeking to dispose of certain higher-risk assets that they view as “capitalinefficient” (i.e., the capital requirements imposed on banking and similar financial institutions in connection with holding certain assets makes their retention by such institutions impracticable and unattractive). Additionally, while an active market has developed for the disposition of such assets by large commercial banks, the Firm believes that, as a result of having a smaller capital base and limited access to capital markets, regional and community banks have had fewer options for efficiently deleveraging and disposing of these assets. The Firm will seek to leverage its experience in the capital markets, including its experience with community banks on behalf of the strategy, to take advantage of market opportunities that are available in the financial industry and related sectors as a result of these changes and, potentially, other market opportunities that become available in the financial industry. The Fund will seek to achieve its objective of designing capital solutions with financial institutions through utilizing credit defaults swaps, debt, hybrid debt securities and collateralized debt obligations. Additionally, the strategy may incorporate the use of equity ad warrants, real estate related loans and leases, and cash and short-term investments. Periodically, EJF affiliates managing private equity funds may come into possession of material non-public information that restricts other EJF affiliates from investing in, or engaging in purchase and sale transactions with certain public issuers. CDO and CLO Securities. For certain of its Clients, EJF may design structured finance products including Collateralized Debt Obligations (“CDOs”) and Collateralized Loan Obligations (“CLOs”) which are generally limited recourse obligations of the issuer thereof payable solely from the collateral owned by such issuer or the proceeds thereof. The value of such securities generally will fluctuate with, among other things, the financial condition of the obligors or issuers of the underlying portfolio of assets of the related CDO or CLO, general economic conditions, the condition of certain financial markets, political events, developments or trends in any particular industry and changes in prevailing interest rates. Consequently, the holders of such securities must rely solely on distributions on the underlying collateral or proceeds thereof for payment in respect thereof. If distributions on the underlying collateral are insufficient to make payments on such securities, no other assets will be available for payment of the deficiency and following realization of the investment, the obligations of such issuer to pay such deficiency generally will be extinguished. The underlying collateral may consist of high-yield debt securities, loans, asset- or mortgagebacked securities and other instruments, which often are rated below investment grade (or of equivalent credit quality). High-yield debt securities generally are unsecured (and loans may be unsecured) and may be subordinated to certain other obligations of the issuer thereof. The lower ratings of high-yield securities and below investment grade loans reflect a greater possibility that adverse changes in the financial condition of an issuer or in general economic conditions or both

may impair the ability of the related issuer or obligor to make payments of principal or interest. Such investments may be speculative. Non-Marketable Loan Strategies An investment objective under this strategy is to earn interest income by providing financing to plaintiff law firms participating in mass tort litigation or other similar litigation. The investment strategy could result in highly concentrated and illiquid positions. This strategy seeks to provide loans to law firms; such loans are secured by the firms’ interests in future award settlements from selected dockets (i.e., a group of cases against one defendant or group of defendants) of mass tort cases. The strategy will primarily focus on lending in three areas of mass tort litigation: (i) pharmaceutical, (ii) medical devices, and (iii) other product liability including asbestos/mesothelioma. Additionally, the strategy may take advantage of other similar opportunities in financing plaintiff law firms participating in other types of litigation. Real Estate Strategies EJF’s real estate investment strategy is designed to take advantage of certain opportunities arising from recent tax reform in the country and can invest in a broad range of real estate and real estaterelated investment opportunities. This strategy seeks to maximize value through acquisition or funding of ownership interests in individual real estate assets, joint ventures, special purpose vehicles related to real estate or real estate related assets. Such investments are anticipated to be longer-term in nature and will involve developers or other third parties. This strategy will primarily focus on investments operating in qualified opportunity zones that can provide potential tax benefits to investors. Venture Capital Strategy EJF’s venture capital strategy seeks to achieve attractive risk-adjusted returns, principally through venture capital investing in equity, equity related investments, SAFE investments, forward purchase agreements, convertible preferred equity, debt, convertible debt, digital assets, warrants, options, and other derivatives issued by early-stage private companies related to the financial sector positioned for growth. The strategy seeks to invest in disruptive companies that aim to bridge the gap between legacy financial institutions and the financial services ecosystem of the future. The strategy may invest on an opportunistic basis and, as such, may seek to make venture or venture-like investments in sectors and industries both related and unrelated to the financial services industry and/or the technology sector, including nascent industries that are emerging or that may emerge over the life of the strategy.

Risks Relating to Investment Strategies The investment strategy for each of EJF’s Clients involve a substantial degree of risk of loss that Clients should be prepared to bear. The Firm has listed certain risks below; however, the list of risks is neither comprehensive nor complete. Clients and investors are strongly encouraged to review the risks of their investment strategy, as contained in the private placement memorandum, in organizational documents and/or as set forth in the Client’s investment management agreement. In addition, while certain risks may be more important for certain investment strategies, certain risks may overlap and apply to multiple investment strategies. For example, on certain occasions EJF and/or its related persons may engage in transactions where EJF and/or its related persons will provide liquidity for certain Clients through conflicted or cross transactions. Such transactions present the risk of costing Clients potential future investment income. On such occasions, EJF strives to provide disclosure to the Client prior to the transaction. Public Equity Strategy Related Risk EJF’s Public Equity Strategy is to seek to seize upon improperly valued publicly traded securities in the market, and sectors that EJF deems an opportunity. Each strategy may be subject to such risks as a fluctuation in securities prices and interest rates, movement in the United States’ and certain foreign countries’ economic growth rates, political events that may have an impact on equity markets, concentration risk, macroeconomic risks, contagion risk, liquidity risk, volatility, and valuation. EJF is an active manager of risk and will utilize short positions, derivatives such as put and call options and other various hedging techniques to reduce volatility and risk of loss. Private Equity and Private Credit Strategy Related Risks While the Firm strives to attain the investment objective of the Funds through its research and portfolio management skills, there is no guarantee of successful performance, that the investment objective can be reached or that a positive return can be achieved. As a general rule, investors can expect that investments with higher return potential will also have higher potential of risk of loss of capital or income. Prospective investors in the Funds should consider the following risks, which are not intended to be an exhaustive listing of all the risks involved in an investment in this strategy. Clients could have control positions in addition to advisory roles in private equity and credit investments, along with certain contractual rights to protect their investments (including shareholder agreements, redemption rights and/or placement of a designee of the Firm or an affiliate on the boards of directors or as a board observer of portfolio companies), but such Clients do not always have control over their portfolio companies. A Client runs the risk of refusal of management or shareholders of portfolio companies to adopt the recommendations of such Client, disagreement with existing management and any resulting negative impact on the value of the

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In addition to Funds, EJF has SMA clients and Fund investors that include but are not limited to the following categories: foundations, trusts, estates, IRAs, retirement plans, funds of funds, endowments, pensions, banks, insurance companies, other business entities, sovereign wealth funds, high net worth individuals, and family offices. As EJF continues to do business, additional categories will be included if appropriate. The minimum investment amount for investors in any of the Funds is between $100,000 and $1,000,000; with regard to offshore Funds, the minimum investment is mandated by law to be $100,000. The minimum investment amount to open an SMA is generally $10,000,000, and for those SMAs in which EJF acts as sub-investment adviser, including, the Wrap Program, the minimum investment amount is $100,000. EJF and its affiliates reserve the right to waive the minimum investment amount for investors in the Funds or individuals/entities opening SMAs.

EJF charges certain Clients performance-based fees and certain Clients pay different performancebased fees. The receipt of performance-based fees creates a conflict of interest for EJF. Since

positive investment returns would likely increase the performance fee paid to EJF by its Clients, the Firm has an incentive to favor those Clients that pay EJF a performance fee or higher performance fees. For example, if EJF allocated profitable trades exclusively to those Clients that pay EJF a performance-based fee or the highest performance fee, EJF would have a conflict of interest. EJF manages this potential conflict of interest by creating, implementing, and enforcing trade allocation policies and procedures. EJF believes that it has policies and procedures that will result in fair trade allocations to Clients over time, even though a particular trade allocation appears to benefit one or more accounts when viewed individually. Whenever possible, EJF will bunch trade orders to minimize trade execution cost and to assist with obtaining best execution. There could be occasions when EJF does not allocate a particular security to a Client in the same investment strategy as another Client that received a trade allocation. Reasons for not allocating a security to a Client include but are not limited to the following: the investment guidelines/restrictions do not permit the purchase of the security; the Client’s portfolio currently contain the prescribed limits of the security or a similar security that is designed to fill the same investment objective; the Client does not have a sufficient cash balance to participate in the trade; the Client has a different risk/return profile than another account, the Client has materially different tax consequences than another account, the Client has unique investment goals; the Client has different liquidity requirements; or a security is only issued in increments of a certain size and the smallest increment of the security for the allocation exceeds the Client’s limit. These limitations to allocation could result in different investment holdings, and performance returns for Clients with assets in the same investment strategy and managed by the same portfolio management team. As stated in Item 5, EJF also charges its Clients an asset-based management fee. As noted above, certain Funds managed by EJF are charged an annual performance fee. This fee is up to 57.5% of the excess, if any, of the net asset value of each series of units or shares in a Fund over a high-water mark and, in certain cases, a hurdle. Certain Funds, as well as classes within Funds, are not subject to a high-water mark. Additionally, the Firm, in accordance with applicable provisions of the Fund’s offering documents, may transfer investors between classes. Not all investors in the Funds are subject to the 57.5% performance fee charged by the Funds. In addition, certain Funds are subject to claw-back provisions with regard to performance fees. Generally, performance fees are not finally determined with regard to private equity funds until the Fund is closed and assets are returned to Fund investors. Certain other Funds and certain SMAs generally pay EJF performance fees annually. However, on a monthly or quarterly basis, a performance fee accrual is made on EJF’s books for each applicable Client.

With regard to certain SMA clients for whom EJF acts as investment adviser, not in sub-advisory capacity, EJF is entitled to receive an annual performance fee of up to 10% of any realized and unrealized capital appreciation of AUM (at least one SMA client may pay a performance fee that is less than 15%), subject, in certain cases, to a threshold amount. Performance-based fees are negotiable. EJF does not charge any of its Clients a flat fee or a fee that is calculated based on hourly rates.

Registered Individuals of a Broker-Dealer EJF does not have an affiliated broker-dealer, nor are any of its employees registered or seeking registration with a non-affiliated broker-dealer. Other Registered Entities As of the date of this Brochure, EJF is registered as a commodity pool operator and a commodity trading advisor with the CFTC. However, EJF has formally commenced proceedings to withdraw from registration pursuant to CFTC No-Action Letter 25-50. The Firm anticipates this withdrawal to occur in calendar year 2026. With regard to the Alternative Investment Fund Manager Directive (“AIFMD”), EJF has made notice filings in a number of foreign jurisdictions. These notice filings allow EJF to market certain Funds to prospective investors in the countries where the filings have occurred. Relationships Material to Advisory Business As discussed above in Item 4, EJF has a number of affiliated entities; these entities are: EJF Capital Ltd. (the “UK Affiliate”), CDO Manager, EJFIM and Armadillo. EJF established the UK Affiliate in the United Kingdom (“UK”), which performs research activities. EJF owns 100% of the interests in the UK Affiliate. CDO Manager is a relying adviser on EJF’s Form ADV and serves as collateral manager for certain CDOs and note securitization products. EJFIM owns 51% of the interests in CDO Manager.

EJFIM is a relying adviser on EJF’s Form ADV, serves as manager of certain funds. EJF owns 100% of the interests in CDO Manager. Armadillo is a relying adviser on EJF’s Form ADV and serves as manager for certain funds. EJF owns approximately 51% of the interests in Armadillo. Also, as noted previously, Kudu, an investment adviser registered with the SEC, owns an economic minority stake in EJF. Kudu’s investment is passive and non-controlling, and the Firm does not believe it presents a material conflict of interest with any Client. From time to time, Kudu recommends that its clients invest in the Clients or refers its clients to EJF. However, such referrals are not material to EJF’s business. Broker-Dealers EJF has entered into a number of solicitation agreements with registered broker-dealers. Under the solicitation arrangements, broker-dealers refer to EJF high net worth individuals or entities that the broker-dealer has determined are qualified to invest in EJF’s products. Broker-dealer solicitors are generally paid a percentage of the management fee and/or the performance fee received by EJF from the Fund in which the high net worth individual or entity invests. These broker-dealers may issue, underwrite, sponsor or facilitate certain securities in the capital markets for themselves or the benefit of their clients. EJF will purchase and sell such securities for Client accounts as an investment for their account. While these investments are made independent of the aforementioned business relationship, they nonetheless present a conflict of interest for EJF. EJF also has arrangements with broker-dealers that receive a placement fee for placing investors in certain EJF Funds. The broker-dealer placement agent could receive a fee that is up to 2.5% of the assets invested in the Fund by the placed client (this is a one-time fee ultimately paid by the investor). Certain broker-dealers also receive an ongoing fee up to 0.5% per annum of assets invested in a Fund by the placed investor (this fee is also ultimately paid by the investor). It should be noted that an investor’s account can be charged higher or lower Management and/or Performance-based fees of the Fund than if the investor came to EJF directly. A full description of applicable fees can be found on the applicable Fund’s offering memorandum, EJF’s subscription documents, as well as the investor’s account statements. EJF may maintain placement agent agreements with broker-dealers that may also act as executing brokers, prime brokers, custodians, trustee, or other vendors of Clients. EJF does not believe such relationships are material, but could pose a conflict of interest for its Clients. Additionally, EJF also issued notes, bonds and other borrowing facilities with certain lending institutions that are affiliated with broker-dealers or other financial institutions. EJF believes such

relationships are may pose a conflict of interest for EJF and its Clients and will restrict Clients from owning such securities. Pooled Investment Vehicles EJF manages the following pooled investment vehicles: EJF Debt Opportunities Master Fund II, LP, EJF Debt Opportunities Fund II, Ltd, EJF Debt Opportunities Master Fund, LP, EJF Debt Opportunities Fund, LP, EJF Debt Opportunities Offshore Fund, Ltd, EJF Financial Services Fund LP, EJF Financial Services Offshore Fund, Ltd, EJF Opzone Fund I LP, EJF Opzone Fund II LP, EJF Sidecar Fund, Series LLC – Small Financial Equities Series and EJF Sidecar Fund, Series LLC – Series F, LP, EJF Ventures Fund LP, EJF Ventures Offshore Fund LP, EJF Financial Debt Strategies Fund LP, EJF Financial Debt Strategies Offshore Fund LP, EJF Funding Offshore LP, EJF Tactical Opportunities Fund LP, EJF Tactical Opportunities Offshore Fund LP, Rocade Capital Fund IV LP, Rocade Capital Offshore Fund IV LP and EJF Rocade Fund V LP collectively, the “Rocade Funds”). For additional information on the Rocade Funds, refer to “Law Firm Lender Joint Venture.” In addition, CDO Manager, Armadillo and EJFIM manage or advise pooled investment vehicles. Specifically, Armadillo manages or advises Armadillo Financial Offshore Fund III LP and Armadillo Financial Holdings III LP. EJFIM serves as the manager for EJF Investments Limited and EJF Investments LP. CDO Manager serves as the collateral manager for the following securitized asset funds: Attentus CDO I, Ltd., Attentus CDO II, Ltd., Kodiak CDO I, Ltd., Kodiak CDO II, Ltd., TruPS Financials Note Securitization 2022-1 Ltd., TruPS Financials Note Securitization 2025-1 Ltd., TruPS Financial Note Securitization 2025-2 Ltd., TruPS Financial Note Securitization 2025-3 Ltd and TruPS Financial Note Securitization 2026-1 Ltd. SMAs generally invest in Funds and certain of our Funds with a private credit strategy invest in securitization. EJF manages multiple Client accounts with similar mandates, strategies and even similar holdings which may create conflicts of interest. The Firm is not obligated to devote any specific amount of time, resources, or effort in managing any Clients’ accounts. Furthermore, Clients’ accounts from time to time compete for investment opportunities, research, internal resources, or even allocation of trades. Certain Clients from time to time also invest in different parts of the capital structure of the same issuer, which may advance or conflict with interests of other Clients, and may directly or indirectly provide economic benefit to other Clients. These transactions impact the valuation, solvency, liquidity and ultimately the performance of Client accounts, and subsequently EJF’s fees, which poses a conflict of interest. For addition information on the conflicts that relate to such investments, refer to Item 12, Brokerage Practices – Conflicts

of Interest. Certain Clients’ accounts also restrict the trading of other Clients’ accounts by availing themselves of non-public information in commonly held securities, or ownership limitations. Alternatively, where appropriate and in the best interest of its Clients EJF may implement information barriers between individuals within the Firm to prevent adversely impacting the ability of persons at EJF, especially persons who are involved in trading or the making of trading recommendations, to perform their usual functions. Given the industry in which EJF performs advisory services, EJF interacts with various entities in many different capacities on behalf of its Clients. Certain managers of pooled investment vehicles, and their affiliates, from time to time act as: competitor, partner, purchaser, seller, investor, coinvestor, counterparty, financer, or trader with EJF’s Clients at various points and in different capacities. While EJF does not retain any material relationships with such entities, such interactions could present a conflict of interest. Banking or Thrift Institutions For information regarding EJF’s relationships with banking or thrift institutions, see “Item 8— Methods of Analysis, Investment Strategies and Risk of Loss—Management Risk” Law Firm Lender Joint Venture EJF and various investment affiliates of Barings LLC, a subsidiary of MassMutual (the “Barings Entities”), capitalized a newly formed entity, Rocade Holdings LLC (together with its subsidiaries, the “Joint Venture”), which pursues a litigation finance platform. EJF owns common equity of the Joint Venture. The Barings Entities maintain a controlling interest in the Joint Venture. The Armadillo investment team of Brian Roth, Jake Cantrell, and Harry Devens became employees of the Joint Venture, with Brian Roth serving as Chief Executive Officer and Chief Investment Officer of the Joint Venture. Such persons are no longer directly employed by EJF, but will provide certain services to EJF. The investment committee of the Joint Venture is composed of Brian Roth, Jake Cantrell, Harry Devens and two members appointed by the Barings Entities. EJF has provided certain administrative and back-office services to the Joint Venture pursuant to a transition services agreement. EJF has received a fee from the Joint Venture for such services based on the invested capital of the Joint Venture and its subsidiaries. The Joint Venture provides certain administrative services to EJF in respect of its remaining litigation finance funds in exchange for an administrative fee based upon such funds’ invested capital. The administrative fee will be borne by EJF. There are conflicts of interests associated with Brian R. Roth and Jacob K. Cantrell serving as both members of the Investment Committee of the Rocade Funds and as officers, directors and/or

investment committee members of the Joint Venture. In addition, there are conflicts of interests associated with Mr. Roth’s former employment at EJF and current employment at the Joint Venture. Mr. Roth formerly served as Portfolio Management Senior Managing Director of EJF and as CEO and CIO of Rocade Capital LLC, a former subsidiary of EJF that previously served as manager of the Rocade Funds. Messrs. Roth and Cantrell may have incentives to take actions that benefit the Joint Venture at the expense of the Rocade Funds. Additionally, the equity interest owned by EJF and its employees in the Joint Venture may present conflicts of interests in connection with EJF’s management of the Rocade Funds. The interests of Rocade Funds might also differ from the interests of the Joint Venture. There are also conflicts related to all investments in which both the Joint Venture and the Rocade Funds participate as the Joint Venture will advance loans to borrowers or otherwise hold the applicable investments directly and issue participation interests in such investments to the Rocade Funds on the same economic terms. This poses a conflict because once the investment is made, neither the Rocade Funds nor EJF will have control over the management of the investment (including those related to restructurings, modifications, consents or exits) and the Rocade Funds will have limited if any consent rights. The Joint Venture will take such actions regarding the loans and other investments as it determines in its sole discretion, without regard for the interests of the Rocade Funds. Lastly, EJF will generally not have the ability to control the outcome of matters requiring a vote of the members or the board of managers of the Joint Venture. Data Providers and Data Management EJF receives or obtains various kinds of data and information in the course of managing Clients, or other non-Client accounts (“Other EJF Accounts”), including data and information relating to business operations and functionality, investment research, trends, budgets, customers and other metrics, some of which is sometimes referred to as “big data.” EJF may be better able to anticipate macroeconomic and other trends, and otherwise develop investment themes, as a result of its access to (and rights regarding) this data and information from the investment activities of Clients and Other EJF Accounts. Although EJF believes that these activities improve EJF’s investment management activities on behalf of the Clients and Other EJF Accounts, information obtained from the Clients and Other EJF Accounts also provides material benefits to EJF or Other EJF Accounts without compensation or other benefit accruing to the Clients or their investors. For example, information from portfolio entities owned by the Clients enables EJF to better understand a particular industry and execute trading and investment strategies in reliance on that understanding for EJF and Other EJF Accounts that do not own an interest in the portfolio company, without compensation or benefit to the Clients or their portfolio entities. Furthermore, except for contractual obligations to third parties to maintain confidentiality of certain information, and regulatory limitations on the use of material nonpublic information, EJF is generally free to use data and information from the Clients’ activities to assist in the pursuit of

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Trading EJF has a code of ethics (the “Code”) that outlines its policies regarding personal trading and various other conflicts of interest that may arise while servicing a Client’s account. Under the Code, each employee is required to certify that he or she has read the Code after the individual joins EJF and on an annual basis thereafter. The Code also requires all employees to disclose all brokerage accounts in which they have a beneficial interest (this includes accounts of immediate family members living in the same household). As a general matter, any transaction in a publicly traded or privately traded security for an EJF employee’s personal brokerage account (or an account he or she has beneficial ownership) must be pre-cleared by the Firm’s Chief Compliance Officer or her designee. Once the transaction is pre-cleared, employees may sell the relevant securities held in their personal brokerage accounts. Other transactions are permissible without pre-clearance by the Compliance Department, for example open-ended mutual funds, Treasurys, futures on Treasurys and any security where the employee has no knowledge of the transaction before it is completed can be purchased without pre-clearance. These transactions are also exempt from the 30-day restriction discussed in “Recommendations to Clients” below. Under the Firm’s Code, certain transactions are prohibited. EJF employees are prohibited from purchasing certain securities, including, but not limited to, common or preferred stock, bonds, options, and futures (other than Treasury securities futures) in

an account over which the employees have direct or indirect influence or control. Employees are also prohibited from executing short sales in their brokerage accounts. The pre-clearance process is designed to compare an employee’s proposed transaction against trades considered or executed for the Firm’s clients. By pre-clearing employee trades, EJF is attempting to prevent employees from front-running Client traded securities and causing EJF to violate its fiduciary duty to its Clients. Employees that maintain discretionary accounts managed by third parties must ensure that monthly/quarterly statements are provided to the Firm’s Compliance Department. Employees that maintain discretionary accounts are also subject to periodic certifications. All employees that maintain brokerage accounts are required to instruct their respective brokerage firms to provide EJF’s Compliance Department with duplicate brokerage account statements and trade confirmations in paper or electronic format. The Firm’s electronic pre-clearance system reviews this information to determine if an employee has violated any provision of the Code. Violations of the Code must be reported to the Chief Compliance Officer. Successive violations are subject to increasingly serious consequences, including termination of employment. A section of the Code addresses EJF’s fiduciary duties, including placing the client’s interest first and the handling of a client’s confidential information. The Code also contains a gift policy that requires all employees to record information in the Firm’s electronic database used to track gifts accepted or given to individuals or entities that are conducting business with EJF or seeking to conduct business with EJF. Employees are generally not permitted to accept or give gifts that exceed a certain dollar value. In addition, the Code requires certain employees to post information in the Firm’s electronic database when they entertain or are being entertained by individuals or entities conducting business with EJF or seeking to conduct business with EJF. The entertainment opportunities in which employees participate should not be so frequent or so expensive that it would cause one to question the integrity of EJF or the employee. The Code also describes when a normal entertainment event is classified as a gift by the Chief Compliance Officer. Finally, the Code discusses the sanctions that may be imposed if an employee fails to comply with the Code’s guidance. A non-EJF sponsored activity engaged in by an EJF employee may create a conflict of interest. All EJF employees are required to complete an outside business activity form prior to engaging in any form of outside business activity (this includes, but is not limited to, serving on the board of directors of an unaffiliated entity). Pre-authorization is required for an EJF employee to serve as an officer, director or trustee of a publicly traded or private company (other than EJF) or a nonprofit organization (including as a trustee for a family related account).

EJF maintains a restricted/watch list. The restricted/watch list is loaded into the database used by the Firm to pre-clear personal securities transactions. Securities pre-cleared by an employee are compared to the Firm’s restricted/watch list. The Code also restricts certain actions of independent investment strategy consultants, independent consultants resident in the Arlington, Virginia office and interns resident in the Arlington, Virginia office. Exceptions to the Code may be made on a limited basis with the approval of the Chief Compliance Officer. EJF will provide a copy of the Code to any SMA client, Fund investor, prospective SMA client or prospective Fund investor upon request. Such requests should be directed to Compliance@ejfcap.com or EJF Capital LP, Attention: Compliance, 2107 Wilson Boulevard, Suite 410, Arlington, VA 22201. Recommendations to Clients EJF employees are prohibited from purchasing an exchange-traded instrument that is held by a Client (a “Client Security”). If an EJF employee wishes to sell a Client Security, the employee will be subject to a 7-day blackout period if the Fund or SMA executed a trade in the same security prior to the employee’s transaction. In addition, EJF employees are prohibited from shorting securities. Employees are prohibited from purchasing a security and selling the same security within 30 days of the original purchase transaction. Additionally, employees are prohibited from selling a security and repurchasing the same security within 30 days of the original sale transaction. There are certain security transactions exempt from the pre-clearance requirement and exempt from these requirements, for example open-ended mutual funds, Treasurys, futures on Treasurys and any security where the employee has no knowledge of the transaction before it is completed can be purchased without pre-clearance. For a discussion on the Firm’s investment in the same securities as a Client, please refer to “Investment in Same Securities Recommended to Clients” below. Investment in Same Securities Recommended to Clients Qualified EJF employees are permitted to invest in Funds managed by EJF. In addition, in limited circumstances referenced below, the Firm may acquire interests in securities as a seed investment for a new client account, or to manage its balance sheet investments.

The Firm, with the approval of the Chief Compliance Officer and Co-Chief Executive Officer, may conduct securities transactions for its own account under the following conditions: Seed Investment for New Client: The Firm may acquire securities which are intended to seed a client account that is not yet established or does not yet have external investors. If the vehicle is not yet formed, such investments may be contributed to the client account, once established, and the Firm’s economic interest in the account will be diluted or replaced as external investors increase their economic interest. Balance Sheet Investments: The Firm may acquire securities to invest on its own behalf. The Firm shall seek to avoid investing in a Client Security, but may do so subject to of each of the Firm’s Co-Chief Executive Officers. In conducting all transactions for its own account, the Firm shall follow the same principles of the Code and operate at all times consistent with its fiduciary duty.

EJF has an approval process that each broker-dealer must go through before EJF’s traders are allowed to execute trades through that broker-dealer for a Client’s account. EJF conducts due diligence on broker-dealers by reviewing items such as their financial status and disciplinary history, if one exists. The Chief Compliance Officer or her designee use the services of a thirdparty vendor to obtain information relating to a broker-dealer that has been recommended for inclusion on the Firm’s Approved Broker List. EJF’s traders are responsible for negotiating commission rates charged by broker-dealers. After a broker-dealer is approved, EJF’s traders are free to place, buy, or sell transactions with the broker-dealer. On a periodic basis, EJF has a best execution committee meeting. In addition to other issues, the best execution committee meeting is designed to determine and analyze where trades are executed and the commission rates charged for the transactions. EJF has also employed the services of a third-party vendor to assist with the best execution analysis for equity securities. The vendor conducts an analysis of execution performance by broker and by security. EJF maintains an approved broker list which is generally designed to limit trading to those brokerdealers that are able to demonstrate knowledgeable sales coverage in the Firm’s area of trading, quality research, access to securities not traded by other firms, and financial responsibility. EJF maintains relationships with a number of broker-dealers including some that have affiliated entities or a department within the same entity that provide services to EJF. Examples of services provided (other than trade execution) by a broker-dealer or a broker-dealer affiliate to EJF include the following, which EJF considers in selecting broker-dealers:

The broker-dealer (that provides trade executions) or an affiliate serves as the prime broker for a Fund’s assets; The broker-dealer (that provides trade executions) or an affiliate refers prospective investors to the Funds; The broker-dealer (that provides trade executions) or an affiliate provides trade executions for Funds or SMA clients; The broker-dealer (that provides trade executions) or an affiliate provides pricing information for Funds; The broker-dealer (that provides trade executions) or an affiliate conducts underwriting or investment banking activity for EJF or its affiliates; The broker-dealer (that provides trade executions) or an affiliate provides EJF with internally generated investment research; and The broker-dealer (that provides trade executions) or an affiliate provides custodian services to Clients.

Additionally, affiliates of certain brokers-dealers on the Firm’s approved broker list may invest in the Funds. EJF’s order management system assists traders in calculating the appropriate trade allocations between multiple Clients. EJF’s staff will monitor trade allocations to determine if decisions are consistent with its policies and procedures. Best Execution EJF seeks to obtain the best available price for the orders placed by its portfolio management team. The objective is to obtain the most favorable total cost or proceeds with regard to the transaction. With regard to best execution, the lowest commission charged on a trade may not be the optimal indication of best execution. EJF is not obligated to merely get the best price or lowest commission, but should also determine whether the transaction represents the best qualitative execution for the account. Additionally, certain transactions require specific services that are not available at the lowest possible commission rates. Research and Other Soft Dollars EJF does not utilize any “soft dollar” credits, but EJF’s portfolio management teams for different Clients sometimes share investment research and have discussions regarding investment ideas and EJF occasionally produces “white papers” which are made available to certain existing and prospective Clients or Fund investors. Certain Clients pay for broker-dealer proprietary research with “hard dollars.” Other Clients from time to time benefit from that research. EJF uses brokerdealer proprietary research to assist with its investment decision-making process. To obtain

broker-dealer proprietary research, EJF pays a higher brokerage commission to execute a trade. Brokerage commissions paid to broker-dealers that do not provide investment research are generally lower than those paid to broker-dealers that do provide proprietary research. EJF could trade more through broker-dealers that provide EJF with proprietary research. By using proprietary research, EJF is receiving research that it does not have to produce internally (EJF or an affiliate may occasionally purchase proprietary research to assist with the decision-making process). This provides EJF with an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on its Clients’ interest in receiving most favorable execution. In addition, this practice creates conflict of interest between EJF’s Clients as resources and investment opportunities could be allocated disproportionately. Aside from broker-dealer proprietary research, EJF does not use its commission dollars to obtain research products and services through third-party vendors. Brokerage for Client Referrals EJF does not use its Client’s brokerage commissions to pay for client referrals. EJF’s employees, however, are occasionally offered by certain broker-dealers the option to participate in or attend conferences, provide EJF employees access to issuers’ management teams, to present non-public investment opportunities such as equity or debt raises, or make prospective investor introductions. Such introduction opportunities may assist EJF in raising capital and thus poses a potential conflict of interest. However, EJF occasionally executes trades on behalf of its Clients with broker-dealers that also receive placement agent fees from Fund investors. Such brokers are not compensated by EJF or its Clients for providing such introduction opportunities. Trade Errors The execution of trading and investment strategies at EJF often necessitates quick trade execution, high trade volumes, complex trades, and the use of negotiated terms with counterparties (particularly when dealing with derivatives or less common and novel instruments). These factors can introduce various risks. For example, due to the high volumes, intricacy, and global scope of these activities, issues such as slippage, errors, and miscommunications with brokers and counterparties may arise, potentially leading to client losses. In such instances, EJF will assess the viability of pursuing damage claims against brokers and counterparties deemed responsible, and will make efforts to recover losses where feasible. However, success in this regard is not guaranteed. Moreover, we reserve the right, at our discretion, to decide against pursuing claims on behalf of our clients, based on factors such as the cost of pursuing claims relative to the expected recovery or the desire to preserve business relationships with brokers and counterparties.

Directed Brokerage EJF may have SMAs with directed brokerage arrangements. In some circumstances, clients can designate a particular broker-dealer through which trades are to be executed, typically under such terms as the client negotiates with the particular broker-dealer. Clients may be incentivized to engage in such arrangements for various reasons such as participating in a rebate or commission recapture program. In those instances where a client directs or influences EJF to execute transactions on behalf of its account with or away from a particular broker-dealer, EJF is not in a position to negotiate commissions or select brokers-dealers based on their ability to provide best execution to such client. Under these circumstances a disparity typically exists between the commissions and execution price between clients who direct brokerage transactions and other Clients who do not instruct EJF to use a particular broker-dealer. As a result, EJF may be unable to achieve most favorable execution of client transactions. Directed brokerage transactions may disadvantage clients as EJF may place directed brokerage transactions after aggregated block transactions (see below). Accordingly, transactions for clients that direct brokerage can be subject to price movements of other Clients, which may be more acute in illiquid securities or large orders. Ultimately clients with directed brokerage arrangements can result in less favorable net prices than might be the case if EJF were able to negotiate commission rates or select brokers or dealers based on best execution. Similarly, certain SMAs where EJF acts as sub-adviser may also instruct EJF not to execute transactions on its behalf with a particular broker-dealer. Clients may desire to instruct EJF in order to avoid certain conflicts of interest that can be created by executing such transactions. By limiting EJF’s ability to execute trades with certain broker-dealers, EJF’s ability to perform its best execution duties may be diminished and potentially result in less favorable prices, which could ultimately impact performance. Wrap Program Trading Wrap fee account transactions are typically executed with the Sponsor due to the all-inclusive fee structure. The Sponsor’s ability to execute transactions is vastly different than that of brokerdealers EJF selects to execute on behalf of its other Clients. This disparity can affect timing, pricing and ultimately performance of Client accounts. Only in very limited circumstances will EJF trade away from the Sponsor, for example when the Sponsor does not have the capability to execute the transaction in a particular security or size. Commissions, and other expenses incurred in connection with any transactions executed with broker-dealers other than the Sponsor, are typically borne by the client. Therefore, it is important for clients who enroll in a Wrap Program where EJF serves as the investment adviser to satisfy

themselves that the program is suitable for them due to the additional commission incurred by them when EJF trades away from the Sponsor. When execution occurs through the Sponsor, EJF does not have the ability to negotiate commissions or other costs for the execution of transactions in the client’s account since such execution costs are included in the all-inclusive fee charged by the Sponsor. Therefore, it is essential the clients in a Wrap Program satisfy themselves that the Sponsor is able to provide best price and execution of orders. Brokerage Aggregation/Allocation Purchases and sales of securities for a Client could be aggregated or bunched when an order is placed with a broker-dealer. EJF may not bunch or aggregate orders if the portfolio management team’s decisions for different accounts are made separately, if the Firm determines that bunching or aggregating would be inconsistent with its investment management duties or with a Client’s direction, or if the orders from the portfolio management teams are not received at approximately the same time. EJF and/or its affiliates have potential conflicts of interest in connection with the allocation of investments or transaction decisions for its Clients, including situations where EJF, its affiliates, and their personnel have a financial interest. EJF and its affiliates may manage accounts that have investment objectives that are similar and/or that seek to make investments in the same securities. This creates potential conflicts of interest and potential differences among the accounts, particularly where there is limited availability or limited liquidity for those investments. EJF has developed allocation policies and procedures that describe how EJF will allocate investment opportunities in a manner it considers to be reasonable and equitable over time. EJF allocates investment opportunities based on relative size of an order, investment objectives, guidelines/restrictions, risk tolerance, availability of other investment opportunities, and available cash for investments. EJF will also take into consideration whether the client account is allowed to use leverage. Although allocating orders among accounts may create potential conflicts of interest, EJF will not make investment allocation decisions based on the allocation that generates higher fees for the Firm. EJF could determine that an investment opportunity or purchases/sales are appropriate for one or more SMA clients, but not for a particular Fund. EJF may also determine that one Fund may participate in a transaction, but based on guidelines/restrictions, cash availability, or duration of investment another Fund may not purchase a particular security. EJF could also determine that an investment is good for one Client but may be appropriate for another Client in different sizes, terms, portion of the capital structure, or at a later time. Such determinations by EJF can result in Clients having differing or even adverse positions in the same security, conflicting rights in the security, or proceeds indirectly exchanged between Client accounts. EJF is keenly aware of

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EJF occasionally enters into arrangements with unaffiliated third-party broker-dealers to promote EJF’s advisory services. If applicable, the referral agreements will address the terms and conditions described in the Investment Advisers Act under Rule 206(4)-1. Under certain referral arrangements, EJF agrees to pay the unaffiliated third-party entities cash or other compensation for endorsements or testimonials. EJF may compensate such third-parties a percentage of the management fee and or incentive fee paid to EJF by the referred Fund investor or the SMA client, a flat amount of fees or retainer over a prescribed period, reimbursement of travel and other expenses, and reduced management fee and incentive fees for their personal investments. It should be noted that a Fund investor’s account can be charged higher or lower Management and/or Performance-based fees within the Fund than if the investor came to EJF directly. EJF also enters into arrangements with unaffiliated third-party broker-dealers to assist with the placement of units of the Funds. Under these arrangements, investors referred by these brokerdealers to certain Funds are subject to a one-time upfront fee of up to 2.5% as well as an ongoing fee of up to 0.5% per annum. The upfront and ongoing placement fees are based on the assets

invested by the referred investor. Currently, only a few Funds are subject to these upfront and ongoing placement fees. Placement fees are paid by the referred Fund investor in addition to the management/performance fees. Such fees can be found on the applicable Fund’s offering memorandum, EJF’s subscription documents, as well as the investor’s statements. With regard to referred clients, EJF will comply with the applicable sections of Rule 206(4)-1 under the Investment Advisers Act, requiring such third parties provide clear and prominent disclosures to any current or prospective Client at the time of endorsement. Such disclosures should include whether or not the person giving the endorsement is an investor, if there is any cash or non-cash compensation being provided for the testimonial or endorsement, and a brief statement of any material conflicts of interests on the part of the person giving the testimonial or endorsement. EJF relies on the promoter to provide the disclosure documents (referenced above) to the Client, as described in Rule 206(4)-1. No entity or individual provides EJF with economic benefits such as sales awards or other prizes.

Approximately twenty years ago, a disciplinary action was taken against Emanuel Friedman, EJF’s Co-Chief Executive Officer, in respect of conduct that occurred more than 25 years ago. Mr. Friedman consented to disciplinary action and was barred from associating in a supervisory capacity with any broker or dealer, with the right to reapply for such association after two years to the appropriate self-regulatory organization, or if there is none, to the SEC. Mr. Friedman and EJF may be prohibited from serving as an investment adviser or sub-adviser to certain prospective clients as a result.

EJF’s Risk Committee conducts periodic reviews of security positions held by Clients. Additionally, EJF’s Director of Risk Reporting provides analysis and reports used by the Firm to monitor portfolios. The other individuals responsible for account reviews are primarily investment professionals on the portfolio management team. In addition, if an SMA client places additional investment guidelines/restrictions (or places investment guidelines/restrictions on the account for the first time), EJF will review the account to determine if/how the new investment guidelines/restrictions impact the account. Some SMA clients contract with EJF to receive customized reporting and monthly account statements. These statements include, but are not limited to, details on the securities held in the portfolio, monthly trading activity, management/incentive fee calculations, and performance information. Unlike Fund clients, SMA clients do not receive audited financial statements on an annual basis. Investors in EJF Funds receive audited financial statements on an annual basis, unaudited financial statements on a quarterly basis and some receive monthly account statements or other customized reporting materials . Such monthly account statements and materials include the same information described above.

Neither EJF nor its affiliates provide custodial services to Clients. Client assets may be held with several different qualified custodians including unaffiliated broker-dealers, savings associations, banks and registered futures commission merchants. With regard to the Funds, EJF or an affiliated entity serves as the general partner of limited partnerships or the managing member of limited liability companies. Under Rule 206(4)-2 (the “Custody Rule”), an investment adviser that operates as a general partner or a managing member for a pooled investment vehicle is deemed to have custody. The Custody Rule provides an exemption for investment advisers that have custody of their clients’ assets because they or an affiliate operate as a general partner or a managing member of a Fund. The Custody Rule allows an investment adviser to deliver audited financial statements to investors in limited partnerships and limited liability companies within 120 days of a fund’s fiscal year end. EJF is not required to comply with certain provisions of the Custody Rule (including the requirement to send quarterly brokerage statements to Fund investors) with regard to the Funds, because it provides audited financial statements to Fund investors within 120 days of the Funds’ fiscal year end. The audited financial statements for the Funds are prepared by more than one public accounting firm. EJF does not have custody of SMA clients’ funds or securities. SMA clients’ assets are held by qualified custodians such as banks and registered broker-dealers, with whom the SMA client establishes and maintains a custodial relationship. When SMA clients receive statements from their custodians, such statements should be reviewed carefully and compared to monthly performance reports provided by EJF, if applicable. EJF does not have control over the SMAs in which EJF acts as sub-investment adviser or other client assets held by unaffiliated custodians.

EJF does not deduct its management or performance fees directly from SMA client custodian accounts.

EJF manages its Funds and certain of its SMA clients’ assets on a discretionary basis. With regard to the Funds, EJF observes the investment guidelines/restrictions placed on the management of the Funds in the offering documents, limited partnership agreements, or investment management agreements if applicable. With regard to SMA clients for which EJF exercises investment discretion, EJF enters into an investment management agreement with the client (“Discretionary SMAs”), which authorizes EJF to exercise investment discretion with respect to the SMA. The investment management agreement must be signed before EJF exercises investment discretion with regard to the client’s assets. Clients with Discretionary SMAs have the ability to place investment guidelines/restrictions on the management of their account. The most common investment guidelines/restrictions are those which prohibit EJF from purchasing specific securities or specific types of securities. EJF employees periodically have conversations with SMA clients to review the SMA and its investment guidelines/restrictions. In the case of SMAs where EJF acts as a sub-adviser, each Client account will execute an investment management agreement with its investment adviser, who then delegates such authority to EJF pursuant to a written agreement. EJF shall retain discretion over such sub-advised accounts, and each Client will have the ability to place reasonable restrictions on their account.

EJF portfolio management team votes client proxies in the best interest of clients and in a manner that the Firm believes will benefit the economic value of a client’s security holdings. EJF has been granted authorization to vote certain Clients’ proxies when received from the issuer’s delivery agent. EJF’s policies and procedures outline the general guidelines for voting client proxy statements. However, EJF could vote a proxy in a manner different from the established guidelines if circumstances warrant. For example, EJF might not vote with management’s recommendation in the case of a proxy fight or a merger. EJF and its employees have a fiduciary duty to their clients to act in their best interest. EJF employees should therefore avoid conflicts of interest if possible. Persons involved with voting proxies should avoid discussing the proxy vote with anyone who has conflicting interests to those of the Client (e.g., management personnel of the issuer, EJF affiliates with conflicting interests, etc.). If any EJF employee determines that a material conflict of interest exists with respect to the

voting of proxies, such employee shall inform the Compliance Department, and a member of the Compliance Department will implement an appropriate course of action to minimize the influence of any conflict. In the event that EJF votes a proxy for a security in which it has a conflict of interest, it will generally vote in accordance with its pre-established guidelines. Fund investors cannot direct EJF’s proxy votes. SMA investors either retain the vote or if the voting is by proxy, the SMA will vote in accordance with EJF proxy voting policies. Upon request, EJF will provide a copy of its proxy voting policies and procedures as well as information on how a particular proxy was voted. Investors should direct requests for information concerning EJF’s proxy voting policies and procedures to Compliance@ejfcap.com or EJF Capital LP, Attention: Compliance 2107 Wilson Boulevard, Suite 410, Arlington, VA, 22201.

Certain registered investment advisers are required to provide financial information to clients if they require or solicit prepayment of more than $1,200 in fees per client six months or more in advance. EJF does not collect fees six months or more in advance and as a result, is not required to provide its financial information to SMA clients or Fund investors. EJF is not aware of any financial condition that is likely to impair its ability to meet its commitments to its clients. EJF has never been the subject of a bankruptcy petition.