Philadelphia Financial Management of San Francisco, LLC

TABLE OF CONTENTS Page

Material Changes ............................................................................................................................ i Advisory Business ......................................................................................................................... 1 Fees and Compensation ................................................................................................................ 1 Performance-Based FEES and Side-By-Side Management ........................................................ 3 Types of Clients ............................................................................................................................. 3 Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 3 Other Financial Industry Activities and Affiliations ................................................................... 8 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......... 9 Brokerage Practices ...................................................................................................................... 9 Review of Accounts ..................................................................................................................... 14 Client Referrals and Other Compensation................................................................................. 14 Custody......................................................................................................................................... 14 Investment Discretion................................................................................................................. 14 Voting Client Securities ............................................................................................................... 15 Financial Information ................................................................................................................. 15

ADVISORY BUSINESS Philadelphia Financial Management of San Francisco, LLC (“Philadelphia Financial,” “we,” “us,” or “our”) began operations in March of 2004. We provide discretionary investment advisory services to private investment funds that are structured as limited partnerships of which we are the sole general partner, or non-U.S. companies of which we are the investment manager. We refer to all of these investment funds collectively as the “Funds” or “clients.” At this time we do not manage assets for or provide investment advice to any clients other than the Funds, although we may in the future. Philadelphia Financial is principally owned by Jordan Hymowitz. We have full discretion to invest and trade the Funds’ assets. The Funds have broad investment mandates, with no contractual limitations on types of instruments in which we may cause them to trade or invest. We cause the Funds to invest and trade in a variety of securities, primarily U.S. and Canadian publicly traded securities of companies involved in the financial services sector. The Funds sell securities short, engage in some short-term trading, and may invest and trade in options, other derivatives and other instruments. We manage each Fund pursuant to the objectives specified in the materials by which the Fund offers its ownership interests to investors. We, as general partner, determine those objectives for the Funds that are limited partnerships. The boards of directors of the non-U.S. Funds have the authority to determine those objectives, subject to our agreement, and to supervise those Funds’ investment and trading activities. Our agreements with the Funds impose no limits on the types of securities or other instruments in which the Funds may invest, the types of positions they may take, the concentration of their investments by sector, industry, fund, country, class or otherwise, the amount of leverage they may employ or the number or nature of short positions they may take. The Funds’ investors do not have the right to specify, restrict, or influence their Funds’ investment objectives or any investment or trading decisions. Our investment decisions and advice with respect to each Fund will be subject to each Fund’s investment objectives and guidelines, as set forth in its respective offering documents. We do not participate in wrap fee programs. As of December 31, 2025, we managed approximately $730,032,684 in regulatory assets under management on a discretionary basis. We do not manage any non-discretionary assets. FEES AND COMPENSATION Compensation to Philadelphia Financial. Each Fund pays us a “management fee” at the beginning of each calendar quarter equal to 0.375% (1.5% per annum) of the value of investors’ holdings in the Fund (limited partner interests or shares). Each non-U.S. Fund also pays us, as an “incentive fee,” 20% of the increase in value of the outstanding Fund shares to the extent those increases exceed previous decreases in value (a “high water mark”). As general partner of each partnership Fund, we are specially allocated as an “incentive allocation” 20% of the increases in the limited partners’ capital account balances to the extent those increases exceed a similar “high water mark.” The Funds pay incentive fees and make incentive allocations at the end of each calendar year and at other times when Fund investors withdraw capital or, in the case of non-U.S. Funds, redeem shares, but then only in relation to the amount of capital withdrawn or shares redeemed. For each period and for each Fund, the foregoing fees and allocations are the aggregate of amounts calculated separately for each investor or group of investors in each Fund. They are not generally negotiable, but our agreements

with the Funds give us the authority to vary them for particular investors or in some cases to waive certain fees. The Funds pay our fees directly from their assets that we manage. Incentive allocations from partnership Funds take the form of increases in the value of our general partner interest in those Funds. Other Fees and Expenses. Each Fund pays all the expenses of its administration and operation, including those for:

brokerage commissions and other transaction-related services (see “Brokerage Practices” below); research; legal and auditing; accounting; administration; price validation; risk monitoring; investment related consultants and other service providers; preparation, duplication and distribution to investors and prospective investors of offering documents, annual reports and other financial information; and similar ongoing operational expenses.

The general partner and any affiliates retained by it will be reimbursed certain out-of-pocket expenses incurred on behalf of the Funds. Such reimbursable expenses shall not include any expense attributable to its provision of office personnel and space required for the performance of its services. The Funds do not currently pay custodial fees directly. Their assets are held by “prime brokers” as custodians. The Funds may be considered to pay for custodial services indirectly through: payments to the prime brokers of commissions and other transaction costs; payments of financing charges related to margin borrowings and stock loans; and the prime brokers’ ability to earn money on certain balances the Funds maintain with them (subject to laws and regulations governing their activities). Each Fund bears certain costs in connection with its organization and the initial offering and sale of ownership interests in it and continues to bear the costs of its ongoing offering of those ownership interests. Prepayment of Fees. The Funds pay management fees quarterly in advance. If we were to terminate our status as general partner of a partnership Fund or as investment manager of a non-U.S. Fund otherwise than as of the end of a quarter, we would refund to the Fund a portion of the management fee that was paid at the beginning of the termination quarter, pro rata for the portion of the quarter during which we were not the general partner or investment manager. Fund investors are generally allowed to withdraw capital or redeem shares as of the end of a calendar quarter, at which time there generally will be no prepaid fees. However, if an investor were allowed to withdraw or redeem at a time other than a calendar quarter-end, we would refund a portion of the management fee pro rata for the portion of the quarter after the effective time of the withdrawal or redemption. Other Compensation. We do not and our personnel do not accept compensation for the sale of securities or other investment products.

Please note that the information we provide in Item 5 is intended to be a general summary of fees charged and other general business practices of Philadelphia Financial in connection with the advisory services it provides. The description of fees and expenses provided in Item 5 are for summary purposes only and are supplemented and superseded in their entirety by the applicable offering documents for each fund. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Each non-U.S. Fund pays us a performance-based “incentive fee” and each partnership Fund allocates to us a portion of the increase in value of investors’ investments, as described above in “Fees and Compensation.” We do not manage any Funds that do not provide for performance-based profit participation. While we have the right to waive incentive fees or incentive allocations as to particular investors in a Fund, we manage each Fund’s assets as an undivided pool, so any such waiver would not give rise to incentives to favor any particular Fund over another. Our potential to receive incentive fees or allocations, and the fact that we will not have to refund any such fees or allocations if the Funds later experience losses, may create an incentive for us to make investments that are riskier or more speculative than would otherwise be the case. We manage pooled investment vehicles in which our related persons represent a significant portion of invested capital. Capital associated with out related persons is not charged any advisory fees, we are incentivized to realize gains in this account. The treatment of this account may create a conflict of interest to incentive gains in this account over the Funds. Please see Code of Ethics, Participation or Interest in Client Transactions and Personal Trading for more information about this account. TYPES OF CLIENTS We provide investment advice only to the Funds. They are privately-offered investment funds that are not regulated pursuant to Sections 3(c)(1) or 3(c)(7) of the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”). Each Fund imposes minimum investor qualification standards and minimum investment requirements. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Investment Objectives and Strategies We seek to achieve the Funds’ investment objective of maximizing total returns by investing primarily in the financial service industry. We invest predominantly (but not exclusively) in U.S. and Canadian publicly-traded securities of finance companies including: banks, thrifts, brokers, asset managers, insurance, mortgage, specialty finance, REITs, homebuilders, financial technology, and other financial intermediaries. Although the predominant emphasis is on the financial sector, we may invest a portion of the Fund’s assets in other sectors in which we have investment experience, such as the automotive sector. We take long positions primarily in undervalued small to medium sized companies we believe offer attractive investment opportunities while shorting those with what we consider deteriorating fundamentals, questionable accounting practices, or flawed business models. Although we have long-term views, when appropriate, we may cause the Funds to trade on a shortterm basis. Funds use leverage and stock options strategically in attempts to hedge positions and enhance returns. We occasionally invest in other diverse instruments, including private equity, distressed debt or securities of financial service companies.

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