MONROE CAPITAL MANAGEMENT ADVISORS LLC

Firm Background MCMA is a Delaware limited liability company that was formed in February 2007. MCMA provides discretionary portfolio management and investment advisory services to pooled investment vehicles and separately managed accounts. MCMA and its Relying Advisers (as defined below) are headquartered in Chicago, Illinois, with additional locations in Austin, Boston, Farmington, Los Angeles, Miami, Naples, New York, San Francisco, Seoul, South Korea, Sydney, Australia and Abu Dhabi, United Arab Emirates. In a transaction effective as of March 31, 2025 (the “Transaction”), Momentum US Bidco, LLC (“Momentum US Bidco”), a majority-owned subsidiary of Momentum US Topco, LLC (“Momentum US Topco”), which is in turn majority-owned by Wendel S.E. (“Wendel”), whose sole controlling shareholder is Wendel Participations SE, indirectly acquired 75% of MCMA and its affiliates. As a result of the Transaction, MCMA became a wholly owned subsidiary of Monroe Capital Intermediate Holdings, LLC (“MC Intermediate Holdco”), which is majority-owned by Momentum US Bidco and minority-owned by Monroe Capital Investment Holdings, L.P. (“MC Investment Holdings”). For the avoidance of doubt, MCMA continues to operate independently with no changes to investment process, strategy or operations arising from the Transaction. The officers and senior management team of MCMA and its affiliated entities include: Theodore L. Koenig, as Chairman and Chief Executive Officer; Michael J. Egan, as Vice Chairman and Chief Credit Officer; Thomas C. Aronson, as Vice Chairman and Head of Originations; Zia Uddin, as President; Aaron D. Peck, as Managing Director and Co-Head and Co-Portfolio Manager of Alternative Credit Solutions; Alexander Franky, as Managing Director and Head of Direct Underwriting; R. Sean Duff, as Managing Director and Head of Client Services; James Cassady, as Managing Director and Chief Operating Officer; Caroline B. Davidson, as Managing Director and Head of Capital Markets; Karina B. Stahl, as Managing Director and Chief Financial Officer of Investment Funds; Peter T. Gruszka, as Managing Director and General Counsel; Kyle A. Asher, as Managing Director and Co-Head and Co-Portfolio Manager of Alternative Credit Solutions; Jeffrey Cupples, as Deputy Head of Credit, Direct Investments; Matthew Lane, as Deputy Head of Underwriting, Direct Investments; Jeffrey Williams, as Managing Director and Co-Head of Tradable Credit Group; Scott A. Marienau, as Chief Financial Officer of Management Company; Alex Patil, as Managing Director and Southern California Region Group Head; Christopher Lund, as Managing Director and Portfolio Manager, Institutional Portfolios of Direct Lending; Nathan Harrell, as Managing Director and Co-head of Portfolio Group; Seth Friedman, as Managing Director and Head of Structured Solutions; Stewart Hanlon, as Managing Director and Co-Head of Technology Finance; and Ronald A. Holinsky, as Chief Compliance Officer, Chief Legal Officer of Regulated Funds, and Head of Operational Risk (collectively, the “Senior Management Team”). With respect to certain affiliated pooled investment vehicles which are advisory clients, MCMA provides discretionary portfolio management and investment advisory services through six (6) relying advisers which include, (i) Monroe Capital Management, LLC (“Monroe Capital Management”); (ii) Monroe Capital Asset Management LLC (“MC Asset Management”); (iii) Monroe Capital CLO Manager LLC (“MC CLO Manager”); (iv) Monroe Capital CLO Manager II LLC (“MC CLO Manager II”); (v) Monroe Capital Partners Fund Advisors, Inc. (“MC Partners Fund Advisors”); and (vi) Monroe Capital Real Estate Credit Advisors, LLC (collectively, the “Relying Advisers”). The Relying Advisers are registered with the SEC as investment advisers relying on MCMA’s investment adviser registration with the SEC pursuant to Rule 203A-2(b) of the Advisers Act and the SEC’s guidance on umbrella registration provided in general instructions to Form ADV. Unless otherwise stated, any reference made to MCMA includes the Relying Advisers hereinafter. MCMA does not act as a general partner of any of its affiliated pooled investment vehicles and/or single

investor funds (“SIFs”). Instead, certain of MCMA’s affiliates serve as general partners to one or more of the pooled investment vehicles and/or SIFs and have delegated exclusive investment advisory and other authority with respect to such pooled investment vehicles and/or SIFs to MCMA. See Item 10 – Other Financial Industry Activities and Affiliations of this Brochure for more information regarding MCMA’s affiliated entities. Horizon Technology Finance Management LLC (“HTFM”), an affiliate of MCMA, is a wholly owned subsidiary of MCH Holdco LLC, which is a wholly owned subsidiary of MC Intermediate Holdco, which is majority-owned by Momentum US Bidco, which is majority-owned by Momentum US Topco, which is in turn majority-owned by Wendel, whose sole controlling shareholder is Wendel Participations SE, and minority-owned by MC Investment Holdings. Advisory Services MCMA provides discretionary portfolio management and investment advisory services to pooled investment vehicles and separately managed accounts that focus on investing in private credit markets across various strategies, including direct lending, asset based lending, specialty finance, opportunistic lending, real estate lending, structured credit and equity primarily in North America that require financing to fund corporate events, recapitalization, ownership transfer, sourcing of expansion and growth capital and/or refinancing. MCMA primarily pursues transactions in such middle market companies by investing in senior and junior secured and unsecured loans, unitranche loans and other asset-based loans, leasing loans, receivables loans, consumer loans, mezzanine loans, stressed and distressed debt, investment and non-investment grade credit, structured debt and equity, warehouse loan facilities, securitized debt and subordinated notes of collateralized loan obligations and other types of securitized debt tranches. As stated above, MCMA provides discretionary portfolio management and investment advisory services to pooled investment vehicles and/or SIFs whose investors include large institutions and high net worth individuals, including but not limited to, state and local pensions, corporate pensions, endowments and foundations, insurance companies, regional banks and family offices. Such privately offered pooled investment vehicles include collateralized loan obligations (the “CLO Funds”), collateralized fund obligations (the “CFO Funds”), private investment funds, SIFs, and other U.S. and non-U.S. structured investment vehicles (collectively, the “Private Funds”). MCMA also provides discretionary portfolio management and investment advisory services to separately managed accounts for large institutions and affiliated investment vehicles of those institutions (“SMA Clients”). A Relying Adviser provides discretionary portfolio and investment advisory services to a privately offered real estate investment trust (the “REIT”). The CLO Funds, CFO Funds, and the Private Funds are collectively referred to herein as the “Funds” or the “Clients”. Pursuant to an investment management agreement, collateral management agreement or other similar governing agreement (each, a “Management Agreement”), each Fund’s respective general partner or director (each, a “General Partner”), has engaged MCMA to provide origination, acquisition, asset management, and other administrative services to each respective Fund in accordance with each Fund’s respective private placement memorandum, offering memorandum, offering circular, limited partnership agreement, indenture or other similar disclosure and governing documents (collectively, the “Governing Documents”). MCMA’s investment advisory services consist of, but are not limited to, managing each Fund’s portfolio of investments, including sourcing, selecting, and determining investments in each Fund, monitoring investments by each Fund and executing transactions on behalf of each Fund in accordance with the investment objectives, policies and guidelines set forth in each respective Fund’s Governing Documents. Accordingly, MCMA’s investment advisory services to the Funds (other than SIFs as described below) is not tailored to the individualized needs or objectives of any particular Fund investor. An investment in a Fund by an investor does not, in and of itself, create an advisory relationship between the investor and MCMA. Investors are not permitted to impose restrictions or limitations on the management of any Fund (other than SIFs as described below). The General Partner of a Fund reserves the right to enter into side letter

agreements or arrangements with one or more investors in a Fund that alter, modify or change the terms of the interests held by such investors. Information about each Fund, and the particular investment objectives, strategies, restrictions, guidelines and risks associated with an investment, is described in each respective Fund’s Governing Documents, which are made available to investors only through MCMA or another authorized party. Since MCMA does not provide individualized advice to investors (and an investment in a Fund does not, in and of itself, create an advisory relationship between the investor and MCMA), investors must consider whether a particular Fund meets their investment objectives and risk tolerance prior to investing. MCMA has, and may in the future, tailor its advisory services to the individual needs of single investor fund (“SIF”). MCMA may agree with a SIF to manage such SIF’s assets against a particular benchmark or pursuant to an investment management agreement, which include provisions related to management fees, investment strategy, investment guidelines, termination rights, proxy voting and sub-adviser, if applicable. SIFs should be aware, however, that the aforementioned restrictions can limit MCMA’s ability to act on behalf of a SIF and as a result, the SIF’s performance may differ from and may be less successful than that of other Clients’ accounts managed by MCMA which are not subject to such restrictions. Prospective clients and prospective client investors must consider whether a particular MCMA advisory relationship is appropriate for their own circumstances based on all relevant factors including, but not limited to, the prospective client’s own investment objectives, liquidity requirements, tax situation and risk tolerance. Prospective clients are strongly encouraged to undertake appropriate due diligence including, but not limited to, a review of Governing Documents relating to the proposed investment program for the SIF and to investigate additional details about MCMA’s investment strategies, methods of analysis and related risks, before making an investment decision or committing to a service provided by MCMA. See Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss of this Brochure for a more detailed discussion on investment strategies and the risks involved with such strategies. ALL DISCUSSION OF THE FUNDS IN THIS BROCHURE, INCLUDING BUT NOT LIMITED TO ITS INVESTMENTS, THE STRATEGIES USED IN MANAGING THE FUNDS, AND CONFLICTS OF INTEREST FACED BY MCMA IN CONNECTION WITH THE MANAGEMENT OF THE FUNDS ARE QUALIFIED IN THEIR ENTIRETY BY REFERENCE TO THE RESPECTIVE FUND’S GOVERNING DOCUMENTS. Wrap Fee Disclosure MCMA does not participate in or sponsor any wrap fee programs. Regulatory Assets Under Management As of December 31, 2025, MCMA managed approximately $18,555,608,314 of regulatory assets under management, of which all were on a discretionary basis, and none were on a non-discretionary basis.

In consideration for MCMA’s advisory and other services, MCMA and/or certain of its affiliates generally are entitled to receive management fees and are also permitted to receive performance compensation (as described below), with respect to the Funds. While the fees, allocations and compensation applicable to each Fund are described in detail in the applicable Governing Documents, side letters and/or fee agreements, an overview of MCMA’s basic compensation schedule is summarized below. A potential investor should read and review all applicable Governing Documents in their entirety before making any investment decisions. Fee Schedules Private Funds (Other than CLO Funds and CFO Funds) Management Fees: In consideration for its advisory services to the Private Funds, MCMA typically receives a “Management Fee” from each respective Private Fund. The specific payment terms and other conditions of the Management Fees available to MCMA are set forth in the applicable Private Fund’s Governing Documents, side letters and/or fee agreements. The Management Fees are generally a percent of the Private Funds’ investors’ aggregate capital commitments or a percent of the Private Funds’ total Invested Assets, on the appraisal date, payable quarterly or monthly in arrears or in advance. “Invested Assets” generally means, with respect to each Private Fund investor, at any time the sum of (a) such Private Fund investor’s total prior capital contributions less any prior distributions that constitute return of such amounts plus (b) such Private Fund investor’s pro rata share of the principal amount of any indebtedness incurred by the Private Fund and outstanding at such time, in each case, as determined by the Private Fund’s General Partner or MCMA in its sole discretion. Management Fees are generally paid to MCMA by deducting such fees from the applicable Private Fund’s account. Upon the termination of MCMA’s Management Agreement with a Private Fund, MCMA will refund to the Private Fund the pro-rated portion of any Management Fee already paid by the Private Fund for the period following the effective date of such termination provided that nothing else was specified in the respective Fund’s Governing Documents and/or Management Agreement, including that some Management Agreements provide for payment of management fees for up to one year upon termination in the absence of cause. MCMA and its affiliates will benefit from MCMA’s relationship with and its receipt of Management Fees from the Private Funds. Such Management Fees and relationship will enhance the value of MCMA, and the Private Fund investors (other than those Private Fund investors holding direct or indirect interests in MCMA, if any) will not participate in any increase in the value of MCMA. Performance-Based Compensation: The General Partner and/or its designee for each respective Private Fund is generally permitted to receive performance-based fees and/or carried interest distributions, as applicable (collectively, “Performance-Based Compensation”) (e.g., carried interest, performance allocations, incentive allocations, performance fees or incentive fees) in connection with the management of the Private Fund. The specific payment terms and other conditions of the Performance-Based Compensation available to a General Partner and/or its designee are set forth in the applicable Private Fund’s Governing Documents, side letters and/or fee agreements. Generally, Performance-Based Compensation payable to the applicable General Partner and/or their designee (as “special limited partner”) is payable quarterly, annually or more frequently in arrears, subject to a preferred return and an interim and/or end-oflife clawback mechanic. All Performance-Based Compensation payable to the General Partners and/or their respective designees of the Private Funds will be consistent with the requirements of Section 205 of the Advisers Act and Rule 205-3 thereunder. As discussed in Item 6 below, Performance-Based Compensation payable to a General Partner and/or its designee on investment income and investment gains may create an incentive for the General Partner’s

affiliate, MCMA, to cause the Private Fund to make investments that are riskier or more speculative than would be the case if a Performance-Based Compensation arrangement were not in effect. The PerformanceBased Compensation may create an incentive for MCMA to time investments, and the realization of investments, so as to maximize Performance-Based Compensation rather than the returns of the Private Fund. In addition, Performance-Based Compensation payable by a Private Fund have not been established on the basis of an arm’s length negotiation among such Private Fund, on the one hand, and MCMA or its affiliates, on the other hand. CLO Funds As compensation for its services as the collateral manager to the CLO Funds, MCMA generally receives a senior management fee, a subordinated management fee and an incentive management fee (collectively, the “Collateral Management Fees”). The senior management fee has a higher priority in a CLO Fund payment waterfall whereas the subordinated management fee generally ranks below principal and interest payments to senior note holders in the payment waterfall. MCMA will generally earn a subordinated management fee if over-collateralization and interest coverage tests have been satisfied for all senior CLO Fund note holders. The senior management fees and subordinated management fees are typically paid by the CLO Fund or its respective trustee quarterly in arrears, in accordance with its Governing Documents. Incentive management fees are typically paid later in a CLO Fund’s tenor by the CLO Fund or its respective trustee in arrears if specific internal rates of return thresholds are achieved. Please consult the CLO Fund’s applicable Governing Documents for additional information regarding such Collateral Management Fees. CFO Funds No fees are borne at the CFO Fund level. Fees Generally The applicable General Partner and/or MCMA generally has the unilateral discretion to waive or modify the application of certain provisions of the Governing Documents for a Private Fund with respect to an investor (including those related to fees, performance allocations, transparency, and withdrawals) without obtaining the consent of any other investor. The applicable General Partner of a Private Fund and/or MCMA may, in its sole discretion, charge lower Management Fees and/or Performance-Based Compensation or waive account minimums based on certain factors the General Partner and/or MCMA deems relevant. However, the applicable General Partner and/or MCMA may be limited in its ability to negotiate fees due, in part, to existing side letters and/or fee agreements, which require equivalent pricing. Under the terms of these agreements, the General Partner and/or MCMA is generally required to charge equivalent pricing. The General Partner of a Fund and/or MCMA has, and may in the future, enter into side letter agreements or arrangements with one or more investors in a Fund that alter, modify or change the terms of the interests held by such investors, providing revised economic terms, including, but not limited to, distribution provisions with respect to such limited partner that differ from those described in the Fund’s Governing Documents. A conflict may arise where some Fund investors receive more favorable overall economic terms and other Fund investors will not participate in such terms. A Private Fund’s Governing Documents generally permit MCMA or its respective General Partner to charge and deduct Management Fees and/or Performance-Based Compensation (collectively, “Advisory Fees”) directly from the assets of the Private Fund, at the times and in the amounts set forth in such Governing Documents. The ability of MCMA to deduct Advisory Fees for SIFs may be negotiable. Collateral Management Fees, with respect to the CLO Funds, are paid to MCMA at the times and in the amounts set forth in the respective CLO Fund’s Governing Documents by directly billing (e.g., invoicing) the CLO Fund’s respective trustee. Advisory Fees for the Private Funds are generally payable on a quarterly or monthly basis and may be payable in advance or in arrears in accordance with the terms of the applicable Governing Documents.

Collateral Management Fees for the CLO Funds are generally payable on a quarterly basis in arrears through the CLO waterfall in accordance with the terms of the applicable Governing Documents. Funds have the right to terminate MCMA’s advisory services in accordance with the terms of the applicable Governing Documents and/or Management Agreement. Upon termination of such agreement with any Fund who has paid in advance, MCMA will refund to such Fund the pro-rata portion of any advance payment based on the number of days remaining in the billing period after the date of termination, provided that nothing else was specified in the respective Fund’s Governing Documents and/or Management Agreement. From time to time, a Fund managed by MCMA may purchase an interest in another Fund managed by MCMA, provided that the sale or purchase is consistent with MCMA’s fiduciary obligations to each such Fund and that such sale or purchase is consistent with the investment policies, guidelines, and objectives of each such Fund’s general investment strategy as per each such Fund’s Governing Documents. Fund investors should be aware that, while MCMA endeavors at all times to act in the best interests of all of its Funds, MCMA receipt of compensation from each of the Funds and the contribution of additional capital by a Fund to another Fund may create potential conflicts of interest. In certain circumstances, MCMA may choose to lower or waive (or rebate back) the Advisory Fees or Collateral Management Fees of a Fund investing in another Fund by the amount of Advisory Fees or Collateral Management Fees applicable to the Fund’s investment in such other Fund. Other Fees and Expenses Organizational Expenses: Each Fund, subject to its Governing Documents, will typically pay or otherwise bear its organizational expenses, subject to a specified expense cap which may vary from Fund to Fund. Any organizational expenses in excess of the specified expense cap will be borne by the applicable General Partner (or its equivalent) or offset against Management Fees. Such organizational expenses generally may include legal, accounting, filing, capital raising, placement agent fees, travel, accommodation, meal and other similar fees, costs and other start-up related expenses (collectively, the “Organizational Expenses”). Certain Funds may be considered “Parallel Funds” of one another, with parallel funds having common investment strategies but for one or more unique characteristics. Other Funds that are not deemed to be Parallel Funds with one another may be considered “Other Monroe Clients” in relation to one another. As used herein, “Other Monroe Clients” means any investment fund, investment partnership, managed account or other investment vehicle or contractual arrangement (other than any Other Wendel Fund Platforms) established, sponsored, owned, managed, advised and/or sub-advised, directly or indirectly, by the applicable General Partner, MCMA, and/or any of their respective affiliates (other than Other Wendel Owned Managers). A Fund may consist of feeder and intermediate funds investing in a common “master fund”, as well as alternative investment vehicles. Generally, the Fund’s Governing Documents typically provide that each Fund shall bear or pay its pro rata share of Fund Expenses (but not in duplicate), where “Fund Expenses” are those incurred on behalf of a defined universe of Parallel Funds and alternative investment vehicles (“Fund Entities”). To the extent that any Fund Expenses are incurred for the benefit of a Fund Entity and/or any of their related entities (or any combination of the foregoing), such Fund Expenses will generally be borne by each such vehicle pro rata or in such other manner as the Firm considers fair and equitable under the circumstances based on the MCMA’s expense allocation methodology. In certain circumstances Organizational Expenses and Fund Expenses will be allocated among Fund Entities and Other Monroe Clients. To the extent that any Organizational Expenses or Fund Expenses (or their substantial equivalent) are incurred that benefit a Fund (or Fund Entities) and an Other Monroe Client(s), such Organizational Expenses or Fund Expenses (or their substantial equivalent) will generally be allocated pro rata or in such other manner as the MCMA considers fair and equitable under the circumstances, based on the MCMA’s expense allocation methodology.

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The following is a summary of the investment strategies and methods of analysis employed by MCMA on behalf of Clients. This summary should not be interpreted to limit in any way MCMA’s investment activities. MCMA may offer any advisory services, provide advice with respect to any investment strategies and make any investments, including those that may not be described in this Brochure, that MCMA considers appropriate, subject to each Client’s investment objectives and guidelines. Specific descriptions of such strategies and methods are included in each Client’s Governing Documents. In the case of SIFs managed by MCMA, the investment strategies and methods of analysis employed on behalf of each SIF will be set forth in the Investment Management Agreement between the SIF and MCMA or in other related documents. There can be no assurance that the investment objectives of any Client will be achieved. Methods of Analysis Idea Generation: MCMA’s deal origination professionals identify new investment opportunities generally through MCMA’s proprietary national, regional and local network of industry relationships formed throughout the past two decades. MCMA’s origination platform consists of dedicated senior professionals who average over 20 years of experience. MCMA’s origination platform is comprised of not only regional coverage in North America, but also specialists in several large industries such as healthcare, technology, media, and retail and consumer products and a vertical that is focused on specialty finance transactions. MCMA’s origination team makes it a point to attend local trade meetings, regional conferences and middle market focused organization events throughout the United States. Strategic Relationships: MCMA has cultivated substantial relationships with strategic bank partners, including many regional banks. Certain strategic bank partners are existing investors in one or more Clients and/or provide financing to one or more Clients through leverage facilities and subscription lines of credit. Accordingly, MCMA believes these relationships create a significant competitive advantage for Clients the banks are not only a powerful source of deal flow, but more importantly are key partners that team with MCMA and the Funds to effectively execute unitranche and A/B financing structures. The banks usually provide critical working capital asset-based revolving credit facilities, while MCMA provides the term loan component. This combination allows the borrower to achieve a lower overall cost of capital, while allowing the Funds to achieve higher incremental deal pricing. The regional banks benefit from deposits, operating accounts, treasury management and other services without significantly impacting their balance sheet. Active Investor and Operating Approach to Value Creation: Prior to making an investment on behalf of Clients, MCMA conducts a comprehensive financial and operational underwriting process to determine the factors likely to impact ongoing performance by assets and portfolio companies or a proposed restructuring or recapitalization process. This analysis includes the following: •

Due Diligence – MCMA utilizes well-defined credit and underwriting criteria and proprietary investment management tools. Standard due diligence items typically include in-person meetings with senior management and company owners, onsite visits, detailed calls with key customers and suppliers and examination of compatibility with MCMA’s Environmental, Social and Governance (“ESG”) Policy. MCMA may also utilize third-party firms to conduct quality of earnings analyses, special purpose accounting reviews, asset and enterprise value appraisals, background checks on senior company management, field audits, technology reviews and business plan reviews. As part of this detailed process, MCMA utilizes recognized and experienced vendors (such as external legal counsel and accounting firms) to promote consistency and efficiency.

•

Strategic Planning – MCMA is actively involved in identification, development and execution of various strategies for portfolio companies.

•

Executive Development – MCMA draws on its network of relationships to assist in the recruiting

and developing the management of portfolio companies, as needed. •

Capital Formation – MCMA draws on its relationships in the banking, finance, private equity, investment banking and capital markets to assist portfolio companies in capital sourcing, as needed.

•

Defining and Establishing Clear Exit Criteria – MCMA establishes a pre-defined exit strategy based on varying estimates of the borrower’s future cash flows or liquidation of assets prior to making an investment and seeks to exit an investment once the exit criteria have been met.

Participation in Clients is only suitable for investors who have knowledge and expertise in financial and business matters and are capable of evaluating the merits and risks of an investment in a Client. The acquisition of interests or shares in a Client and the investments made by the Clients are highly speculative and may involve the risk of total loss of an investor’s capital. Investment Strategy Each Client’s investment strategy is outlined in its applicable Governing Documents. MCMA’s objective is to achieve attractive risk-adjusted returns across all economic cycles. MCMA’s investment approach is value oriented, focusing on industries in which it has considerable knowledge and emphasizing downside protection and the preservation of capital. Clients principally seek to make debt investments that offer a compelling risk/reward, are undervalued by the markets and/or are priced at attractive yields. MCMA seeks to achieve this objective by primarily pursuing opportunities to make loans to, and invest in, middle market companies located in North America that require financing to fund a corporate event such as a buyout, recapitalization, ownership transfer, sourcing of expansion and growth capital or refinancing. MCMA’s seeks to provide investors with access to a well-selected, transparent and diversified portfolio of otherwise hard to access private credit investments in such middle market companies. MCMA pursues such middle market companies by making directly originated and/or broadly syndicated loans to middle market companies through investments in senior and junior secured and unsecured loans, unitranche loans and other asset-based loans, leasing loans, receivables loans, consumer loans, mezzanine loans, stressed and distressed debt, investment and non-investment grade credit, structured debt and equity, warehouse loan facilities, securitized debt and subordinated notes of collateralized loan obligations and other types of securitized debt tranches. MCMA develops its investment strategies based upon the following distinguishing characteristics: (i)

Integrated Business Model with Strong Credit Expertise. MCMA and its affiliates rely on MCMA’s partners’ active participation in, and experience with, credit markets to gain understanding of transaction sourcing, investing, operating and exit opportunities. As an integrated business, MCMA’s structured credit fixed income, structured debt and securitized product businesses are operated on an integrated investment platform with no information barriers.

(ii)

Flexible Approach to Investing Across Market Cycles. MCMA has consistently invested capital throughout economic cycles by focusing on opportunities that it believes are often overlooked by other investors. Its expertise in credit markets, focus on core industry sectors, and investment experience allows MCMA to respond quickly to changing environments. MCMA pays close attention to the cycles core industry sectors are experiencing and is opportunistic in entering and exiting investments when the risk/reward profile is in MCMA’s favor.

In addition, subject to a Fund’s Governing Documents, a Client’s investment portfolio has contained and may, in the future, contain securities issued by publicly held companies. Client strategies involve a high degree of uncertainty. The possibility of partial or total loss of capital will exist in connection with such strategies, and investors should not invest unless they can readily bear the consequences of such loss. Risk of Loss An investment in a Fund involves a high degree of risk, relating to both the types of investments

contemplated by a Fund as well as the Fund’s ability to achieve its investment objectives, and therefore should only be undertaken by qualified investors whose financial resources are sufficient to enable them to assume the risks and to bear the loss of all of their investment. There can be no assurance that a Fund will be able to implement its investment strategy, generate returns or return any capital. The following risk factors are those generally applicable to MCMA’s Clients but are not meant to be an exhaustive list of all of the potential risks associated with an investment in a Fund. Additional risk factors, including risk factors that are specific to a particular Client’s investment strategy, may be described in each Client’s applicable Governing Documents and/or offering documents. The order in which these risks are presented is not intended to represent the relative magnitude of any particular risk. Business Risks. Investments involve a high degree of business and financial risk, which could result in substantial losses to a Client. In particular, these risks could arise from changes in the financial condition or prospects of the entity in which the investment is made, changes in national or international economic and market conditions, and changes in laws, regulations, fiscal policies, or political conditions of countries in which investments are made, including the risks of war and the effects of terrorist attacks on security operations. The possibility of partial or total loss of capital will exist. Middle Market Companies. Subject to a Client’s applicable Governing Documents, a Fund may invest in private loans to middle market companies. While MCMA believes that such investments can provide an attractive risk adjusted return, investments in such companies involve higher risks in some respects than do investments in larger companies. Loans to middle market companies may carry more inherent risks than loans to larger, publicly-traded entities. For example, there is generally no publicly available information about privately-owned middle market companies and some obligors may not meet net income, cash flow and other coverage tests that may be imposed by certain lenders. Further, middle market companies that are obligors of below investmentgrade loans may be highly leveraged. These companies generally have more limited access to capital and higher funding costs, may be in a weaker financial position, may need more capital to expand or compete, and may be unable to obtain financing from public capital markets or from traditional sources, such as commercial banks. These companies frequently have shorter operating histories, narrower product lines and smaller market shares than larger businesses, which render them more vulnerable to competitors’ actions and market conditions, as well as general economic downturns. Accordingly, loans made to middle market companies may involve higher risks than loans made to larger companies that have greater financial resources or are otherwise able to access traditional credit sources. These risks may be particularly acute with respect to technology, software and other service companies that may be asset light. Early-Stage Companies. Subject to a Client’s applicable Governing Documents, a Fund may occasionally make loan investments in early-stage opportunities. Such investments are subject to risks, including those related to uncertain growth and/or cash flows of the target companies. If an early-stage portfolio company is unable to generate adequate cash flows, a Fund may suffer a partial or total loss of capital invested in such portfolio company, which could adversely affect the returns of such Fund. Nature of Investments; Inherent Illiquidity and Volatility. Although Clients’ investments are expected to be primarily secured, some investments may be unsecured and subordinated to substantial amounts of senior indebtedness, all or a significant portion of which may be secured and bear floating interest rates. In the event that any portfolio company cannot generate adequate cash flow to meet debt service, Clients may suffer a partial or total loss of capital invested in the portfolio company, which could adversely affect the returns of Clients. Furthermore, the companies and securities in which Clients will invest generally will not be rated by a credit rating agency, and if they were rated, they could be lower rated. Non-rated debt instruments and securities are subject to greater risk of loss of principal and interest than higher-rated debt instruments and securities with higher ratings in the case of deterioration of general economic conditions. The market for lower-rated and comparable non- rated debt instruments and securities is thinner, often less liquid, and less active than that for higher-rated and comparable non- rated debt instruments and securities,

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As discussed in Item 4 of this Brochure, MCMA provides discretionary portfolio management and investment advisory services to privately-offered pooled investment vehicles, including private investment funds, SIFs, CLO Funds, CFO Funds, and other U.S. and non-U.S. structured investment vehicles, whose investors include large institutions and high net worth individuals, including but not limited to, state and local pensions, corporate pensions, endowments and foundations, insurance companies, regional banks and family offices. MCMA also provides discretionary portfolio management and investment advisory services to a limited number of SMA Clients. Each Fund’s minimum investment amount is stated in each respective Fund’s Governing Documents. Each Fund’s respective General Partner may waive the applicable minimum at their discretion subject to applicable law. In addition, MCMA reports its minimum investment limits required of an investor for each Fund in Schedule D, Section 7.B.(1) – Private Fund Reporting of Part 1 Form ADV, which is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for MCMA is 157073. Generally, investors participating in the Funds are required to meet certain suitability and net worth qualifications, such as being (1) either (i) an “accredited investor” within the meaning of Rule 501(a)(1), (2), (3) or (7) of Regulation D under the Securities Act of 1933, as amended (the “Securities Act”) and are also a “qualified purchaser” as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “1940 Act”); or (ii) a non-U.S. person in accordance with the requirements of Regulation S under the Securities Act and applicable eligibility requirements of the respective Fund; and (2) meeting other eligibility requirements in accordance with any other applicable law. As such, the Funds MCMA manages are exempt from registration as an investment company through the exemption provided by Section 3(c)(7) of the 1940 Act.

As discussed in Item 5 above, each respective Fund’s General Partner or its designee generally receives Performance-Based Compensation (e.g., carried interest, performance allocations, incentive allocations, performance fees or incentive fees) in connection with the management of the Fund. The specific payment terms and other conditions of the Performance-Based Compensation available to a General Partner are set forth in the applicable Fund’s Governing Documents, side letters and/or fee agreements. The receipt of Performance-Based Compensation from Funds may create an incentive for MCMA to make riskier or more speculative investments on behalf of Funds than they might otherwise make in the absence of such Performance-Based Compensation. Performance-Based Compensation may also incentivize MCMA to overvalue assets to increase the amount of its Performance-Based Compensation. The performance on which Performance-Based Compensation are calculated may, in certain circumstances, include unrealized appreciation and depreciation of investments that may not ultimately be realized and as a result may create an incentive for MCMA to time investments, and the realization of investments, so as to maximize Performance- Based Fees rather than the returns of the Fund. Similarly, the Management Fee rates charged to Funds by MCMA vary. Different Management Fee rates may incentivize MCMA to dedicate increased resources and allocate more profitable investment opportunities or best investment ideas to Funds who are charged Management Fees (or Performance-Based Compensation arrangements) that are more profitable for MCMA. Further, MCMA may be incentivized to allocate investment opportunities to Funds who either pay Performance-Based Compensation or a higher Performance-Based Compensation rates to their respective General Partners or to Funds whose current performance does not require them to reimburse investors for losses attributable to prior unprofitable investments before distributing carried interest to their General Partners. Performance fees and/or carried interest are only charged to “qualified clients” in accordance with Rule 2053 under the Advisers Act. In the future, not all compensation arrangements will necessarily include a performance component, and the rate and nature of the calculation of performance compensation may vary. SPECIFIC CONFLICTS OF INTEREST AND MCMA’S PRACTICES DESIGNED TO MITIGATE SUCH CONFLICTS OF INTEREST Like all investment advisers who advise multiple accounts or funds having different fee structures, MCMA and its personnel face actual and potential conflicts of interest, including an incentive to favor those Funds in which MCMA or its personnel have greater pecuniary interests over other Funds managed by MCMA. Such conflicts of interest and MCMA’s practices that are designed to mitigate such conflicts of interest are discussed below. As a general matter, MCMA addresses such conflicts by following a thorough, detailed, and consistent investment decision-making process and by regular reviews of investments by MCMA’s investment staff. See “Potential Conflicts of Interest” under Item 11 below for additional information on potential and actual conflicts of interest.

Affiliated Broker-Dealers__ An affiliate of MCMA has filed an application to register as a broker-dealer with the SEC and to be a member firm of FINRA, Inc. See “Potential Conflicts of Interest – Future Affiliated Brokers” under Item 11 below for additional information. Affiliated CPO and/or CTA MCMA and its management persons are registered as a commodity pool operator. Affiliated Investment Advisers Monroe Capital BDC Advisors, LLC Through common control, MCMA is affiliated with Monroe Capital BDC Advisors, LLC (“MC Advisors”), an investment adviser registered with the SEC under the Advisers Act. MC Advisors serves as the investment advisor to three (3) business development companies: (i) Monroe Capital Corporation (“MC Corporation”) (NASDAQ: MRCC), a publicly traded 4 business development company; (ii) Monroe Capital Income Plus Corporation (“MC Income Plus”), a perpetual life, privately offered business development company s; and (iii) Monroe Capital Enhanced Corporate Lending Fund (“MLEND”), a perpetual-life, continuously offered, non-traded business development company. e MC Corporation, MC Income Plus and MLEND are collectively referred to herein as the “BDCs”. MCMA and MC Advisors currently share the same physical location and certain supervised persons. MC Advisors is wholly owned by MC Intermediate Holdco, which is in turn majority-owned by Momentum US Bidco (a majority-owned subsidiary of Wendel), and minority-owned by MC Investment Holdings. Messrs. Theodore L. Koenig, Mick Solimene, and Michael J. Egan, each of whom is a principal and Investment Committee member of MCMA, serve as investment committee members for MC Advisors, pursuant to a staffing agreement (the “Staffing Agreement”) between MCMA and MC Advisors. Under the terms of the Staffing Agreement, MCMA’s Investment Committee members provide MC Advisors services to enable MC Advisors to undertake and perform its business activities as an investment adviser to the BDCs. Such services include, the identification and analysis of investment opportunities, evaluation (conducting research and due diligence on prospective investments), structuring, monitoring, negotiation and conclusion of investment transactions, and monitoring of investments. Mr. Theodore L. Koenig is the Chairman and Chief Executive Officer of each respective BDC. Mr. Mick Solimene is the Chief Financial Officer and Chief Investment Officer of each respective BDC and also currently serves as managing director of MCMA. Both Messrs. Koenig and Solimene serve as interested board of directors for each respective BDC. In addition to the Staffing Agreement, MCMA provides the BDCs administrative services pursuant to administration agreements (the “Administration Agreements”) between MCMA and each respective BDC. Under the terms of the Administration Agreements, MCMA provides the BDCs office facilities and equipment and clerical, bookkeeping and record keeping and other administrative services at such facilities. Additionally, under the Administration Agreements, MCMA performs, and/or oversees the performance of, the BDCs’ required administrative services, which include, among other things, being responsible for preparing and maintaining the BDCs’ financial books and records, preparing stockholder reports and reports filed with the SEC. MCMA also assists in determining and publishing the BDCs’ net asset values, oversees the preparation and filing of tax returns, prints and disseminates reports to the BDCs’ stockholders and generally oversees the payment of the BDCs’ expenses and the performance of administrative and professional services rendered to the BDCs by others. MCMA also provides, on the BDCs’ behalf, managerial assistance to those portfolio companies that have accepted the BDCs’ offer to provide such assistance.

In consideration for the services provided to MC Advisors under the Services Agreement, MCMA does not receive any compensation. However, MCMA is reimbursed by MC Advisors for the out-of-pocket costs and expenses directly incurred in performing its obligations under the terms of the Services Agreement. In consideration for the administrative services provided to the BDCs under the Administration Agreements, MCMA does not receive any compensation. However, MCMA is reimbursed by each respective BDC for any out-of-pocket costs and expenses directly incurred in performing its obligations under the terms of the Administration Agreements, which generally are equal to an amount based on each respective BDC’s allocable portion of MCMA’s overhead in performing its obligations under the Administration Agreements, including rent, and the allocable portion of the cost of the BDCs’ Chief Financial Officer and Chief Compliance Officer and their respective staffs. In general, MCMA expects to conduct its activities in a manner that is separate and independent from the activities of MC Advisors. However, as stated above, certain of MCMA’s principals and employees provide investment advisory and other services and engage in various activities with respect to MC Advisors and its advisory clients, the BDCs. Additionally, MC Advisors’ advisory clients could from time to time invest in the same financial instruments or engage in the same or similar investment strategies as MCMA and/or its Clients. These activities could conflict with the transactions and strategies employed by MCMA and its employees and affiliates in managing Clients and could raise various other actual or potential conflicts of interest. Moreover, the time and effort of MCMA’s principals, Investment Committee members and other investment personnel and various other employees will not be devoted exclusively to MCMA’s business or the business of its Clients but will be allocated among MCMA, its Clients and MC Advisors and its clients, the BDCs. MCMA and MC Advisors address these and other conflict of interest by providing in its Code of Ethics that all supervised persons have a duty to act in the best interests of each Client and by providing training to supervised persons with respect to conflicts of interest and how such conflicts are resolved under MCMA’s and MC Advisors’ written policies and procedures. Additional information about Monroe Capital BDC Advisors, LLC can be found in its respective Form ADV which can be found at www.adviserinfo.sec.gov. Horizon Technology Finance Management LLC MCMA has been registered as an investment adviser with the SEC under the Advisers Act since March 22, 2012, and is a Registered Commodity Pool Operator and an Exempt Commodity Trading Advisor with the National Futures Association. MCMA and its affiliates provide fundraising and marketing advice and services to HTFM, which may indirectly benefit Clients of HTFM. MCMA and its affiliates do not receive compensation for their advice and services. In general, HTFM expects to conduct its business and activities in a manner that is separate and independent from MCMA and its affiliates. However, as mentioned above, certain of HTFM’s principals, including Messrs. Koenig and Egan, are also principals of MCMA. To address any potential conflicts of interest that may arise, HTFM has adopted policies and procedures to resolve potential conflicts of interest in accordance with all applicable regulatory requirements and its fiduciary obligations to Clients. Affiliated Relying Advisers As stated in Item 4 of this Brochure, MCMA is affiliated with the Relying Advisers. Each Relying Adviser is registered with the SEC as investment advisers relying on MCMA’s investment adviser registration with the SEC pursuant to Rule 203A-2(b) of the Advisers Act and the SEC’s ABA No-Action Letter. Each Relying Adviser intends to conduct their activities in accordance with the Advisers Act and the rules thereunder.

Set forth below are the Relying Advisers: 1. Monroe Capital Management, LLC 2. Monroe Capital Asset Management LLC 3. Monroe Capital CLO Manager LLC 4. Monroe Capital CLO Manager II LLC 5. Monroe Capital Partners Fund Advisors, Inc. 6. Monroe Capital Real Estate Credit Advisors, LLC

Affiliated General Partners As stated in Item 4 of this Brochure, MCMA does not act as a general partner for any of its Clients. Instead, certain affiliates of MCMA, serve as a general partner to one or more of MCMA’s Clients and are regularly engaged in the business of sponsoring such Clients. In connection with such services, the applicable General Partner of each respective Client may receive Performance-Based Compensation (e.g., carried interest) described above in Item 5 of this Brochure. The specific payment terms and other conditions of the Performance-Based Compensation available to a General Partner are set forth in the applicable Client’s Governing Documents, side letters and/or fee agreements. Through common control, MCMA is affiliated with each Client’s respective General Partner. Additionally, as described above in Item 6 of this Brochure, the receipt of Performance-Based Compensation from Clients may create an incentive for the General Partners to cause such Clients to make riskier or more speculative investments than they would otherwise make in the absence of Performance-Based Compensation. Performance-Based Compensation also may incentivize the General Partners to overvalue assets in order to increase the amount of its Performance- Based Fees. Moreover, the performance on which Performance-Based Compensation are calculated may, in certain circumstances, include unrealized appreciation and depreciation of investments that may not ultimately be realized and as a result may create an incentive for the General Partners to time investments, and the realization of investments, so as to maximize Performance-Based Compensation rather than the returns of Clients. Lastly, each Client’s respective General Partner may be required to return excess amounts of Performance- Based Fees as a “clawback,” pursuant to the Client’s applicable Governing Documents. This clawback obligation may create an incentive for a General Partner to defer disposition of one or more investments or delay the liquidation of a Client if the disposition and/or liquidation would result in a realized loss to the Client or would otherwise result in a clawback situation for the General Partner. MCMA addresses these conflicts of interest by providing in its Code of Ethics that all supervised persons have a duty to act in the best interests of each Client, providing training to supervised persons with respect to conflicts of interest and how such conflicts are resolved under MCMA’s written policies and procedures. Affiliated Loan Origination and/or Servicing Businesses Affiliates of MCMA and certain MCMA Clients and/or their portfolio companies may be engaged in the loan origination and/or servicing businesses. In connection with their lending activities, such loan origination and/or servicing businesses may receive certain fees, including, director’s fees, commitment fees, investment banking fees, financial consulting fees, break-up fees, termination fees, closing fees, collateral monitoring fees, debt placement fees and other similar fees received as part of such loan origination and/or servicing businesses. Such fees may be charged on a cost reimbursement or on a costplus basis. The Client or the issuers of financial instruments held by the Client may acquire loans originated, structured, arranged and/or placed and/or arranged by such affiliated loan origination and/or servicing businesses and in respect of which such businesses receive fees. To the extent set forth in the Governing Documents of a Client, some or all of these fees will not be applied to reduce Management Fees or other fees payable by the Client or any of its investments or otherwise directly or indirectly benefit the Client or any of its investors. Such fees will otherwise be borne by the Client or by the issuers of financial instruments held by the Client. See Item 5 – Fees and Compensation of this Brochure for more information regarding Transaction Fees and Management Fee Offsets. Selection of Service Providers Except as may otherwise be provided under the terms of a Client’s Governing Documents, MCMA or one or more of its affiliates will generally select Clients’ service providers and will determine the compensation of such providers without review by or the consent of an advisory committee, the investors or an independent party. Clients, regardless of the relationship to MCMA, its affiliates or the person performing the services, bear the fees, costs and expenses related to such services. This may create an incentive for MCMA or an applicable affiliate to select an Affiliated Service Provider or to select service providers based on the potential benefit to MCMA, rather than to Clients. For example, MCMA may select service providers that use its or

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Personal Trading MCMA maintains a policy of strict compliance with the highest standards of ethical business conduct and the provisions of applicable federal securities laws, including rules and regulations promulgated by the SEC, and has adopted policies and procedures described in its Code of Ethics. The Code of Ethics has been adopted by each of MCMA, MC Advisor, and the BDCs in compliance with Rule 17j-1 under the 1940 Act and Section 204A of the Advisers Act. The Code of Ethics applies to each employee of MCMA and any other “access person” as defined under the Advisers Act. It is designed to ensure compliance with legal requirements of MCMA’s standard of business conduct. A complete copy of MCMA’s Code of Ethics is available to any Client or prospective Client upon request. The Code of Ethics is based upon the premise that all MCMA personnel have a fiduciary responsibility to render professional, continuous and unbiased investment advisory services. The Code of Ethics requires all personnel to: (i) comply with all applicable laws and regulations; (ii) observe all fiduciary duties and put Client interests ahead of those of MCMA; (iii) observe MCMA’s personal trading policies so as to avoid “front-running” and other conflicts of interests between MCMA and its Clients; and (iv) ensure that all personnel have read the Code of Ethics, agreed to adhere to the Code of Ethics, and are aware that a record of all violations of the Code of Ethics will be maintained by MCMA’s Chief Compliance Officer, and that personnel who violate the Code of Ethics are subject to sanctions by MCMA, up to and including termination. Standards of Conduct: MCMA and its access persons are expected to comply with all applicable federal and state laws and regulations. Access persons are expected to adhere to the highest standards of ethical conduct and maintain confidentiality of all information obtained in the course of their employment and bring any risk issues, violations, or potential violations to the attention of the Chief Compliance Officer. Access persons are expected to deal with Clients fairly and disclose any activity that may create an actual or potential conflict of interest between them and MCMA or Client. Ethical Business Practices: Falsification or alteration of records or reports, also known as a prohibited financial practice, or knowingly approving such conduct is prohibited. Payments to government officials or government employees are prohibited except for political contributions approved by MCMA’s Chief Compliance Officer or designee. MCMA seeks to outperform its competition fairly and honestly and seeks competitive advantages through superior performance not illegal or unethical dealings. Access persons are strictly prohibited from (i) participating in online blogging and communication with the media, unless approved by the Chief Operating Officer or the Chief Compliance Officer, and (ii) spreading of false rumors pertaining to any publicly traded company. Confidentiality: Employees must maintain the confidentiality of MCMA’s proprietary and confidential information and must not disclose that information unless the necessary approval is obtained. MCMA has a particular duty and responsibility, as investment adviser, to safeguard Client information. Information concerning the identity and transactions of investors is confidential, and such information will only be disclosed to those employees and outside parties who may need to know it in order to fulfill their responsibilities. Gift and Entertainment Policy: Access persons shall not, directly or indirectly, take, accept or receive gifts or other consideration in merchandise, services or otherwise of more than nominal value from any person, firm, corporation, association or other entity other than such person’s employer that does business, or proposes to do business, with MCMA or any of its affiliates.

Personal Trading Personal Trading Policy: Access persons may not purchase or otherwise acquire direct or indirect beneficial ownership of any covered security, and may not sell or otherwise dispose of any covered security in which he or she has direct or indirect beneficial ownership, if he or she knows or should know at the time of entering into the transaction that: (i) a Client has purchased or sold the covered security within the last 15 calendar days, or is purchasing or selling or intends to purchase or sell the covered security in the next 15 calendar days; or (ii) MCMA has within the last 15 calendar days considered purchasing or selling the covered security for any Client or within the next 15 calendar days intends to consider purchasing or selling the covered security for any Client. Access persons must obtain approval from the Chief Compliance Officer or his designee before directly or indirectly acquiring beneficial ownership in any securities in an initial public offering or in a limited offering (including, private placements). No access person shall recommend any transaction in any covered securities by Clients without having disclosed to the Chief Compliance Officer his or her interest, if any, in such covered securities or the issuer thereof, including: (i) the access person’s beneficial ownership of any covered securities of such issuer; (ii) any contemplated transaction by the access person in such covered securities; (iii) any position the access person has with such issuer; and (iv) any present or proposed business relationship between such issuer and the access person (or a party in which the Access Person has a significant interest). Access persons are prohibited from buying or selling shares issued by the MC Corporation except during an open trading window announced by MC Corporation’s Chief Compliance Officer. Except with the express written consent of MC Corporation’s Chief Compliance Officer, all access persons are prohibited from buying or selling options on, or futures or other derivatives related to, shares issued by MC Corporation, and are likewise prohibited from selling short shares of MC Corporation. Prohibition against Insider Trading: MCMA forbids any access person from trading, either personally or on behalf of others, including Clients advised by MCMA, on material non-public information or communicating material non-public information to others in violation of the law or duty owed to another party. This conduct is frequently referred to as “insider trading”. The concepts of material non-public information, penalties for insider trading, and processes for identifying insider trading are addressed in detail in the Compliance Manual and Code of Ethics. Reporting Requirements: In compliance with SEC rules, access persons are required to disclose all of their personal brokerage accounts and holdings within 10 days of initial employment with MCMA, within 10 days after the end of each calendar quarter of opening a new account, and annually thereafter. Additionally, the last day of the month following each quarter-end, all access persons must report all transactions in reportable securities over which the access person had any direct or indirect beneficial ownership. Access persons are also required annually to affirm all reportable transactions from the prior year. Privacy and Confidentiality Privacy Policy: MCMA has adopted a privacy policy that explains the manner, in which MCMA collects, utilizes and maintains nonpublic personal information about Clients and Clients’ investors. MCMA recognizes and respects the privacy concerns of potential, current and former Clients and Clients’ investors. MCMA is committed to safeguarding this information. As a member of the financial services industry, MCMA will provide this Privacy Policy for informational purposes to Clients, Clients’ investors and employees and will distribute and update it as required by law. A complete copy of MCMA’s Privacy Policy is available to any Client or prospective Client upon request. Collection of Information and Disclosure of Nonpublic Personal Information: To provide investors with effective service, MCMA may collect several types of nonpublic personal information about investors, including: (i) information from forms that investors may fill out, such as subscription forms, questionnaires and other information provided by investors in writing, in person, by telephone, electronically or by any

other means. This information includes name, address, nationality, tax identification number, and financial and investment qualifications; (ii) information investors may give orally; (iii) information about transactions within MCMA, including account balances, investments and withdrawals; (iv) information about the amount investors have invested, such as initial investment and any additions to and withdrawals from an investment in the Clients; and (v) information about any bank accounts investors may use for transfers to or from accounts (if applicable). Disclosure of Nonpublic Personal Information: MCMA does not sell or rent Client investor information. MCMA uses this information to conduct business with its Clients: to develop or enhance its products and services; to understand the financial needs of its Clients so that MCMA can provide such Clients with quality products and superior service; and to protect and administer its Clients’ records, accounts and funds. MCMA does not disclose nonpublic personal information about its investors to nonaffiliated third parties, except as permitted or required by law. For example, MCMA may share nonpublic personal information in the following situations: (i) to service providers in connection with the administration and servicing of MCMA and its Clients; this may include attorneys, accountants, auditors and other professionals. MCMA may also share information in connection with the servicing or processing of investor transactions; (ii) to affiliated companies in order to provide investors with ongoing personal advice and assistance with respect to the products and services investors have purchased through MCMA and to introduce investors to other products and services that may be of value to such investors; (iii) to respond to a subpoena or court order, judicial process or regulatory authorities; (iv) to protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; and (v) upon consent of an investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor. Protection of Client Information: MCMA’s policy is to require that all employees, financial professionals and companies providing services on its behalf keep Client and investor information confidential. MCMA maintains safeguards that comply with federal standards to protect Client and investor information. MCMA restricts access to the personal and account information of Clients and investors to those employees who need to know that information in the course of their job responsibilities. Third parties with whom MCMA shares Client or investor information must agree to follow appropriate standards of security and confidentiality. MCMA’s privacy policy applies to both current and former Clients and investors. MCMA may disclose nonpublic personal information about a former Client to the same extent as for a current Client. Potential Conflicts of Interest General: Client investors should be aware that there will be situations where the applicable General Partner, MCMA and their respective affiliates may encounter potential conflicts of interest in connection with Clients’ activities. The following discussion enumerates certain potential and actual conflicts of interest between the applicable General Partner, MCMA and their affiliates on the one hand, and the Client or Client investors on the other. By acquiring an interest in a Client, each Client investor will be deemed to have acknowledged the existence of such actual and potential conflicts of interest and to have waived any claim with respect to the existence of such actual and potential conflicts of interest. Pursuant to a Private Fund’s relevant Governing Documents, a Private Fund advisory committee will typically be established and the applicable General Partner or an affiliate thereof may, in certain situations, choose to seek the approval of, and/or consult with, such committee with respect to conflicts of interest. A Fund’s Governing Document will typically also permit the applicable General Partner or an affiliate thereof to choose to seek the approval of Client investors with respect to conflicts matters specified therein or certain other conflict situations. In such event, interests of the applicable General Partner and its affiliates will be disregarded. If the applicable General Partner, in its sole discretion, seeks any approval by the advisory committee or Fund investors, such approval will be binding upon the Fund and all investors. Independence of Wendel Platform: Wendel, the majority-owner of MCMA and the Monroe Group (as defined below), is a publicly traded company with a leading global alternative asset management platform,

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Generally, MCMA receives discretionary investment authority from its Clients at the outset of an investment advisory relationship. Subject to the investment objectives, policies and restrictions of each Client as set forth in their respective Governing Documents, MCMA has discretionary authority to determine the type, amount, and price of securities and investments to be bought and sold on behalf of each Client, including the selection of, and if applicable commissions paid to, counterparties. Counterparty Selection MCMA seeks to execute transactions on behalf of its Clients in a manner that is fair and equitable to all Clients, and to exercise diligence and care throughout the transaction process. In placing portfolio transactions, MCMA uses reasonable diligence to ascertain the “best” market price for all securities bought or sold in that market so that the price to the Client is as favorable as possible under prevailing market conditions. The determinative factor is whether the transaction represents the best qualitative execution for the Client and not whether the lowest possible commission cost is obtained. MCMA considers the full range of quality of the broker’s service in selecting brokers to meet best execution obligations and may not pay the lowest commission rates available. MCMA generally takes the following factors into account in selecting brokers for portfolio transactions: (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 affected, taking into account the size of order and difficulty of execution;

(iii)

the financial strength, integrity and stability of the broker;

(iv)

the broker firm’s risk in positioning a block of securities;

(v)

the quality, comprehensiveness and frequency of available research services considered to be of value; and

(vi)

the competitiveness of commission rates in comparison with other brokers satisfying MCMA’s other selection criteria.

MCMA may not weigh any of these factors equally. MCMA primarily pursues investment transactions on behalf of its Clients in securities issued by privately held middle market companies, which primarily consist of senior and junior secured and unsecured loans, unitranche loans and other asset-based loans, leasing loans, receivables loans, consumer loans, mezzanine loans, stressed and distressed debt, investment and non-investment grade credit, structured debt and equity, warehouse loan facilities, securitized debt and subordinated notes of collateralized loan obligations and other types of securitized debt tranches of middle market companies. Transactions in such securities are typically privately negotiated and will not require the use of brokers or the payment of brokerage commissions. However, in certain circumstances an assignment fee may be charged by the administrative agent for a particular loan, and fees may be payable when buying and selling bank loans. Soft-Dollars Arrangements As of the date of this Brochure, MCMA does not engage in soft dollar arrangements, including participate in any soft dollar relationships with other firms for research or any other service. Section 28(e) of the Exchange Act is a “safe harbor” that permits an investment manager to use commissions or “soft dollars” to obtain research and brokerage services that provide lawful and appropriate assistance in the investment decision-making process. MCMA will limit the use of “soft dollars” to obtain research and brokerage services to services which constitute research and brokerage within the meaning of Section 28(e).

Brokerage for Client Referrals MCMA does not consider, in selecting a broker-dealer, whether MCMA or an affiliate receives Client or investor referrals from that broker-dealer. Directed Brokerage MCMA does not routinely recommend, request or require that a Client direct MCMA to execute transactions through a specified broker-dealer. Generally, MCMA does not accept Clients who require transactions be executed through a specified broker-dealer. However, Clients may recommend MCMA uses their preferred broker-dealer(s). MCMA will use such broker- dealer(s) subject to its determination that said broker-dealer provides best execution of the Client transactions. In a situation where a Client directs MCMA to place trades with a particular broker- dealer, MCMA may not be free to seek the best price, volume discounts or best execution by placing transactions with other broker-dealers. Additionally, as a result of directing MCMA to place trades with a particular broker-dealer, a disparity in commission charges may exist between the commissions charged to Clients who direct MCMA to use a particular broker-dealer and those Clients who do not direct MCMA to use a particular broker-dealer as well as a disparity among the brokers to which different Clients have directed trades. Order Aggregation If MCMA determines that the purchase or sale of the same security is in the best interest of more than one Client, MCMA may, but is not obligated to, aggregate orders in order to reduce transaction costs to the extent permitted by applicable law. When an aggregated order is filled through multiple trades at different prices on the same day, each participating Client will receive the average price with transaction costs allocated pro rata based on the size of each Client’s participation in the order (or allocation in the event of a partial fill) as determined by MCMA. In the event of a partial fill, allocations generally will be made pro rata based on the initial order, but may be modified on a basis that MCMA deems to be appropriate, including, for example, in order to avoid odd lots or de minimis allocations. This may result in allocations of certain investments on other than a pari passu basis.

MCMA does not receive any economic benefits, including sales awards or prizes, from non-clients for providing investment advice and other advisory services. In the event MCMA engages a third-party to solicit or refer advisory clients (each a “Solicitor”), such thirdparty client solicitation arrangements will be made in compliance with Rule 206(4)-1 of the Advisers Act (the “Marketing Rule”), which requires that, among other things, compensation to a Solicitor be made pursuant to a written agreement and, for third-party Solicitor arrangements, that the Solicitor provide to each person solicited for MCMA’s advisory services, a written disclosure statement and current copy this Brochure. Furthermore, MCMA has entered into and may enter into written agreements with and compensate nonaffiliated third-parties for referring investors into the Clients (i.e., the Funds) (each a “Placement Agent”). These Placement Agent arrangements will be fully disclosed to affected investors and will generally be consistent with the requirements of the Marketing Rule under the Advisers Act, which only applies to the solicitation of Clients and not investors. Generally, the terms of such arrangements will vary but call for MCMA to pay the Placement Agent a fee equal to a percentage of capital contributions, Management Fees, or a combination of such contributions or fees borne by each investor introduced to a Fund by the Placement Agent.

On July 20, 2023, the SEC published an order of settlement between it and MCMA relating to MCMA’s failure to timely file amended reports on Schedule 13G related to certain special purpose acquisition company (“SPAC”) related investments, to timely disclose conflicts of interest related to client investments in SPACs, and to adopt reasonably designed policies and procedures regarding its personnel’s ownership interests in SPAC sponsors. Without admitting or denying the findings, MCMA consented to the entry of the SEC’s order finding that MCMA violated Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder, and violated and caused violations of Section 13(d) of the Securities Exchange Act of 1934 and Rule 13-d-2 thereunder, and agreed to a cease-and-desist order against future violations of these provisions, a censure and a $1 million civil penalty.

MCMA’s Investment Committee has the responsibility to exercise and maintain prudent supervision and control of the Client’s portfolio of investments. As stated in Item 8 of this Brochure, the Investment Committee is responsible for overseeing the investment process from the origination of each investment transaction (including deal sourcing, underwriting and acquisition), through asset management and ultimately the realization of the investment. The Investment Committee periodically reviews and ensures the investment policies, guidelines, and objectives of the Client’s general investment strategy are achieved and attained per the Client’s Governing Documents. The Investment Committee maintains prudence and effectiveness of each portfolio investment of the Client and formulates and oversees the investment policies and management of the Client’s assets, and periodically reviews investment strategies and investment performance. In carrying out its duties the Investment Committee provides recommendations on investment opportunities through a stringent due diligence process to identify investment opportunities that meet the Client’s stated investment objective and goals; reviews individual investment performance and recommends changes when appropriate; and works closely with staff to ensure that the investment objectives are being met as stated in the Client’s Governing Documents. In monitoring a Client’s portfolio of investments, the Investment Committee ensures (i) the management of investments and capital actions are consistent and comply with attainment of the Client’s investment policy, objectives and strategy goals, and (ii) the Client’s portfolio is in compliance with legal and regulatory requirements. Nature and Frequency of Reporting MCMA will use commercially reasonable efforts to furnish to all Private Fund investors within 120 days after the Private Fund’s fiscal year end an audited, written annual report, which typically includes financial statements prepared in accordance with GAAP and certain other information related to the applicable Private Fund’s investments. The annual report is prepared and the delivery of it are intended to comply with the SEC’s custody rule, as described in more detail below in Item 15 of this Brochure. In addition, MCMA will cause annually the delivery of tax information necessary for the completion of income tax returns. On a quarterly basis, each Private Fund investor will be furnished with unaudited financial statements of the Private Fund. Private Fund investors will also receive a quarterly letter providing descriptive information concerning the Private Fund’s investment portfolio on a quarterly basis. With respect to the CLO Funds and/or CFO Funds, the independent trustees generally prepare monthly compliance reports for the CLO Funds and quarterly distributions reports for the CLO Funds and CFO Funds. Additionally, MCMA may prepare periodic investor letters, portfolio profile summaries and pro forma results to supplement and further clarify any trustee reports. MCMA also generally holds an annual meeting for investors.

While it is MCMA’s practice not to accept or maintain physical possession (i.e., custody) of any Client assets, MCMA may be deemed, under Rule 206(4)-2 of the Advisers Act (the “Custody Rule”), to have custody of the assets of certain Clients by virtue of its common control with the Clients’ respective General Partner and the authority the General Partner has over such Clients or their assets. In order to comply with the Custody Rule, MCMA utilizes the services of “qualified custodians” (e.g., banks) to hold and maintain all cash and securities of the Clients (except with respect to privately offered securities). In accordance with the Custody Rule, MCMA also (i) has engaged independent public accounting firms that are members of, and examined by, the Public Company Accounting Oversight Board (“PCAOB”) to conduct annual audits of each Client with assets over which MCMA is deemed to have custody; and (ii) distributes audited annual financial statements of such Clients, prepared in accordance with GAAP, to all investors within at least 120 days after the Client’s fiscal year end. In addition, upon the final liquidation of any such Client, MCMA will obtain a final audit and distribute audited financial statements prepared in accordance with GAAP with respect to such Client to all investors promptly after completion of the audit. Qualified custodians are not expected to provide account statements directly to investors in the Clients. With respect to the CLO Funds, MCMA is not deemed to have custody. MCMA’s Agency Account The loans held in MCMA Funds’ portfolios that are originated or otherwise sourced by MCMA are typically funded by a loan syndicate organized by MCMA (a “Loan Syndicate”). In most cases, MCMA serves as the administrative agent to such Loan Syndicates. The participants in a Loan Syndicate (the “Loan Syndicate Participants”) generally include MCMA and its affiliates, MCMA’s Clients, and other bank and non-bank lenders. As the administrative agent to the Loan Syndicates, MCMA performs the duties and responsibilities typically assigned to an administrative agent for and on behalf of each Loan Syndicate. Each Loan Syndicate’s credit agreement requires MCMA to follow negotiated guidelines or formulas regarding the movement of cash to and from the lenders and the borrower, as applicable, for the Loan Syndicate (e.g., the collection of loan proceeds from lenders and their disbursement to the borrower, as well as the use and distribution of payments received from the borrower). Accordingly, MCMA, in its capacity as the administrative agent, applies the terms of each credit agreement and has no authority to determine how the cash is used, allocated or disbursed. MCMA has established bank accounts in U.S. Dollar, Australian Dollar, Canadian Dollar, Euro and Great Britian Pounds (the “Agency Accounts”), with major banks that meets the definition of a “qualified custodian” under the Custody Rule, facilitates the movement of cash to and from the lenders and the borrowers, as applicable, for all of the Loan Syndicates. The Agency Accounts were opened by and are in the name of MCMA as agent for the Loan Syndicate Participants (i.e., the funds related to the Loan Syndicates are not held in separate accounts or sub-accounts for each Loan Syndicate Participant under the Loan Syndicate Participant’s name, but are commingled in the Agency Accounts). The qualified custodian of the Agency Accounts do not send Agency Account statements to the Loan Syndicate Participants. MCMA is deemed to have custody over Client assets in the Agency Accounts because of MCMA’s role as administrative agent to the Loan Syndicate Participants, which include our Clients. In such role, MCMA has access to, and authority over, monies in the Agency Accounts. Although MCMA has no authority to determine how the cash is used, allocated or disbursed. In light of the foregoing, MCMA relies on alternative means of complying with the Custody Rule based on

certain SEC guidance. By satisfying such requirements, MCMA’s dual activity as administrative agent and investment adviser, meet the conditions to be in compliance with Rule 206(4)-2(a)(1) and 206(4)-2(a)(3).

MCMA generally has discretionary authority to determine the type, amount and price of securities and investments to be bought and sold on behalf of each Client, including the selection of, and commissions paid to, broker-dealers. This discretionary authority is subject to the investment objectives, policies and restrictions as set forth in the Governing Documents of each such Client. For MCMA to assume such discretionary authority, each investor must complete the appropriate Client subscription documents or an Investment Management Agreement prior to the establishment of an advisory relationship granting such authority. Please see Item 16 of the HTFM’s brochure for a description of HTFM’s investment discretion.

Proxy Voting Authority MCMA specializes in fixed income securities and bank debt, and does not generally receive proxies for securities held in Client portfolios. However, should MCMA receive proxies for securities held in Client portfolios it understands and appreciates the importance of proxy voting and will generally manage the receipt of incoming proxies, maintain a log of all proxies, and place votes based on established policies and guidelines. In the course of exercising discretion to vote a proxy, MCMA will vote any such proxies in the best interests of the Clients and in accordance with the procedures outlined below (as applicable). Prior to voting any proxies, a senior member of the investment team, the designation of which may change from time to time, will determine if there are any conflicts of interest related to the proxy in question. If a conflict is identified, such senior member of the investment team will then make a determination (which may be in consultation with a third-party compliance consultant) as to whether the conflict is material or not. If no material conflict is identified pursuant to its set procedures, such senior member of the investment team will, following discussion with MCMA’s investment personnel, make a decision on how to vote the proxy in question. MCMA also has the flexibility to abstain from a particular proxy vote when it is determined to be in the best interest of investors. Please let MCMA’s Chief Compliance Officer know if you have any questions about these procedures or if you would like detailed information of how any proxies were actually voted. The Chief Compliance Officer can be contacted at (312) 258-8300 or info@monroecap.com. Please see Item 17 of HTFM’s brochure for a description of HTFM’s proxy voting procedures.

MCMA does not solicit prepayment of more than $1,200 in fees per Client six months or more in advance, and thus has not provided a balance sheet according to the specifications of 17 CFR Parts 275 and 279. There is no financial condition that is reasonably likely to occur that would impair MCMA’s ability to meet contractual commitments to Clients. MCMA has not been the subject of a bankruptcy petition during the past ten years.