Hildene Capital Management, LLC

The Firm and Relying Advisers Hildene Capital Management, LLC, a Delaware limited liability company (“HCM”), was founded by Brett Jefferson in January 2008 to take advantage of opportunities in the stressed/distressed structured finance market. HCM is a wholly-owned subsidiary of Hildene Holding Company, LLC (“HoldCo”). In turn, HoldCo is principally owned by Mr. Jefferson and related estate planning vehicles (the “Jefferson Entities”). HCM has offices in Stamford, CT and Durham, NC. Neither HoldCo nor HCM is publicly owned or traded. On December 8, 2025, it was announced that Jefferies Financial Group Inc. (“Jefferies”) will acquire, through its wholly-owned subsidiary, Leucadia Asset Management Holdings LLC, a 50% interest in HoldCo. The commitment was coincident with certain affiliated entities of HoldCo signing a definitive agreement to acquire SILAC, Inc., the parent company of SILAC Insurance Company, a provider of fixed indexed annuities. Jefferies entered into a strategic relationship with Hildene in 2022, as a result of which Jefferies already owns a revenue share in HCM’s asset-management business. Jefferies will exchange its existing revenue share; a portion of its interest in a Hildene-managed private fund; and $340 million in cash for a 50% interest in HoldCo. Certain of HCM’s principals will contribute their current ownership in HCM plus approximately $250 million of fund and related equity interests to HoldCo, and will own the remaining 50% of HoldCo. Subject to customary closing conditions, including receipt of required regulatory and client approvals, these transactions are expected to close in the second quarter of 2026. Hildene Collateral Management Company, LLC (“HCMC I”), a Delaware limited liability company, was founded in December 2016 to provide portfolio and collateral management services to certain issuers of collateralized debt obligations. HCMC II, LLC (“HCMC II”), a Delaware limited liability company, was founded in October 2018 to provide portfolio and collateral management services to certain issuers of collateralized debt obligations. HCMC III, LLC (“HCMC III”), a Delaware limited liability company, was founded in December 2019 to provide portfolio and collateral management services to certain issuers of collateralized debt obligations. Taberna European Capital Management, LLC, (“Taberna Europe” and, together with HCMC I, HCMC II and HCMC III collectively, “HCMC”), a Delaware limited liability company, was purchased by HCMC Holding Company, LLC (“HCMC HoldCo”) in February 2025, and provides portfolio and collateral management services to certain issuers of collateralized debt obligations. HCMC I, HCMC II, HCMC III and Taberna Europe are each a wholly-owned subsidiary of HCMC HoldCo. Prior to January 2025, HCMC HoldCo was majority beneficially owned by the Jefferson Entities. Effective as of January 2025, HCMC HoldCo and its subsidiaries are wholly-owned direct and indirect subsidiaries of Hildene Re Holdings, LLC, Series 1 (“Hildene Re Holdings”). Hildene Re Holdings is majority owned by Hildene Insurance Holdings, LLC (“HIH”), a private fund managed by HCM as discussed further below. The remaining interests in Hildene Re Holdings are owned by Hildene Re Management Holdings, LLC, a Delaware limited liability company and an affiliated company of HCM. HCMC HoldCo is indirectly owned by HCM clients and employees. None of HCMC HoldCo, HCMC I, HCMC II, HCMC III nor Taberna Europe are publicly owned or traded. Hildene Structured Advisors, LLC (“HSA”), a Delaware limited liability company, was founded in October 2017 to provide portfolio and collateral management services primarily to new issue collateralized debt obligations sponsored by HSA. HSA is a wholly-owned subsidiary of HoldCo, and is not publicly owned or traded.

Each of HCMC I, HCMC II, HCMC III, Taberna Europe and HSA are included in Form ADV, Schedule R, as relying advisers, and are referred to individually herein as a “CM Affiliate” and collectively herein as “CM Affiliates.” Compensation received by each CM Affiliate is retained by such CM Affiliate and is ultimately retained by the clients and employees that own such CM Affiliate. Types of Advisory Services HCM provides continuous investment management services on a fully discretionary basis to a diverse array of clients, including institutions and pooled investment vehicles and in limited circumstances, nondiscretionary investment management services. Services provided are consistent with each client’s investment guidelines as noted in the applicable investment management agreement and/or offering documents. HCM primarily provides advice with respect to structured finance opportunities such as collateralized debt obligations (“CDOs”), collateralized loan obligations (“CLOs”), residential mortgage-backed securities (“RMBS”), and other types of debt securities or debt obligations backed by the payments from pools of fixed income instruments. HCM also advises clients on other types of fixed income and equity securities, including, without limitation, trust preferred securities issued by bank and insurance holding companies and real estate investment trusts, high yield bonds, syndicated bank loans, mortgage loans, common and preferred equity of various issuers, consumer loans, multifamily loans and other types of investments. HCM specializes in complex financial instruments and uncovering overlooked long-term value opportunities within inefficient markets. With a disciplined, systematic approach, HCM seeks to achieve high risk-adjusted returns through calculated investments at deeply discounted fundamental values in dislocated markets. Structured finance investments and other types of investments that HCM advises on can be complex, opaque and require specialized expertise to analyze. HCM provides its investment management services through a variety of vehicles, including private funds and separate accounts. A description of the advisory services HCM provides in respect of these vehicles is as follows. Private Funds Hildene Opportunities Master Fund, Ltd. (“HOF”) HOF was launched in May 2008 for the purpose of investing and trading primarily in structured finance securities including collateralized debt obligations, collateralized loan obligations, mortgage-backed securities, asset-backed securities, bank debt, special situations, high-yield bonds and special situation equity securities. HOF is part of a “master-feeder” fund structure comprised of investments by three feeder funds, Hildene Opportunities Fund, LP, a Delaware limited partnership established for U.S. taxable investors, Hildene Opportunities Offshore Fund, Ltd., a Cayman Islands-based corporation established for non-U.S investors and U.S. tax-exempt investors, and Hildene Opportunities Rated Feeder Fund, LP, a Delaware limited partnership established for U.S. based insurance company investors. HOF’s investment objective is to achieve absolute risk-adjusted returns over an extended period of time with a minimum correlation to the broadly-based stock and bond indices. HOF invests (directly and indirectly) primarily in CDOs backed by trust-preferred securities (“TruPS”) issued by small and regional financial institutions in the United States (including CDOs managed by affiliates of HCM).

HOF invests in securities that are complex and illiquid, and leverage is used in an effort to enhance returns. Hildene Opportunities Master Fund II, Ltd. (“HOF II”) HOF II was launched in August 2011 for the purpose of investing and trading primarily in credit-related opportunities including small and medium-sized corporate credits, single name credits, CLOs, seasoned residential mortgage-backed securities, asset-backed securities, bank debt, special situations, high-yield bonds, seasoned ABS CDOs, CRE CDOs, TruPS CDOs and other structured credit investments (including CDOs managed by affiliates of HCM). HOF II is part of a “master-feeder” fund structure comprised of investments by two feeder funds, Hildene Opportunities Fund II, LP, a Delaware limited partnership established for U.S. taxable investors, and Hildene Opportunities Offshore Fund II, Ltd., a Cayman Islandsbased corporation established for non-U.S investors and U.S. tax-exempt investors. HOF II’s investment objective is to achieve absolute risk-adjusted returns over an extended period of time with a minimum correlation to the broadly-based stock and bond indices. To do this, HOF II primarily invests in credit-based securities, applying a thorough and multi-faceted fundamental valuation of the underlying structure. This entails an in-depth analysis of the legal components, a detailed analysis of the underlying cash flows and a thorough understanding of the overall credit risk of the underlying investment. HOF II invests in securities that are complex and illiquid, and leverage is used in an effort to enhance returns. Hildene Insurance Holdings, LLC (“HIH”) In August 2022, Hildene established Hildene Re SPC, Ltd. (previously known as Ludlow Re SPC, Ltd.), a Class B-III licensed insurance company domiciled in the Cayman Islands (“Hildene Re”). Hildene Re is wholly owned by Hildene Re Holdings. Hildene Re has entered into reinsurance contracts to reinsure fixed index annuities through quota share agreements with two U.S.-based insurance companies. Hildene launched HIH in July 2024 to: (i) acquire a majority interest in Hildene Re Holdings and Hildene Re, which were formerly owned by other Hildene-managed accounts as well as principals and employees of Hildene, (ii) make strategic investments in insurance companies and (iii) invest in assets or origination platforms that are a fit for Hildene Re’s regulatory portfolio requirements. Hildene expects Hildene Re to continue to enter into additional reinsurance transactions in the future. Hildene Private Credit Fund I, LP (“HPCF”) HPCF was launched in January 2022, held its first close in November 2022 and its final close in April 2024. The fund was formed for the purpose of investing and trading primarily in residential, multifamily and consumer/specialty assets through the formation of unique, exclusive or limited access strategic relationships with operating partners that are actively involved in the origination, sourcing, monitoring, servicing or securitizing of residential, multifamily and consumer loans. HPCF’s investment objective is to achieve absolute risk-adjusted returns with low correlation to traditional fixed income and equity benchmarks through a combination of current income and capital appreciation.

Hildene Private Credit Rated Feeder Fund I, LP (“HPCF Rated Fund”) was formed in September 2023 and invests all of its investable assets in limited partner interests of HPCF. HPCF invests in securities that are complex and illiquid, and leverage is used in an effort to enhance returns. Hildene Asset Based Credit Fund II (“HABC II”) HABC II was formed in October 2024 and held its first close in August 2025. The fund was formed for the purpose of investing and trading primarily in residential, multifamily and potentially consumer/specialty assets through the formation of unique, exclusive or limited access strategic relationships with operating partners that are actively involved in the origination, sourcing, monitoring, servicing or securitizing of residential, multifamily and consumer loans. HABC II’s investment objective is to generate superior riskadjusted returns primarily by investing in housing, consumer or other asset-backed credit instruments, which may include, but are not limited to, acquiring or originating housing-related loans or other financing transactions relating to the acquisition, construction or improvement of real estate. HABC II is part of a dual “master-feeder” fund structure comprised of investments by two feeder funds, Hildene Asset Based Credit Fund II, LP (“HABC II Onshore”), a Delaware limited partnership established for U.S. taxable investors, and Hildene Asset Based Credit Offshore Fund II, LP a Cayman Islands-based exempted limited partnership for non-U.S investors and U.S. tax-exempt investors. Hildene Asset Based Credit Rated Feeder Fund II, LP (“HABC II Rated Fund”) was formed in July 2025 and invests all of its investable assets in limited partner interests of HABC II Onshore. HABC II invests in securities that are complex and illiquid, and leverage is used in an effort to enhance returns. HCM 2021-1, LLC In January 2021, Hildene launched HCM 2021-1, LLC (“HCM 2021-1”), a co-investment vehicle established to acquire multifamily credit investments, predominantly "B-pieces" backed by Freddie Mac loans. Hildene TruPS Co-Invest Fund, LP (“TruPS Co-Invest Fund”) In October 2022, Hildene launched the TruPS Co-Invest Fund for the purpose of investing in certain TruPS CDOs. Bryant Park & Orchard Park Credit Funds Bryant Park Credit Fund I, LP (previously known as Hildene Rated Credit Fund I, LP) and Bryant Park Credit Fund II, LP (previously known as Hildene Rated Credit Fund II, LP) were formed in September 2022, Bryant Park Credit Fund III, LP (previously known as Hildene Rated Credit Fund III, LP) was formed in May 2023 and Bryant Park Credit Fund IV, LP was formed in December 2023. Bryant Park Credit Fund I, LP, Bryant Park Credit Fund II, LP, Bryant Park Credit Fund III, LP and Bryant Park Credit Fund IV, LP are collectively referred to herein as the “Bryant Park Credit Funds.” The Bryant Park Credit Funds’ investment objective is to generate superior risk-adjusted returns primarily by investing in TruPS, including both TruPS CDOs and single name TruPS.

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HCM generally charges a management fee to clients, which is based on a percentage of assets the client has supervised by HCM. The standard management fees charged to clients range from 0.5% per annum to 2% per annum. Management fees are generally deducted from the assets managed by HCM on behalf of a client on a quarterly basis, in advance; provided that certain separately managed account clients pay management fees on a less frequent basis and/or in arrears. Management fees are negotiable depending on the size of the client’s investment and/or the client’s investment strategy. Certain clients may not be charged a management fee, and HCM may also elect to waive any management fees payable by any investor or client or may elect to rebate management fees received to a client. Management fees are typically non-refundable once paid, though Hildene may negotiate with a client to refund a pro rata portion of management fees paid in advance in respect of certain separately managed accounts in the event such account is terminated during the applicable fee period. As discussed in Item 6, HCM also typically receives an incentive fee or allocation based on the performance of each account for which it provides investment management services, subject to a high-water mark or preferred return, including to certain clients that do not pay a management fee. HCMC receives base collateral management fees equal to between 0.03% to 0.25% per annum of the collateral balance of each CDO it manages. However, some portions of HCMC’s fees may be payable only after certain levels of payments have been made to the holders of securities issued by the CDO. In addition, HCMC may receive a subordinated collateral management fee of between 0.10% and 0.20% per annum of the collateral balance of the CDO, including any previously accrued but unpaid subordinated collateral management fees, and may also receive performance fees as discussed in Item 6 below. All fees attributable to the HCMC CDOs are paid quarterly (or, for some Trapeza CDOs, biannually) to HCMC by an independent trustee for the CDO in accordance with the terms of the applicable indenture. Management fees attributable to the HCMC CDOs are calculated by the trustee and confirmed by HCMC. HCMC does not require the CDOs to pay fees in advance. Prior to March 19, 2026, HSA waived all base or subordinated collateral management fees in connection with securitization transactions for which it served as collateral manager or collateral servicer. HSA has since implemented changes to its fee practices and now receives collateral management and/or related fees with respect to certain HSA CDOs to the extent that the investments in such HSA CDOs are not managed by Hildene, as provided in the applicable governing documents. In connection with these changes, investors for which HSA was previously waiving fees, including but not limited to accounts in which Hildene principals, employees, or affiliates have an ownership or economic interest, may receive rebates, offsets, or other reductions of such fees. Beginning March 19, 2026, with respect to the HITR CDOs and HCOMF, HSA receives subordinated collateral management fees equal to 0.30% per annum of the collateral balance of the CDO, including any previously accrued but unpaid subordinated collateral management fees, and may also receive performance fees as discussed in Item 6 below. All fees attributable to the HSA CDOs are paid quarterly to HSA by an independent trustee for the CDO in accordance with the terms of the applicable indenture. Management fees attributable to the HSA CDOs are calculated by the trustee and confirmed by HSA. HSA does not require the CDOs to pay fees in advance.

Neither HCM nor any of its relying advisers or supervised persons accept compensation for the sale of securities or other investment products. Other than management fees and the incentive fees discussed above and in Item 6 below, neither HCM nor its relying advisers receive any additional fees from clients for its services. In addition to management fees and incentive fees, funds and separate accounts managed by HCM and its relying advisers incur certain fees and expenses in connection with the provision of investment advisory services. As provided in a client’s account documents, clients may bear expenses such as administrator fees, custodian/settlement agent fees, insurance, research, organizational expenses, accounting/audit fees, taxes, legal fees and transaction costs. Expenses incurred by a client are generally paid directly by the client, but Hildene may pay the expenses directly and seek reimbursement from the applicable client. Certain costs and expenses may be incurred for the benefit of, or be shared by, multiple clients, including clients which are not eligible to bear such costs and expenses. Such shared expenses generally will be allocated across the applicable clients on a pro rata basis based on relative assets under management or in such other manner as Hildene deems appropriate. Hildene will bear the portion of such shared costs and expenses otherwise allocable to clients who benefit from, but are not eligible to pay, such shared costs and expenses. From time to time, entities affiliated with HCM (each, an “Affiliated Entity”) may provide services (“Affiliate Services”) to, and in turn, receive compensation for such Affiliate Services from, an HCM client. In addition, from time to time, HCM may provide services to a client or share its personnel and/or facilities in a manner that is outside the scope of its investment management duties (“Shared Services”), and receive compensation for such Shared Services from such client, which compensation shall be in addition to its investment management fee. Affiliate Services and Shared Services may include providing consulting, actuarial, financial and other services to HCM clients and/or its clients’ portfolio companies. For more information, please see “Affiliate and Shared Services” in Item 10 below. Additional information on fees and expenses can be found in the applicable account governing document. See Item 12 Brokerage Practices, for a description of transaction costs borne by clients and client accounts.

Methods of Analysis and Investment Strategy HCM primarily provides advice regarding structured finance opportunities, including CDOs, CLOs, RMBS, and other types of debt securities backed by the payments from pools of fixed income instruments. HCM also advises clients on other types of fixed income and equity securities, including, without limitation, trust preferred securities issued by bank and insurance holding companies and real estate investment trusts, high yield bonds, syndicated bank loans, mortgage loans, common and preferred equity of various issuers, consumer loans and other types of investments. HCM’s investment ideas are generated from a wide variety of sources. HCM uses a bottom-up approach that analyzes investment opportunities from a fundamental and technical perspective, evaluating innate structural value, net asset value, liquidation value and other fundamental and technical factors. Using this approach, HCM purchases instruments and securities that it believes are mispriced because of either their complexity or a technical component in the marketplace. Ultimate value is achieved through a long-term view that focuses on the general realization of value in the underlying assets. HCM believes that performance is best achieved when understanding all the macroeconomic components of the overall market and dissecting microeconomic drivers that define a structure or company. HCM typically gathers information about an investment from a number of sources including, but not limited to, trustee reports, licensed and proprietary software, issuers, customers, vendors, suppliers, competitors, consultants, advisors, dealers and industry executives. Through these channels of communication, HCM is often alerted to relevant news, nuances and information that may enhance the effectiveness of its investment analysis. HCM also gathers information from public filings (10-K's, 10-Q's, 8-K's, 13-G's, etc.), trade and financial publications, publication search engines, yield rankings, valuation screens, corporate action calendars, investment conferences and other available information sources. HCM’s due diligence is founded on an in-depth knowledge of underlying structural nuances. A thorough analysis of the expected result based on financial engineering and an overall understanding of the terminal value and risks of the underlying credits of a specific company are utilized in decision-making. HCMC monitors the portfolio investments of the HCMC CDOs to evaluate their performance. However, because the reinvestment period has ended with respect to each of the HCMC CDOs, HCMC is not actively making new portfolio investments on behalf of the HCMC CDOs. In monitoring portfolio investments with respect to the HCMC CDOs, HCMC analysts review a variety of sources for information including, but not limited to, financial newspapers and magazines; inspections of and meetings with portfolio companies; third party research materials; corporate rating services; company press releases; and corporate regulatory filings. For new issue CDOs, HSA has discretionary authority over each HSA CDO’s assets during the presecuritization warehouse period and is responsible for the selection of any securities to be acquired and held in each of the warehouses. Post-securitization, HSA monitors the portfolio investments of the HSA CDOs to evaluate their performance. However, because the new issue HSA CDOs are comprised of static portfolios, HSA does not make new portfolio investments on behalf of the HSA CDOs after securitization.

For Insurance-Wrapped Vehicles, HSA has discretionary authority over the investment and reinvestment of assets held in an Insurance-Wrapped Vehicle’s premium reserve accounts in connection with certain structured finance transactions. Such discretion is exercised subject to the terms of the applicable transaction documents. In monitoring portfolio investments with respect to the HSA CDOs, HSA analysts review a variety of sources for information including, but not limited to, financial newspapers and magazines; inspections of and meetings with portfolio companies; third party research materials; corporate rating services; company press releases; and corporate regulatory filings. Summary of Material Risks Hildene invests in securities that are complex and may be distressed. Prices of securities react to the business and financial condition of the issuer as well as macro-economic factors. Investing in any security entails risk of loss, particularly when the securities are complex or distressed. Hildene has listed certain risks below; however the list of risks is not comprehensive or complete. Clients are strongly advised to review the risk factors and potential conflicts of interest contained in the relevant offering materials, organizational documents and/or investment management agreements relating to their investments with Hildene. The investment strategies that Hildene employs for its clients entail various risks, including, but not limited to, the following:

General Investment Risk. All investments involve risks, including the risk that the entire amount invested may be lost. There can be no assurance that HCM will be able to obtain the expected financial terms on its targeted investments. In addition, there can be no assurance that HCM will be able to generate returns or that the returns will be commensurate with the risks of investing in the type of companies and transactions that HCM will engage in.

Structured Finance Securities. The investment strategies employed by Hildene involve investing and trading in structured finance products. Investing in structured finance securities entails a variety of unique risks. In addition, the performance of a structured finance security will be affected by a variety of factors, including its priority in the capital structure of the issuer thereof, the availability of any credit enhancement, the level and timing of payments and recoveries on and the characteristics of the underlying receivables, loans or other assets that are being securitized, remoteness of those assets from the originator or transferor, the adequacy of and ability to realize upon any related collateral and the capability of the servicer of the securitized assets.

Distressed Securities. The investment strategies employed by Hildene may involve investing in distressed securities or underperforming or non-performing debt. Distressed debt securities are subject to the significant risk of an issuer’s inability to meet principal and interest payments on the obligations (credit risk) and also may be subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (market risk). Distressed securities may react to developments affecting market and credit risk to a greater extent than non-distressed securities. In addition, certain types of distressed securities involve bankruptcy risks, including with respect to securities purchased after an issuer emerges from a bankruptcy reorganization. With respect to post-reorganization securities, such securities typically entail a higher degree of risk than investments in securities of companies which

have not undergone a reorganization or restructuring. Moreover, post-reorganization securities can be subject to increased selling or downward pricing pressure after the completion of a bankruptcy reorganization or restructuring. If Hildene’s evaluation of the anticipated outcome of an investment situation should prove incorrect, clients holding such investment could experience a loss.

Financial Institution Risk. Clients are subject to the risk that one of the client’s account’s banks, brokers, hedging counterparties, lenders or other custodians of some or all of the account’s assets (each, a “Financial Institution”) fails to perform its obligations or experiences insolvency, closure, receivership or other financial distress or difficulty (each, a “Distress Event”). Distress Events can be caused by factors including, but not limited to, eroding market sentiment, significant withdrawals, fraud, malfeasance, poor performance or accounting irregularities. In the event a Financial Institution experiences a Distress Event, Hildene and/or its accounts may not be able to access deposits, borrowing facilities or other services for an extended period of time or ever. Although assets held by regulated Financial Institutions in the United States frequently are insured up to stated balance amounts by organizations such as the Federal Deposit Insurance Corporation (“FDIC”), in the case of banks, or the Securities Investor Protection Corporation (“SIPC”), in the case of certain broker-dealers, amounts in excess of the relevant insurance are subject to risk of loss, and any non-U.S. Financial Institutions that are not subject to similar regimes pose increased risk of loss. Although in recent events governmental intervention has resulted in additional protections for depositors, there can be no assurance that governmental intervention will be successful or avoid the risk of loss, substantial delays or negative impact on banking or brokerage conditions or markets. A Distress Event may have a potentially adverse effect on the ability of Hildene to manage client accounts and their investments, and on the ability of Hildene and/or its clients to maintain operations, which in each case could result in significant losses and unconsummated investment acquisitions and dispositions. Such losses have the potential to include fees and expenses incurred by a client in the event the client is not able to close a transaction (whether due to the inability to draw capital on a credit line provided by a Financial Institution experiencing a Distress Event, the inability of investors to make capital contributions or otherwise), as well as the inability of a client to acquire or dispose of investments at prices believed to reflect the fair value of such investments. Although Hildene expects to exercise contractual remedies under the agreements with Financial Institutions in the event of a Distress Event, there can be no assurance that such remedies will be successful or avoid losses or delays. Although Hildene seeks to do business with Financial Institutions that it believes are creditworthy and capable of fulfilling their respective obligations to clients, Hildene is under no obligation to use a minimum number of Financial Institutions with respect to any client, or to maintain account balances at or below the relevant insured amounts.

Concentration of Investments. The investment strategies employed by Hildene may be concentrated and may involve investing in a small number of investments. The allocation of a large portion of an account’s capital to one or a small number of investments could increase the risk of investing in the account because of the lack of diversification in its portfolio. The concentration of an account’s portfolio in any one issuer, industry or strategy would subject such account to a greater degree of risk with respect to the failure of one or a few issuers or with respect to economic downturns in relation to such industry. Certain clients accounts are concentrated in CDOs backed by TruPS

issued by small and regional banks and insurance companies. The issuers of these TruPS operate within a sector of the economy which has recently been, and may continue to be, subject to significant stress.

Leverage. Hildene uses leverage in connection with the investment strategies employed for certain clients, including the use of borrowed funds and investments in certain types of options. Hildene may also employ leverage through the use of total return swaps or credit default swaps, or through repurchase transactions. While such strategies and techniques increase the opportunity to achieve higher returns on the amounts invested, they also increase the risk of loss. To the extent a client purchases securities with borrowed funds, its net assets will tend to increase or decrease at a greater rate than if borrowed funds are not used. The level of interest rates generally, and the rates at which such funds may be borrowed in particular, could affect the performance of a client’s account. If the interest expense on borrowings were to exceed the net return on the portfolio securities purchased with borrowed funds, the use of leverage would result in a lower rate of return than if the applicable account were not leveraged.

Limited Liquidity. The investment strategies employed by Hildene may involve investing in assets that are illiquid or have limited liquidity. At times, Hildene may be unable to realize certain of its illiquid investments, or would only be able to realize such investments at a value determined by Hildene to be a discount to their true value. If an investment is thinly traded or is not traded at all, Hildene could have difficulty unwinding the investment at a desirable price. If invested in illiquid assets, a client’s account might suffer significant losses if forced to unwind an illiquid investment as a result of changing market conditions, margin calls or other factors.

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HCM offers discretionary investment management services to private funds and separate accounts. Investors are generally institutional clients, such as financial institutions, insurance companies, pension funds, corporations and other business entities, as well as family offices, endowments, trusts and high net worth individuals through private funds. HCM generally requires a minimum investment of $1,000,000 from investors in its private funds and a minimum investment of $50,000,000 from separate account clients. From time to time, investments less than these amounts are accepted by HCM from “friends and family” and other investors and clients, as determined by HCM in its discretion. Prospective investors should refer to the appropriate fund offering documents or separate account advisory contract, as the case may be, for additional qualification requirements for investment. HCMC provides portfolio and collateral management services to the HCMC CDOs. Certain private funds and separate accounts managed by HCM are also investors in the HCMC CDOs managed by HCMC. HSA provides portfolio and collateral management services to the HSA CDOs. Certain private funds and separate accounts managed by HCM are also investors in the HSA CDOs managed by HSA.

HCM receives an incentive fee or allocation based on the performance of each account for which it provides investment management services. This performance-based payment is payable either directly to HCM or to an affiliate of HCM. The standard incentive payment for clients ranges from 15% to 20% per annum, subject to a high-water mark or preferred return. Incentive fees are negotiable depending on the size of the client’s investment. HCM seeks to align its incentive fees with investors and has committed with certain investors to classify certain amounts of incentives as unearned redemption payments that are not earned or payable until capital is withdrawn or redeemed by the investor. Each client paying an incentive fee to HCM must qualify as a “qualified client” under Rule 205-3 promulgated under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Earned incentive payments are deducted from a client’s assets at the end of each year and/or upon each withdrawal of capital by a client, and, in the case of private funds managed by HCM, are typically treated as an allocation by such fund to HCM or its affiliates. HCM may manage its own accounts or the accounts of an affiliate of HCM (an “Affiliated Account”) alongside client accounts on a side-by-side basis. Affiliated Accounts and client accounts may have similar investment objectives, investment guidelines and investment limitations, and certain investment opportunities considered by HCM may be suitable for both clients and Affiliated Accounts. In such circumstances, in accordance with HCM’s trade allocation policy, HCM shall first allocate such opportunities to HCM’s clients for whom allocation would be appropriate, in such amounts as may be appropriate, prior to allocating such opportunities to any Affiliated Accounts. In any circumstance involving the side-by-side management of client accounts and Affiliated Accounts, HCM shall always put client accounts first. HCM has adopted the foregoing policy to ensure the fair and equitable allocation of investment opportunities among clients and Affiliated Accounts. HCM also manages client accounts (including private funds and separately managed accounts) on a sideby-side basis. For more information, please see “Allocation of Trades” in Item 12 below. HCMC charges a performance fee of between .15% and .25% per annum to certain of the Trapeza CDOs and Alesco CDOs it manages, as set forth in the applicable indenture and collateral management agreement. The performance fee is payable when the equity class of securities of the CDO has achieved a specified return on investment. Prior to March 19, 2026, HSA waived all performance fees in connection with securitization transactions for which it served as collateral manager or collateral servicer. HSA has since implemented changes to its fee practices and now receives collateral management and/or related fees with respect to certain HSA CDOs to the extent that the investments in such HSA CDOs are not managed by Hildene, as provided in the applicable governing documents. In connection with these changes, investors for which HSA was previously waiving fees, including but not limited to accounts in which Hildene principals, employees, or affiliates have an ownership or economic interest, may receive rebates, offsets, or other reductions of such fees. In addition, HSA may earn an incentive management fee with respect to the HITR CDOs and HCOMF, as set forth in the applicable indenture and collateral management agreement. The incentive management fee is performance‑based and is payable only to the extent that the equity or subordinated tranche of the

securitization achieves specified return thresholds. HSA does not currently charge any fees in respect of the services it provides to any of the other HSA CDOs. HSA may in the future charge a management fee and/or an incentive fee in respect of such CDOs for which it provides collateral management services.

Other Financial Industry Affiliations Neither HCM, HCMC, HSA nor any of their respective management persons has registered as, or currently has a pending application to register as, a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor or an associated person of any of the foregoing entities. Hildene may evaluate from time to time whether to expand its business lines or affiliate structure, including through the potential formation or acquisition of regulated entities. Any such expansion would be subject to applicable regulatory approvals and appropriate client disclosure. Hildene Advisors, LLC (“HADV”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of certain feeder funds of HOF and HOF II and TruPS Co-Invest Fund; Hildene Private Credit Fund I GP, LLC (“HPCFGP”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of HPCF and HPCF Rated Fund; Hildene Asset Based Credit Fund II GP, LLC (“HABCGP II”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of HABC II and HABC II Rated Fund, Bryant Park Credit Fund I GP, LLC (“BPCFGP I”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of Bryant Park Credit Fund I, LP; Bryant Park Credit Fund II GP, LLC (“BPCFGP II”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of Bryant Park Credit Fund II, LP; Bryant Park Credit Fund III GP, LLC (“BPCFGP III”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of Bryant Park Credit Fund III, LP; Bryant Park Credit Fund IV GP, LLC (“BPCFGP IV”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of Bryant Park Credit Fund IV, LP; Orchard Park Credit Fund I GP, LLC (“OPCFGP I”), a Delaware limited liability company and an affiliate of HCM, serves as the general partner of Orchard Park Credit Fund I, LP; and Hildene Trapeza Manager, Inc. (“HTMI”), a Delaware corporation and an affiliate of HCMC I, serves as the manager of certain Trapeza CDOs for which HCMC I serves as collateral manager. Each of HCMC I, HCMC II, HCMC III, Taberna Europe and HSA is currently registered with the SEC as a relying adviser of HCM. None of HADV, HPCFGP, HABCGP II, BPCFGP I, BPCFGP II, BPCFGP III, BPCFGP IV, OPCFGP I or HTMI is registered or licensed in any capacity with any regulatory body, nor do they conduct any activities other than serving as the general partner or manager, as the case may be, of certain private funds and CDOs managed by HCM and HCMC, respectively. In August 2022, HCM created and received regulatory approval for a Cayman Islands-domiciled Class BIII insurance company named Hildene Re SPC, Ltd. HCM, HCMC and HSA do not have any other financial industry affiliations material to its advisory business. HCM, HCMC and HSA do not recommend other investment advisers to clients or receive any compensation from other investment advisers. Certain private funds managed by HCM and certain CDOs managed by HCMC and/or HSA may have common investors. Affiliate and Shared Services From time to time, Affiliated Entities may provide Affiliate Services to, and in turn, receive compensation for such Affiliate Services from, an HCM client. In addition, from time to time, HCM may provide Shared

Services to, and in turn, receive compensation for such Shared Services from, a client, which compensation shall be in addition to its investment management fee. Affiliate Services and Shared Services may include providing consulting, actuarial, financial and other services to HCM clients and/or its clients’ portfolio companies. HCM may face a potential conflict of interest in determining the fees for or costs of such Affiliate Services and/or Shared Services that will be charged to the relevant client. The terms of any agreement entered into in connection with any Affiliate Services or Shared Services, including any fees and expenses paid or received by HCM or its Affiliated Entities, will be determined by HCM in good faith on a case-by-case basis based on what it believes to be reasonable or customary at such time. In making such determination, HCM may seek to obtain benchmarking data regarding rates charged or quoted by third party service providers for similar services, or regarding the costs or expenses that are borne by comparable companies to maintain similar services in-house. In other circumstances, HCM may charge its or its Affiliated Entity’s respective costs for providing such Shared Services or Affiliate Services to the client, including, without limitation, an applicable portion of the compensation paid to its employees providing such services. Any such related compensation will be paid, reimbursed, or otherwise borne by the client, and a portion of the overhead related to such employees may also be allocated to such client. The rate paid for such employees may exceed the applicable market rate. Unless otherwise required by a client’s governing documents, these types of arrangements will not require client, director of advisory committee consent (as applicable) and such rates will not be subject to approval by any of the foregoing. Prior to entering into any Affiliate Services or Shared Services arrangement, HCM will make a good faith determination that such arrangement is in the best interests of the relevant client.

Code of Ethics and Personal Trading HCM has adopted a written Code of Ethics (the “Code”) in compliance with Securities and Exchange Commission (“SEC”) Rule 204A-1. The Code is updated by HCM from time to time to reflect new legislation or regulations, or to otherwise reflect evolving best practices. All employees are required to read the Code, as part of HCM’s overall Compliance Manual (the “Manual”), and annually acknowledge compliance with the policies and procedures set forth therein. HCM will provide a copy of the Code, as contained in the Manual, to any client or prospective client upon request to the email address on the cover of this brochure. HCM’s relying advisers, including HCMC I, HCMC II, HCMC III, Taberna Europe and HSA, operate under the same policies and procedures as HCM. The Code holds individuals to the highest standards of ethical conduct and places upon them a duty to act for the client’s benefit as well as to place the financial interests of HCM’s clients ahead of their own interests at all times. The Code also sets forth trading restrictions and/or prohibitions on certain types of securities for personal accounts, requires mandatory pre-clearance in respect of personal trades conducted in certain types of securities, and mandates reporting of initial holdings information upon employment and periodic transaction reporting thereafter for access persons of Hildene. HCM reviews these reports to ensure compliance by employees with HCM’s policies and procedures regarding personal trading activities. Participation or Interest in Client Transactions HCM and/or its principals and affiliates on occasion own, buy and/or sell securities which HCM recommends to its clients, subject to the personal trading limitations noted above. Such transactions may also include trading in securities in a manner that differs from or is inconsistent with advice given to clients. HCM employees may have a direct or indirect ownership interest in a client, as well as an indirect ownership interest in certain relying advisers from which they are entitled to receive management fees and/or performance-based fees. HCM recognizes that potential conflicts arise from such transactions and has taken reasonable measures to mitigate such conflicts. Additionally, HCM occasionally permits certain investors to participate directly along with investments made by a private fund managed by HCM. If, in such event, HCM later determines that it will sell any such investments for the relevant private fund, clients holding the same position will be contacted to give them an opportunity to sell concurrently with such fund. Certain affiliates of HCM serve as general partner, managing member or investment adviser to pooled investment vehicles which HCM recommends to its clients. In particular, if HCM determines that it is in a client’s best interest, HCM recommends from time-to-time that its clients invest in Hildene- managed private funds as well as securities issued by the HCMC CDOs or HSA CDOs, for which affiliates of HCM serve as the collateral manager, collateral servicer and/or managing member. HCMC receives collateral management fees and may in certain cases receive performance fees from the HCMC CDOs, as described in Items 5 and 6 above. Other than with respect to the HITR CDOs and HCOMF, HSA does not currently charge any fees in respect of the services it provides to any of the HSA CDOs.

From time-to-time, HCM engages in transactions in which it causes one of its clients to purchase securities or other instruments from, or sell securities or other instruments to, other clients managed by HCM and/or its affiliates (“cross trades”). HCM and/or its principals or affiliates also engage in principal transactions with clients (“principal transactions”) from time-to-time, subject to the client’s prior written consent and after full disclosure to the client of HCM and/or its principals’ or affiliates’ interest in the transaction. HCM and/or its affiliates will not take brokerage commissions or otherwise be compensated for effecting these cross trades or principal transactions. If utilized, HCM intends that cross trades and principal transactions will, to the best of HCM’s ability, reflect the fair value of the asset or other instrument being purchased or sold. In determining such fair value, HCM will typically rely on the most recent month-end quotations obtained from market makers, dealers or pricing services for cross transacted assets; provided, however, that if HCM obtains reliable information (e.g., through HCM’s trading activity in an asset) to indicate that the fair value of an asset has changed after the most-recent valuation date but before the execution date of a principal or cross transaction involving the asset, HCM may in its discretion (i) revise the valuation, upwards or downwards as the case may be, to reflect the new pricing information if HCM determines that the most-recent month-end valuation is no longer reflective of the asset’s fair value or (ii) to the extent practicable, obtain one or more third party quotes of the asset as of the transaction date or a recent date thereto. Prior to effecting any cross trade or principal transaction, HCM will make a good faith determination that the transaction is in the best interests of the relevant clients.

HCM is responsible for the placement of the portfolio transactions of clients and the negotiation of any commissions or spreads paid on such transactions. Portfolio investments are generally purchased through brokers on securities exchanges or directly from the issuer or from an underwriter or market maker for the investments. Purchases of portfolio investments through brokers will typically involve a commission to the broker. Purchases of portfolio investments from dealers serving as market makers include the spread between the bid and the ask price. In placing portfolio transactions and negotiating commission rates, HCM will seek to obtain the best execution for its clients where possible; provided, however, that many of HCM’s portfolio transactions occur in the OTC marketplace, where HCM may not have the ability to compare or evaluate different broker-dealers in respect of a particular portfolio transaction. In reviewing best execution, HCM may take into account the following factors: (i) the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); (ii) the operational efficiency with which transactions are effected, taking into account the size of order and difficulty of execution; (iii) the financial strength, integrity and stability of the broker; (iv) the reputation of the broker; (v) the firm’s risk in positioning a block of securities; (vi) efficiency of execution and error resolution; (vii) the quality, comprehensiveness and frequency of available research services considered to be of value; and (viii) the competitiveness of commission rates in comparison with other brokers satisfying HCM’s other selection criteria. HCM is authorized to pay higher prices for the purchase of securities from or accept lower prices for the sale of securities to brokerage firms that provide it with such investment and research information or to pay higher commissions to such firms if HCM determines such prices or commissions are reasonable in relation to the overall services provided. Research services furnished by brokers may include written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; statistics and pricing or appraisal services; discussions with research personnel; and invitations to attend conferences or meetings with management or industry consultants. HCM is not required to weigh any of these factors equally. Information so received is in addition to and not in lieu of services required to be performed by HCM, and HCM’s fees charged to clients are not reduced as a consequence of the receipt of such supplemental research information. Research services provided by broker/dealers used by HCM clients may be utilized by HCM or its affiliates (including other investment funds managed by such persons) in connection with their other investment activities. Since commission rates in the United States are negotiable, HCM’s selection of brokers on the basis of considerations which are not limited to applicable commission rates may at times result in HCM’s clients being charged higher transaction costs than they could otherwise obtain. Use of “Soft Dollars” The term “soft dollars” refers to the receipt by an investment manager of products and services provided by brokers, without any cash payment by the investment manager, based on the volume of brokerage commission revenues generated from securities transactions executed through those brokers on behalf of the investment manager’s clients. Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), provides a “safe harbor” to investment managers with respect to potential liability for violating their duty to obtain best execution for a client’s securities transactions in circumstances in which such managers use soft dollars generated by their advised accounts only for purposes of obtaining

investment research and brokerage services (i) that provide lawful and appropriate assistance to the investment manager in the performance of investment decision-making responsibilities and (ii) where the commissions paid are reasonable in relation to the value of the services provided. HCM does not currently, and does not in the future intend to, engage in any soft dollar transactions. In the event that HCM does engage in any soft dollar transactions, it will not engage in any such transactions other than with respect to products and services which fall within the Section 28(e) safe harbor or where such products or services would otherwise be chargeable to its clients pursuant to the relevant fund offering documentation or separate account advisory contract. Client Referrals HCM may direct some of its clients’ brokerage business to brokers who refer prospective investors to HCM. Because such referrals, if any, are likely to benefit HCM but will provide an insignificant (if any) benefit to HCM’s clients, HCM will have a conflict of interest with its clients when allocating such clients’ brokerage business to a broker who has referred investors to HCM. To prevent HCM’s clients’ brokerage commissions from being used to pay investor referral fees, HCM will not allocate its clients’ brokerage business to a referring broker unless HCM determines in good faith that the commissions payable to such broker are not materially higher than those available from non-referring brokers offering services of substantially equal value to such clients. Aggregation of Orders HCM will at times determine that certain securities are suitable for acquisition by more than one account, possibly including Affiliated Accounts, and may aggregate purchase or sale orders for client accounts. The aggregation or blocking of transactions typically allows an adviser to execute transactions in a more timely, equitable, and efficient manner and seeks to reduce overall commission charges to accounts. HCM’s policy is to aggregate transactions where possible and when advantageous to the accounts participating in such transactions. When HCM is placing bids for securities in certain OTC markets in which it and its clients invest, it may routinely aggregate orders into a single bid due to timing constraints and other practical considerations. From time to time, HCM participates in auctions or bid solicitations in which HCM bids to acquire securities in its capacity as investment adviser on behalf of its clients. In such instances, HCM will generally place a single bid for securities based upon the aggregate number of securities that HCM seeks to acquire on behalf of all of its clients. HCM will allocate any securities acquired in such auction or pursuant to such bid solicitation among accounts for whom such securities are suitable in accordance with its trade allocation policy described below, with such allocation determined upon acquisition of the relevant securities (rather than at the time of the relevant bid). Any transaction costs arising from an aggregated transaction will be shared on a pro rata basis by participating accounts, based upon the assets allocated to each such account in accordance with HCM’s trade allocation policy. HCM may aggregate transactions for clients and Affiliated Accounts, subject to HCM’s policy to place client account allocations first. Allocation of Trades When HCM aggregates orders, HCM will seek to allocate investments among clients, including Affiliated Accounts, on a fair and equitable basis over time based on the following factors: (i) diversity of the accounts’

investment objectives; (ii) differences in the accounts’ investment guidelines and investment restrictions; (iii) differences in the accounts’ risk tolerances and return targets; (iv) differences in the accounts’ existing portfolio holdings and related balancing and diversification concerns; (v) differences in the accounts’ relative sizes; (vi) differences in the accounts’ available investment resources (including the timing of capital contributions and withdrawals) and side pocket constraints; (vii) differences in the accounts’ liquidity requirements; (viii) differences in the accounts’ investment time horizons; (ix) tax considerations; and (x) such other factors as HCM may determine to be relevant at the time of allocation. In addition, HCM may take into account settlement costs in making allocation determinations. For example, if the amount of a security that would be allocated to a particular account would be small in view of the factors described above, and if HCM determines in its discretion that the settlement costs associated with making such allocation would outweigh the benefits of such allocation due to the small amount of securities proposed to be allocated, HCM may elect not to make an allocation to such account. Allocations may be made among accounts in a manner that is not pari passu if such allocation is determined to be reasonable by HCM in accordance with the factors described above. Allocations based on these factors will result in differences in invested positions and securities held among clients, and consequently in performance. HCM shall endeavor to afford each account fair and equitable treatment in allocating trades among accounts, provided that allocations shall first be made to HCM’s clients for whom allocation would be appropriate in light of the factors described above, in such amounts as may be appropriate in accordance with such factors, prior to making any allocation to any Affiliated Accounts. To the extent relevant, HCMC and HSA adhere to the foregoing brokerage practices in connection with their respective management of the HCMC CDOs and HSA CDOs.

HCM has entered into arrangements with placement agents whereby HCM will compensate third parties who introduce certain private fund investors and clients. Such placement agent arrangements will seek to conform to Rule 206(4)-1 of the Advisers Act, to the extent applicable. Compensation typically takes the form of a percentage of the management fees and performance fees received by HCM from such investors. The fees paid to such placement agents are generally paid by HCM and are not borne by investors, and such fee arrangements are disclosed to applicable investors. HCM does not receive economic benefits from any person not a client of HCM in exchange for providing advisory services to HCM clients. Neither HCMC nor HSA has any written agreements in place with any third party marketers. Neither HCMC nor HSA receives any economic benefits from any person not a client of HCMC or HSA, as the case may be, in exchange for providing advisory services.

Hildene has no disciplinary events to disclose.

Transaction activity for each HCM account is reviewed on a daily basis, typically by a senior investment team member, as well as Compliance. HCM investment personnel meet periodically to discuss new investment opportunities and current market conditions. Additionally, HCM investment management personnel review HCM’s portfolios on at least a monthly basis for compliance with each portfolio’s guidelines and investment strategy. Additional portfolio reviews may be conducted as a result of client contributions or distributions, revised client objectives, or changes in law. HCM, or an administrator engaged by HCM, typically provides clients with reports concerning account holdings, transaction summaries and performance data, on either a monthly or quarterly basis. More frequent reporting may be provided as requested by a client or investor. Investors in HCM-managed private funds and separately managed accounts receive monthly or quarterly account statements from the accounts’ administrator or custodian. Audited financial statements are typically provided to investors in private funds managed by HCM on an annual basis. Investments held by CDOs or CDO warehouses are periodically reviewed by investment professionals of HCMC and/or HSA, as applicable. This review primarily focuses on an analysis of each investment’s financial performance, a review of each investment’s capital structure and a review of each investment’s industry prospects. Individual CDO deal metrics are also periodically reviewed. Investors in CDOs receive monthly or quarterly reports from the account’s trustee, which are reviewed for accuracy by CM Personnel.

HCM does not have custody of its clients’ assets; however, HADV, HPCFGP, HABCGP II, BPCFGP I, BPCFGP II, BPCFGP III, BPCFGP IV, and OPCFGP I, affiliates of HCM, serve as the general partner of certain private funds, and HCM has a principal who serves on the board of directors of certain private funds for which HADV and/or HCM are deemed to have custody under certain rules promulgated by the SEC. With respect to any account in which HCM or an affiliate is deemed to have custody, the assets of such HCM clients are held by a qualified custodian, which provides monthly account statements to each client and provides copies of such statements to HCM. Investors in HCM’s private funds additionally receive monthly account statements from the applicable fund’s administrator. Investors are urged to carefully review such statements. Additionally, the private funds undergo an audit on an annual basis by an independent public accountant that is both registered with and subject to regular inspection by the Public Company Accounting Oversight Board. In respect of such private funds, HCM provides audited financial statements of each fund to the investors in the fund within 120 days of the end of the fund’s fiscal year. Investors are urged to carefully review such audited financial statements. Neither HCMC nor HSA currently maintain custody of any client’s funds or securities.

HCM generally has discretionary authority over its clients’ assets pursuant to the advisory contracts it enters into with such clients. This means that HCM places trades in its clients’ accounts without contacting the client prior to any trade to obtain the client’s permission. HCM’s discretion may be limited pursuant to the terms and conditions of the applicable advisory relationship, provided that the restrictions are essentially consistent with HCM’s investment process. Similarly, HSA has discretionary authority over each HSA CDO’s assets during the pre-securitization warehouse period pursuant to investment management agreements entered into between HSA and the applicable HSA CDO. HSA’s discretion may be limited pursuant to the terms and conditions of the applicable advisory relationship, provided that the restrictions are essentially consistent with HSA’s investment process. HSA has discretionary authority, pursuant to the applicable transaction documents, over the investment and reinvestment of certain assets held in an Insurance-Wrapped Vehicle’s premium reserve accounts in connection with certain structured finance transactions for which HSA serves as collateral servicer. Such discretion is exercised subject to the terms of the governing documents, including applicable investment guidelines, eligibility criteria, and other contractual limitations. The applicable indentures for CDOs managed by HCMC and HSA, including the HCMC CDOs and the new issue HSA CDOs, place significant restrictions on HCMC and HSA’s ability to buy and sell collateral debt securities on behalf of the CDOs once warehouse operations have ceased and a securitization transaction has occurred (and, in the case of HCOMF, the reinvestment period has ended). These indentures generally restrict HCMC and HSA during such periods from selling collateral debt securities on behalf of a CDO unless such securities have experienced specified credit deterioration, ratings downgrades, or events of default.

HCM accepts authority to vote client securities for certain clients, including the private funds it manages. In such circumstances, proxy and other corporate action material is promptly reviewed by HCM to evaluate the issues presented. In voting proxies, HCM is guided by general fiduciary principles. HCM’s goal is to act prudently, solely in the best interest of the client accounts it manages. HCM attempts to consider all aspects of its vote that could affect the value of the investment; and where HCM votes proxies, it will do so in the manner that it believes will be consistent with efforts to maximize the value of security holdings. HCM may determine to abstain from voting a proxy or a specific proxy item when it concludes that the potential benefit of voting is outweighed by the cost or when it is not in the client’s best interest to vote. In many instances, the disparate interests of HCM’s clients may make it difficult for HCM to determine a manner in which to vote and, in those circumstances, HCM may abstain from voting. However, if HCM does vote, HCM shall vote in a manner it believes to be consistent with the interests of its clients and shall not subordinate client interests to its own, or subordinate one client’s interest to another client’s. HCMC and HSA’s CDO investments are primarily comprised of various tranches of debt securities. Generally, the holders of these investments are not entitled to vote on corporate matters, however, to the extent relevant, HCMC and HSA will adhere to the foregoing voting practices in connection with its management of CDOs. In furtherance of Hildene’s goal to vote proxies in the best interests of clients, Hildene follows procedures designed to identify and address material conflicts that may arise between Hildene’s interests and those of its clients before voting proxies on behalf of such clients. In the event a material conflict of interest is identified, certain methods may be used to resolve the conflict, including (i) disclosing the conflict to the client and obtaining its consent before voting; (ii) suggesting to the client that it engage another party to vote the proxy on its behalf; or (iii) such other method as Hildene deems appropriate under the circumstances, given the nature of the conflict. Clients may obtain a copy of Hildene’s proxy voting policies and procedures upon request to the email address on the cover of this brochure. Hildene maintains records of each proxy form or corporate action as voted for its clients.

None of HCM, HCMC or HSA has additional financial circumstances to report. A balance sheet is not required to be provided because none of these entities requires or solicits prepayment of more than $1,200 in fees per client more than six months in advance of services rendered.