Thomas J. Herzfeld Advisors, Inc.

General Description of Adviser and Principal Owners Thomas J. Herzfeld Advisors, Inc. (the “Firm” or “TJH”) is a Florida corporation that was formed in 1984. TJH maintains its principal office at 119 Washington Avenue, Suite 405, Miami Beach, FL 33139. The Firm is owned by Thomas J. Herzfeld, who currently owns 100% of the voting stock of the Firm. TJH employs approximately 15 persons engaged in portfolio management or investment research, investment operations, trading, client service, legal and compliance activities. Types of Advisory Services TJH currently offers investment advisory services in three primary strategies: 1) investment in closed-end funds, business development companies and interval funds; 2) investment in credit related instruments generally, including Collateralized Loan Obligations (CLOs) and CLO equity securities; and 3) investment in private credit related to commercial real estate development. Within the closed-end fund investment strategies, the advisor currently has eight (8) sub-strategies, all within its Managed (Composite) Portfolio Program: •

Herzfeld Balanced & Flexible Composite

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Herzfeld Fixed Income Composite

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Herzfeld Foreign Equity & Fixed Income Composite

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Herzfeld U.S. Equity Composite

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Herzfeld Tax-Exempt (Municipal Bonds) Composite

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Herzfeld Special Situations Composite

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Herzfeld Preferred Composite

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Herzfeld SPAC Portfolio

For additional information about these investment strategies please refer to Item 8. TJH provides investment advisory services directly to registered investment companies, private funds, and separately managed accounts. Additional information about these advisory services and the type of clients we serve is described immediately below and in Item 7. Registered Investment Companies TJH provides investment advisory services to the following investment company registered under the Investment Company Act of 1940 (the “Company Act”): Herzfeld Credit Income Fund, Inc.

(the “HERZ Fund” or the “Registered Fund”) (NASDAQ: HERZ), under an Investment Management Agreement between the HERZ Fund and the Firm. The HERZ Fund’s primary investment objective is maximizing risk adjusted total returns with a secondary objective of generating high current income for shareholders. The HERZ Fund seeks to achieve its investment objectives by investing in credit related instruments including equity and junior debt tranches of collateralized loan obligations, or CLOs. CLOs are portfolios of collateralized loans consisting primarily of below investment grade U.S. senior secured loans with a large number of distinct underlying borrowers across various industry sectors. Private Funds (the “Private Funds”) TJH provides investment advisory services to a series of private funds and their respective related entities as identified in the Firm’s Form ADV Part 1, including 1) a “master feeder” structure focused on investment in U.S. private credit that includes two master funds domiciled in the Cayman Islands (the “Master Fund”), an “offshore feeder fund” domiciled in the Cayman Islands, and an “onshore feeder fund” domiciled in Delaware, United States, 2) a U.S. domiciled private fund focused on investment in U.S. private credit, 3) a U.S. domiciled private fund focused on private credit investments in the U.S. commercial real estate industry, and 4) a Cayman domiciled private fund and related U.S. domiciled private fund focused on investment in private credit to U.S. BDCs. TJH also manage other private funds from time to time, including certain co-investment and other structures for the benefit of the Firm’s clients. Separately Managed Accounts (“SMAs”) TJH provides investment advisory services to a variety of separately managed account clients, including individuals, pension plans, high net worth individuals, charitable organizations, corporations, and institutional clients. Investment Strategies and Restrictions TJH manages the Registered Fund, Private Funds, and SMAs (together, “Clients”) based on each Client’s strategies, restrictions, and guidelines and does not tailor its advisory services to any particular Client except as described below. With respect to SMAs, TJH will consider each client’s risk tolerance, time horizon, tax status, liquidity needs, return objectives and preferences. TJH provides its investment advisory services in accordance with the specific investment objectives and restrictions of each client, in accordance with and subject to the directions, guidelines, and limitations imposed by the client through, as applicable, the investment management agreement, prospectus and statement of additional information, private placement memorandum, and/or other governing documents (the “Governing Documents”). TJH’s investment discretion with respect to managing the Registered Fund is also subject to the parameters provided by and oversight of the Registered Fund’s governing body (e.g., board of

directors/trustees). TJH’s investment discretion with respect to managing the Private Funds is also subject to the parameters provided by and oversight of each respective Private Fund’s governing body (e.g., board of directors/trustees, general partner, or managing member). Generally, the investment advice offered by the Firm is limited to the investment strategies described above. However, the Firm will manage other strategies at the specific request of a Client, subject to review and agreement on the type of strategy, applicable investment restrictions, minimum account size and agreement on fees. Wrap Fee Programs “Wrap arrangements,” “wrap fee programs,” and/or “wrap fee accounts” involve individuallymanaged accounts for individual or institutional clients. The wrap fee accounts are offered as part of a larger program by a “sponsor,” usually a brokerage, banking or investment advisory firm, and are managed by one or more investment advisers. TJH has arrangements with several brokerage, bank and/or investment advisory firms (sponsors) who sponsor “wrap fee” programs where TJH acts as adviser or sub-adviser to the wrap program and provides investment management services to those clients who select TJH as part of their investment program. The sponsor typically authorizes payment of a portion of its program fee to TJH for its services, which TJH receives directly from the wrap fee client. Generally, TJH’s management of wrap fee accounts and other accounts under the same investment strategy is consistent. Subject to our best execution policy when selecting brokers for trading for our wrap fee program accounts, TJH at its discretion may trade with different broker/dealers than for our other (non-Wrap) accounts or trade away with a single broker/dealer on a combined basis. Trades for wrap fee program accounts are typically directed to the wrap fee program sponsor (or its designated broker/dealer), since brokerage commissions are included in the wrap fee. In such situations, TJH may be required to trade a wrap fee program’s accounts separately from other accounts being managed within the same strategy. As described in “Item 12- Brokerage Practices”, while directed brokerage is designed to benefit the wrap fee program account through lower trading costs, there may be circumstances where directed trades do not receive the best price, or where dividing the trade into separate components may inhibit TJH’s ability to obtain the same level of or as timely an execution as it may otherwise have been able to obtain if it had been able to execute the entire trade with one broker/dealer. Operational limitations with these types of accounts make trading away from the sponsor difficult. To the extent that TJH trades away from the sponsor by placing trades with a different brokerage firm, the client will typically incur the costs associated with this trading, in addition to the wrap fees normally payable. Subject to these limitations, TJH continues to employ methods, such as trade rotation and periodic brokerage review, in an effort to reduce the impact of these issues. Clients who enroll in these programs should satisfy themselves that the sponsor is able to provide best price and execution of transactions. TJH may engage in wrap programs involving both single-contract and dual-contract accounts. In a single contract, the sponsor typically provides a level of research and due diligence on TJH and often stands as a co-fiduciary with TJH. Customers execute one contract with the sponsor. Dual contract programs require a customer to execute two separate contracts: one covering services

provided by the sponsor; and the other covering separate investment management services provided by TJH. With respect to single contract wrap fee program accounts, TJH may not be provided sufficient information by the wrap fee program sponsor to perform an assessment as to the suitability of TJH’s services and investment strategy for the client. In such cases, TJH will rely upon the wrap fee program sponsor who, as part of its fiduciary duty to each client, must determine not only the suitability of TJH’s services and investment strategies for the client, but also the suitability of the wrap fee program in general. In addition, TJH relies upon the wrap fee program sponsor to provide required disclosures to such clients, including delivery of this Form ADV Part 2A (Brochure) and, where applicable, Part 3 (CRS) to clients as required. Please see additional information regarding wrap fee programs in “Item 5 – Fees and Compensation.” Assets Under Management As of December 31, 2025, TJH managed assets of approximately $890 million. Of this amount, approximately $20 million was on a non-discretionary basis and approximately $870 million was on a discretionary basis. During the current reporting period, the Firm began providing advisory services to three additional private funds, which reported an aggregate of $92 million in gross assets in Section 7.B.(1) of Schedule D of the Firm's current Form ADV Part 1A. This amount includes approximately $23 million attributable to an intercompany financing arrangement between two of the funds, which is reflected in the reported gross assets of both.

Compensation earned by the Firm for the provision of investment advisory services to our clients is primarily comprised of management fees based on a percentage of assets under management during the investment period. In certain circumstances, the Firm charges performance fees for its services as further described herein. Fees and compensation are described within the Governing Documents for each client account that we manage. Except as noted below, all advisory fee invoices are sent to Clients at the end of each calendar quarter for services rendered in the prior quarter. Fees are deducted directly from Client custodial accounts if the Client has consented to such deductions in writing. Clients may request that fees not be automatically deducted and, depending upon the custodian used, the Firm seeks to accommodate those requests. For certain wrap fee program Clients, invoices related to advisory fees are sent directly to the wrap fee program sponsor and advisory fees are paid directly by the wrap fee program sponsor to the Firm. In such cases, no individual Client invoices are generated by the Firm. Note that management fees are generally calculated either by the custodian (in case of Registered

Fund accounts) or by the Administrator or TJH as per the Governing Documents (in the case of Private Funds or SMAs). TJH, through its Valuation Committee, oversees the valuation of securities. The Valuation Committee maintains procedures requiring, to the extent possible, pricing from an independent third-party pricing vendor as determined by its approved pricing hierarchy. The Valuation Committee also looks to other observable inputs for its valuations. If a vendor price or other observable inputs are unavailable or deemed unreliable, the Valuation Committee makes a reasonable determination of a security’s fair value. The following is a general description of fees typically charged by TJH for each type of client. However, some fees fall outside of the stated ranges, and fees may be negotiated in certain circumstances. Investors and clients should refer to the Governing Documents for complete information on fees and compensation. Advisory Fees for the Registered Fund In its capacity as investment manager to the HERZ Fund, TJH is entitled to receive an investment management fee in the amount of 1.25% of the Fund’s Managed Assets (gross assets less noninvestment liabilities) and an incentive fee of 10% of the Fund’s pre-incentive fee net investment income, for each calendar quarter subject to a 9.0% annualized hurdle rate, with a “catch-up” provision intended to provide the Adviser with an incentive fee of 10% on all of the Fund’s PreIncentive Fee net investment income as if a hurdle rate did not apply when the Fund’s net investment income exceeds 2.25% in any calendar quarter. The “catch-up” portion of the Fund’s pre-incentive fee net investment income is the portion that exceeds the 2.25% hurdle rate but is less than or equal to 2.5% in any calendar quarter. Registered Fund fees and expenses are described in the Registered Fund’s proxy materials, prospectus and statement of additional information. Advisory Fees for Private Funds In its capacity as investment manager to the Private Funds, TJH typically receives an investment management fee that ranges from 0.75% to 1.50% of the respective Fund’s net assets, depending upon share class and other factors applicable to specific investors. In addition, TJH is entitled in some cases to receive from the Private Funds’ investors a performance-based fee (also known as an incentive allocation) equal to a percentage (typically 10%) of the appreciation in an investor’s capital balance during the year, subject to various contingencies such as a hurdle rate, high water mark and/or other conditions. TJH Private Fund fees are described in more detail in each Private Fund Offering Memorandum and/or respective Limited Partnership Agreement or other Governing Documents. See Section 6 below for a description of Performance Based Fees. Advisory Fees for SMAs The basic fee schedule for separately managed accounts ranges from 0.50% to 1.50% of assets under management depending on product, asset type, and size of account. Generally, the fee schedule for separately managed accounts is fixed after negotiation with the client or the applicable wrap fee program sponsor and may be lesser or greater than the range set forth above depending upon a client’s specific requirements.

Fees are generally billed quarterly, in advance or in arrears, based on the market value of the account(s) as specified in the investment management agreement or other Governing Documents. In addition to securities, market values include cash, cash equivalents, accrued dividends and other income. If an account is opened or closed during a billing period, the advisory fees are pro-rated for that portion of the billing period during which the account was open. TJH may agree to certain fee reductions or waivers. Any such agreements are memorialized in writing. General Information Fees may vary from the applicable schedules above based on factors such as client type, asset class, pre-existing relationship, service levels, portfolio complexity, number of accounts, account size or other special circumstances or requirements and are negotiable in some cases. Some existing clients pay higher or lower fees than new clients. Related accounts may be aggregated for fee calculation purposes in certain circumstances. TJH will manage some accounts of TJH’s employees, affiliate employees, former employees, or their family members without an advisory fee. When TJH calculates fees, unless otherwise provided in a Client’s investment management agreement, valuations of account assets are determined in accordance with TJH’s valuation procedures, which generally rely on third party pricing services, but may permit the use of other valuation methodologies in certain circumstances. TJH’s determinations may differ from valuations reflected in a client’s custodial statements. Other Fees and Expenses TJH may invest in closed-end funds, open-end funds, exchange traded funds (ETFs), exchange traded notes (ETNs), and other pooled investment vehicles on behalf of its clients. When TJH invests client assets in such vehicles, unless otherwise agreed and where permitted by law, the client will bear its proportionate share of fees and expenses as an investor in such vehicles in addition to TJH’s investment advisory fees. TJH may, subject to applicable law and internal allocation policies, cause a Registered Fund, Private Fund, or account (each, a “Client”) to invest, directly or indirectly, in one or more other investment funds, special purpose vehicles, or other investment structures sponsored, managed, or advised by TJH or its affiliates (each, an “Affiliated Vehicle”). Such investments may be effected through co-investments, parallel investments, or other structures alongside or through other Clients. Participation in such opportunities will be determined by TJH in its discretion and in accordance with its allocation policies and procedures. TJH is under no obligation to offer any particular investment opportunity to any Client, and different Clients may be offered different opportunities, or may participate on different terms. These arrangements present conflicts of interest, including, without limitation, with respect to the allocation of investment opportunities, structuring considerations, timing of investments and dispositions, and the terms on which Clients participate. Investments by a Client in an Affiliated Vehicle may result in the imposition of fees and expenses at multiple levels, including at the Client level and at the level of the underlying Affiliated Vehicle. It is TJH’s policy to seek to mitigate the potential for duplicative management fees and performance-based compensation on the same invested capital; however, there can be no assurance

that duplication will be eliminated in all circumstances. Without limiting the foregoing: •

Management Fees. To the extent a Client invests in an Affiliated Vehicle that charges a management fee (or similar asset-based fee), TJH generally intends to implement a waiver, reduction, or offset of management fees at one level (either at the investing Client level or the Affiliated Vehicle level), such that substantially similar management fees are not charged on the same capital; provided, however, that the structure, timing, and mechanics of any such waiver, reduction, or offset will be determined by TJH in its discretion.

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Performance-Based Compensation. With respect to carried interest, incentive allocations, or other performance-based compensation, TJH generally intends to avoid the imposition of multiple layers of such compensation on the same gains. This may be achieved through structuring such compensation at a single level or through the application of offsets, credits, or other adjustments. The manner in which such mitigation is achieved may vary by investment and is not uniform across all Clients or Affiliated Vehicles.

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Expenses. Notwithstanding the foregoing, a Client investing in an Affiliated Vehicle will generally bear, directly or indirectly, its allocable share of fees and expenses at each level of the investment structure, including, without limitation, organizational expenses, administrative expenses, fund-level operating expenses, and transaction-related costs (e.g., diligence, legal, accounting, financing, and brokerage expenses), to the extent such expenses are not duplicative in nature.

TJH may have an incentive to structure investments through Affiliated Vehicles that charge fees or generate additional compensation to TJH or its affiliates. While TJH seeks to mitigate duplicative fees as described above, such conflicts of interest may result in Clients bearing higher aggregate fees and expenses than would be the case in a different structure. TJH will address such conflicts in accordance with its fiduciary duties, including its duty of loyalty and its obligation to seek to treat Clients fairly and equitably over time; however, “fair and equitable” treatment does not necessarily mean identical treatment, and different Clients may experience different fee structures, offsets, or overall economic outcomes. No assurance can be given that any particular fee waiver, offset, or reduction will be applied in any specific circumstance, or that any such measures will fully eliminate duplicative fees. TJH’s clients generally will incur brokerage and other transaction costs (which, in the case of wrap fee program clients, may be included in total costs charged to clients by wrap fee program sponsors). For additional information about brokerage practices and brokerage costs, please refer to Item 12. Neither TJH nor any of its supervised persons accepts compensation for the sale of securities or other investment products (other than indirectly through the management fees charged for TJH’s advisory services generally).

Methods of Analysis In general, the Firm invests in a) closed-end investment companies that primarily invest in equity and income-producing securities and b) other securities consistent with strategies that seek risk adjusted total return and current income. The investment methodology utilizes a number of factors and consists of both a quantitative and qualitative approach to identify opportunities across the entire universe of closed-end funds. The overall investment philosophy is predicated on recognizing the recurring valuation patterns found in the closed-end fund industry and the general credit industry, capitalizing on opportunities in a systematic manner. The closed-end fund strategy seeks to exploit the discount and premium spreads (i.e. Share Price to Net Asset Value differences) associated with closed-end funds. The Firm may also allocate assets to other investment company structures, including exchange-traded funds (“ETFs”), equity securities, including common and

preferred stocks (and with a particular emphasis on preferred stocks issued by registered investment companies), cash, and/or short-term cash equivalents. Once a security is identified for potential purchase or sale via both quantitative and qualitative analysis, approximately twenty other factors are analyzed (e.g. volatility, liquidity, yield, financial ratios, potential for dissident activity, portfolio earnings assessments, leverage and others). Other strategies may be employed by the Firm from time to time. In all cases, we employ fundamental and technical analysis designed to identify investment opportunities that are consistent with the particular strategy or strategies desired by our Clients. Investment Strategies General descriptions of TJH’s investment strategies are presented below. These descriptions are not intended to serve as specific guidelines. In addition, TJH may develop other investment strategies from time to time and manage portfolios according to a client’s specific investment guidelines, thus strategies may vary by client account. Closed-End Fund Strategies: The Firm invests in closed-end funds whose principal investment strategies include one or more of the following: Domestic Funds: • Municipal Bond, Build America Bond, Government Bond, Corporate Bond, High Yield Bond • Equity—Sector Specific (such as Utilities, Real Estate, MLPs), Equity—Covered Call, Equity—General, Equity—Growth & Income, Equity—Dividend, Equity— Tax-Advantaged, Equity—Preferred, Equity—Convertible Bond • Loan Participation • Mortgage-Backed • Multi-Strategy Non-U.S. Funds • Foreign Equity—Country Specific, Foreign Equity—Geographic Region, Global Equity—General, Global Equity—Growth & Income, Global Equity—Dividend • Global Fixed Income • Global Multi-Strategy The closed-end funds that invest in equity securities may or may not use a growth or value strategy and may include funds investing in securities of issuers of any market capitalization. Closed-end funds that invest in non-U.S. issuers may include issuers in emerging markets. Closed-end funds that invest in fixed income securities may invest in securities of any credit quality, including below investment grade (so-called “junk bonds”). Within the closed-end fund investment strategies, TJH currently has eight (8) sub-strategies, all within its Managed (Composite) Portfolio Program:

Herzfeld Balanced & Flexible Composite: includes all portfolios that invest in closed-end funds with the goal of maximizing risk adjusted total return. There is no restriction on asset class weighting, although the goal is to have wide level of diversification across sectors. Herzfeld Fixed Income Composite: comprised of portfolios invested in closed-end funds which invest in U.S. Fixed Income Market funds with the goal of maximizing risk adjusted total return. Herzfeld Foreign Equity & Fixed Income Composite: comprised of portfolios which invest in non-U.S. Fixed Income & Equity closed-end funds with the goal maximizing risk adjusted total return. Herzfeld US Equity Composite: comprised of portfolios which invest in U.S. Equity closedend funds with the goal of maximizing risk adjusted total return. Herzfeld Municipal Bond Composite: comprised of portfolios which invest in closed-end funds of the U.S. Municipal Bond market with the goal of maximizing risk adjusted total return. Herzfeld Special Situations Composite: comprised of portfolios which invest in closed-end funds which may undergo a corporate action. Our objective is to maximize risk adjusted total return. Herzfeld Preferred Composite: comprised of portfolios which invest in preferred shares, baby bonds, and senior notes. Our objective is to maximize risk adjusted total return. Herzfeld SPAC Composite: comprised of portfolios which invest in Special Purpose Acquisition Companies (SPAC’s). Our objective is to maximize risk adjusted total return. Herzfeld Credit Income Strategy: The Firm’s credit income strategy is implemented through its management of the HERZ Fund. The primary investment objective of the HERZ Fund is maximizing risk adjusted total returns with a secondary objective of generating high current income for stockholders. The HERZ Fund seeks to achieve its investment objectives by investing primarily in credit related instruments, including equity and junior debt tranches of collateralized loan obligations, or “CLOs,” that are collateralized by a portfolio consisting primarily of below investment grade (such loans are commonly referred to as “junk”) U.S. senior secured loans with a large number of distinct underlying borrowers across various industry sectors. The Fund may also invest in other related securities and instruments or other securities and instruments that the Adviser believes are consistent with our investment objectives, including senior debt tranches of CLOs, loan accumulation facilities (“LAFs”), collateralized fund obligations (“CFOs”), and securities issued by other securitization vehicles, such as collateralized bond obligations, or “CBOs.” The HERZ Fund investment team utilizes a variety of methods to proactively source and analyze CLO investments, including leveraging its management team’s industry experience, using the investment team’s professional networks, performing due diligence on issuers and their

management, and utilizing third party and, in some cases, proprietary financial and analytical models to aid in the selection and monitoring of investments. Potential investments undergo a detailed review by the Firm’s portfolio management and investment analyst personnel, which includes consideration of a number of factors, including competitive strengths/weaknesses of the CLO equity issuer, of the issuer’s financial performance (historical and projected), and overall business of the issuer, including products, services, management, sponsor, industry and competition. Investments that satisfy the Firm’s underwriting criteria are reviewed by the portfolio management team, which must approve the investment. Once an investment is acquired, it is reviewed on an ongoing basis as appropriate by the relevant portfolio manager(s).

Herzfeld Commercial Real Estate Strategy: The Firm’s commercial real estate strategy is implemented through its private fund, Herzfeld CRE I LP. The fund’s primary investment objective is to seek a superior total return on capital over the intermediate to long term by pursuing a specialized investment strategy. The fund seeks to achieve the investment objective primarily by executing a strategy to acquire, originate, or finance properties subject to long-term double/triple net lease agreements, wherein the tenant is responsible for payment of real estate taxes, insurance, and/or maintenance costs, in addition to base rent (such investments referred to hereinafter as “Portfolio Investments”). These may include single-tenant or multi-tenant properties leased to creditworthy tenants under leases typically ranging from 10 to 25 years. In addition to the Fund’s primary strategy described above, the Fund may pursue other real estate related activities as it deems necessary to maximize the return of its NN/NNN strategy for Fund investors.

Herzfeld Private Credit Strategy: The Firm’s private credit strategy is primarily implemented through the management of the HCM Fund, Akebono Funds, and other private fund vehicles. The private credit strategy generally provides financing to business development companies (“BDCs”) and/or closed end funds (“CEFs”) through both private debt financing and purchasing of debt securities available on public markets. BDCs are U.S. companies that choose to be regulated under the Investment Company Act of 1940 and are required to adhere to certain requirements in order to maintain their Registered Investment Company (“RIC”) status, including a limit in the amount of senior securities (debt and preferred stock) a BDC may issue and indebtedness it may incur. Generally, a BDC may issue senior securities or incur indebtedness such that its asset coverage is equal to at least 150% after such issuance or incurrence. BDCs are subject to periodic examinations by the U.S. Securities and Exchange Commission and potentially regulatory fines, penalties and other sanctions for violations of applicable laws and rules.

CEFs regulated under the Investment Company Act of 1940 are also subject to a comprehensive regulatory framework designed to protect investors. These protections include, among others, asset coverage ratio requirements, restrictions on affiliated and related party transactions, and independent board oversight. Registered CEFs are subject to periodic examinations by the U.S. Securities and Exchange Commission and potentially regulatory fines, penalties and other sanctions for violations of applicable laws and rules. Please refer to the specific offering memoranda applicable to each private fund vehicle for further details on the investment strategy and risk associated with an investment.

Usage and Development of Artificial Development Tools Increased adoption and technological developments in query-based artificial intelligence, agentic artificial intelligence, and semi-automated and automated machine learning technology (collectively, "AI Technology" or "AI") may present risks to the Firm and its clients. We encourage clients, investors and prospects to discuss, request information, review updates to the Firm's Form ADV Brochure and to ask questions about how AI is used in connection with the services provided to you. Within financial services generally, the uses for AI are expanding and include, but are not limited to, investment research, portfolio analysis, risk modeling and investor reporting. The use of AI Technology does not augment or alter TJH's responsibility as an investment adviser, nor does it reduce our fiduciary obligation to our Clients. TJH may utilize AI Technology tools to assist in certain aspects of its advisory operations. For example, TJH currently uses automated tools to parse publicly available filing data (e.g., filings on the SEC's EDGAR system) and to assist in compiling analytical information relating to closed-end funds and business development companies ("BDCs"). These tools are used to support, and do not replace, the analysis and judgment of TJH's investment professionals, and all outputs are subject to human review before being relied upon in connection with client accounts. TJH does not currently use agentic AI Technology or AI that independently plans and executes multi-step actions without human direction at each material step. TJH has adopted policies and procedures that are designed to govern the use of such tools, including policies that all AI-assisted outputs are subject to human review. AI Technology, nonetheless, has known limitations, including potential "hallucinations" and outputs that are inaccurate, incomplete, or outdated. AI tools and models may include biases or assumptions which affect an AI output or recommendation. AI-generated content may contain inaccuracies, and TJH's use of such tools does not eliminate the risk of error. TJH's review processes are designed to identify and correct such errors prior to reliance on AI-generated content, but no process can guarantee the complete elimination of such risk. AI tools are generally reliant on the data to which they have access. Verifying the accuracy of all data used by a given AI tool is not practical or possible. In addition, TJH has established relationships with third-party service providers that may use AI Technology in their own operations. While TJH maintains a vendor due diligence program, TJH cannot dictate how a third party licenses or develops proprietary AI tools, the data those tools rely upon, or the degree of human oversight applied to AI-generated outputs. Clients should be aware that the use of AI Technology by TJH or by third parties that TJH engages may affect the services provided to you in ways that are not fully transparent or predictable. TJH seeks to mitigate the risks associated with AI Technology through its AI policies and procedures, which include restrictions on permissible use cases, human review requirements, data security

controls, and ongoing AI training. TJH does not currently use AI Technology to autonomously make investment decisions, execute trades, or manage client accounts.

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TJH provides advisory services to clients on a discretionary basis consisting of its Registered Fund, Private Funds, and SMAs. TJH’s SMA Clients include primarily individuals, investment companies, trusts, corporations and various types of retirement accounts. The minimum investment for opening an SMA is generally $1,000,000 for individuals and $5,000,000 for institutional clients, depending upon, among other things, the strategy for the particular SMA. TJH may waive these minimums at its discretion. Additional information about the minimum investments for each client and other investment qualifications and conditions are described in the applicable Governing Documents.

TJH may charge performance-based fees to its Clients on a case-by-case basis. With respect to the Master Fund, TJH receives a performance-based profit allocation (the “Incentive Allocation”) at the end of each year, or upon any redemption of shares of the Master Fund (or corresponding feeder funds), on the applicable redemption date. The Incentive Allocation is equal to ten percent (10%) of the annual net income allocated to the feeder fund’s shareholder with respect to each Incentive Allocation Period to the extent that such net income is (i) in excess of the cumulative unrecovered losses carried forward from prior years or fiscal periods (this limitation is commonly referred to as a “high water mark”), and (ii) in excess of a 7% per annum annual hurdle rate of return. The Master Fund and corresponding feeder fund fees and expenses are described in each Private Fund’s Private Placement Memorandum. Other private funds may have similar performance fees that provide a profit-based allocation to TJH upon terms and conditions specific to those funds. Please refer to the relevant fund’s offering document for specific detail and conditions where performance fees may be charged. The Registered Fund is charged a performance-based fee of 10% of the Fund’s pre-incentive fee net investment income, for each calendar quarter subject to a 9.0% annualized hurdle rate, with a “catch-up” provision intended to provide the Adviser with an incentive fee of 10% on all of the Fund’s Pre-Incentive Fee net investment income as if a hurdle rate did not apply when the Fund’s net investment income exceeds 2.25% in any calendar quarter. The “catch-up” portion of the Fund’s pre-incentive fee net investment income is the portion that exceeds the 2.25% hurdle rate but is less than or equal to 2.5% in any calendar quarter. The performance-based fees are described in detail in the HERZ Fund’s proxy materials, prospectus and statement of additional information. Performance-based fees may create an incentive for certain investment advisors to favor accounts having performance-based fees over asset-based fee accounts or make investments that are riskier or more speculative than would be the case in the absence of performance-based fee clients. Although the investment strategy for each Client may be separate and distinct from investment strategies used for other TJH Clients, TJH has an established review processes and other related procedures that are designed to ensure that all Clients and investors are treated fairly and equally and to prevent conflicts from influencing the allocation of investment opportunities among Clients. To mitigate potential conflicts of interest when managing performance-based fee clients side-byside with asset-based fee clients, TJH has developed a policy in which portfolio managers attempt to allocate investment opportunities among eligible accounts on a pro rata basis if that is practical; or if a pro rata allocation is not practical, to allocate the investment opportunities among TJH advisory clients on a basis that over time is fair and equitable to each advisory client relative to other clients, taking into account relevant facts and circumstances, including, but not limited to: •

differences with respect to available capital and the size of a client;

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differences in investment objectives or current investment strategies;

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differences in risk profiles at the time an opportunity becomes available;

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the nature of the security or the transaction including minimum investment amounts and the source of the opportunity; and

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existing or prior positions in an issuer/security.

While the procedures described above are intended to allocate investment opportunities among advisory clients on a basis that is fair and equitable to all clients over time, the procedures could, in some circumstances, preclude an advisory client from participating in an investment opportunity, or otherwise result in certain allocations that favor one client over another. TJH will periodically review allocations of investment opportunities and sequencing of transactions and compare the performance of such accounts. Any exceptions or issues arising from these reviews shall be brought to the attention of TJH’s Chief Compliance Officer for possible corrective action.

TJH is parent company to a wholly owned subsidiary, HCM GP LLC, which is general partner to the onshore feeder fund that is a Private Fund Client. TJH is also the managing member (or voting control member) of four Private Fund special purpose vehicles formed as limited liability companies in Delaware. Herzfeld CRE I GP LLC (the “Herzfeld CRE General Partner”), a Delaware limited liability company, is the general partner of Herzfeld CRE I LP Fund. The Herzfeld CRE General Partner is jointly owned and managed by TJH and 7 Crowns Capital LLC (“7 Crowns”), an independent commercial real estate company. Activ Regulated Debt Fund LLC is a wholly owned subsidiary of the HCM Preferred Equity

Master Fund Ltd. The Firm does not engage in other financial industry activities or have any other affiliates.

TJH has adopted and implemented a Code of Ethics (the “Code”) in compliance with SEC Rule 204A-1 under the Advisers Act and Rule 17j-1 under the Company Act. The Code sets forth the standards of conduct expected of all employees, directors, and officers of the Firm (“Employees”). The Code requires certain business activity or conduct to be reported and monitored to avoid potential conflicts of interest. In addition, the Code also outlines policies and procedures designed to detect and prevent conflicts of interest relating to personal trading by all Employees and to ensure that TJH effects transactions for clients in a manner consistent with its fiduciary duty and in accordance with applicable laws. The Code prohibits TJH Employees from purchasing securities (with certain limited exceptions) that are held in any client account or are under active consideration for purchase or sale by any client account. Included in this prohibition are all equivalent and/or related securities, based on the issuer. In addition, all Employees are prohibited from trading, either personally or on behalf of others, on material nonpublic information or communicating material nonpublic information to others in violation of the law. Various procedures have been adopted under the Code including the requirement to pre-clear all applicable transactions. Additional restrictions relating to short-term trading and purchases of initial public offerings are also defined in the Code and applicable to all employees. Employees are required to comply with certain periodic reporting requirements and to certify they have read and will comply with the Code upon commencement of employment and annually thereafter. Employee reporting requirements and trading, as noted above, is monitored for adherence to the Code and any employee who violates the Code is subject to remedial actions. A copy of TJH’s Code is available upon request by contacting Thomas Morgan, TJH’s Chief Compliance Officer, at (305) 777-1660 and/or via electronic mail at tmorgan@herzfeld.com. Participation or Interest in Client Transactions Some officers and employees of the Firm have opened SMAs managed by the Firm that generally invest in the same securities and trade alongside other client accounts. In addition, certain officers and employees of the Firm have invested in the Registered Fund and the Private Funds. This creates a conflict if the Firm were to favor such employee or officer owned accounts or the Registered Fund or Private Funds in the allocation of investment opportunities. The Firm maintains policies and procedures designed to treat all clients, including the Registered Fund, Private Funds and SMAs, fairly when aggregating and allocating investment opportunities.

Although some officers and employees of TJH may maintain a material position or percentage interest in Registered Fund and/or the Private Funds, the restrictions and/or prohibitions on securities transactions under the Code, as set forth above, do not apply to officer or employee accounts held in the Registered Fund or Private Funds. Instead, to address any conflict created or mitigate any associated risk under these circumstances, the Firm reviews allocations of investment opportunities and sequencing of transactions across all accounts and compares the performance of such accounts to other client accounts to detect any favoritism. The Firm provides investment advisory services to various clients that at times will differ from the advice given, or the timing and nature of the actions taken with respect to any one account, including personal accounts, depending upon a variety of factors as discussed in Item 16. In addition, other factors such as market impact or liquidity constraints could result in one or more clients receiving less favorable trading results if the Firm were to implement an investment decision ahead of or contemporaneously with similar decisions for one set of clients ahead of other clients. As set forth above, the Firm maintains policies and procedures reasonably designed to ensure that all clients are treated fairly when aggregating and allocating investment opportunities. Similarly, there may be limited opportunity to sell an investment held by multiple accounts. In addition, different account guidelines and/or differences within investment strategies may lead to the use of different investment practices for portfolios with a similar investment strategy. The Firm will not necessarily purchase or sell the same securities at the same time, same direction, or in the same proportionate amounts for all eligible accounts, particularly if different accounts have materially different amounts of capital under management, different amounts of investable cash available, different strategies, or different risk tolerances. As a result, although the Firm manages numerous accounts and/or portfolios with similar or identical investment objectives, or may manage accounts with different objectives that trade in the same securities, the portfolio decisions relating to these accounts, and the performance resulting from such decisions, will differ from account to account. From time to time, the Firm may effect internal cross transactions among two or more client accounts if the Firm determines such transactions to be in the best interest of all clients involved, subject to limits imposed by ERISA and the Company Act. For example, this may happen in limited cases where the Firm is purchasing a security to be allocated to one or more clients, but at the same time is directed by a client to sell that same security (for example, for tax loss harvesting purposes). The Firm recognizes the conflicts of interest that cross trades or principal trades may create. To mitigate the conflicts of interest, the Firm will take steps to ensure that the crossing price in any such transaction is fair to both sides of the transactions (for example, by ensuring the trade is conducted through independent brokers), does not disadvantage any one client over the other client, and is in compliance with applicable law. Prior to affecting such transaction, approval from the Firm’s Compliance Department must be received, and if applicable, the trade will be subject to Registered Fund’s board of directors and/or Private Fund board of directors oversight. To the extent that the Firm’s controlling persons own more than a 25% interest in any one or more of the client accounts, the cross transaction will be deemed to be principal transactions and the Firm will comply with the principal trade provisions of the Advisers Act. Principal trades will not be effected when the trade involves an ERISA client or a client subject to the Company Act. Management of Multiple Accounts: Each of the portfolio managers is responsible for managing

multiple accounts, including SMAs, the Private Funds, and the Registered Fund, as applicable. From time to time, a potential conflict of interest will arise as a result of the portfolio manager’s management of a number of accounts (including proprietary accounts) with similar investment strategies. Often, an investment opportunity may be suitable for a number of clients but may not be available in sufficient quantities for all eligible accounts to participate fully. The Firm has adopted policies and procedures reasonably designed to allocate investment opportunities on a fair and equitable basis over time. Material Non-Public Information: The Firm may come into possession of material non-public information with respect to an issuer. Should this occur, the Firm would be restricted from buying or selling securities, derivatives or loans of the issuer on behalf of a Client until such time as the information became public or was no longer deemed material. Due to these restrictions, the Firm may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. Investments and Financing Between Related Clients: From time to time, Clients managed by the Firm, including the Registered Fund, one or more Private Funds, or SMAs may invest in, provide financing (including debt, credit facilities, derivative exposure, or other extensions of credit) to, or acquire an equity or ownership interest in other Clients managed by the Firm (each, an “Affiliated Vehicle” and each such transaction, a "Related Client Transaction"). In negotiating and structuring a Related Client Transaction, the Firm participates in both sides of the transaction. Terms that may be favorable to the investing and/or financing Client (e.g., a higher interest rate, stronger covenants, senior priority, more investor-favorable equity terms) may be correspondingly less favorable to the Affiliated Vehicle receiving such investment and/or financing, and vice versa. The Firm therefore may be in a position where it cannot negotiate the transaction on a genuinely arm's-length basis, and there is a risk that the terms will be more or less favorable to one Client than could have been obtained from an unaffiliated third party. The Firm may also have an incentive to cause one Client to invest in or extend financing to an Affiliated Vehicle experiencing liquidity constraints, capital needs, or underperformance, in order to support the Affiliated Vehicle’s continued operations, avoid a default, forced sale, or winddown, or otherwise protect the Firm's fee revenue, track record, or reputation with respect to the Affiliated Vehicle, rather than because the transaction represents an attractive or appropriate investment for the investing Client. Investments by a Client in an Affiliated Vehicle may result in the imposition of fees and expenses at multiple levels, including at the Client level and at the level of the underlying Affiliated Vehicle. It is TJH’s policy to seek to mitigate the potential for duplicative management fees and performance-based compensation on the same invested capital; however, there can be no assurance that duplication will be eliminated in all circumstances. Where the investing Client's position (whether debt or equity) in the Affiliated Vehicle is illiquid or does not have a readily ascertainable market value, the Firm may be responsible for, or may influence, the valuation of that position for purposes of calculating the investing Client's net asset

value and associated fees, while simultaneously being responsible for the financial condition and performance of the receiving Client whose securities or obligations are being valued. Once a Related Client Transaction is in place, the Firm may encounter further conflicts in exercising rights or making decisions on behalf of the investing Client with respect to that position. Decisions relating to amendments, waivers, covenant relief, restructuring, extension of maturity, or enforcement of remedies can create a conflict because such decisions directly affect both the Affiliated Vehicle and investing Client, who may have differing interests, and the Firm owes a duty of loyalty and care to both Clients. The Firm has established policies and procedures that are intended to mitigate conflicts associated with these Related Client Transactions. Such policies and procedures include requirements for board of directors/trustees review of such Related Client Transactions, requirements regarding obtaining independent analysis of pricing and structure with respect to the Related Client Transactions (so-called “transfer pricing studies”), and other policies and procedures that the Adviser has determined are appropriate.

Selection of Broker-Dealers In determining the broker-dealers through which to place securities transactions for client accounts, the Firm’s policy is to seek the best execution of orders at the most favorable price in light of the overall quality of brokerage and research services provided. In selecting brokerdealers to execute transactions, the determination of what is expected to result in best execution at the most favorable price involves a number of factors, including, but not limited to, the nature of the security being traded, the size and timing of the transaction, the activity existing and expected in the market for the particular security, the likelihood of price improvement, the speed of execution, and the ability to minimize market impact. In addition, the Firm considers the broker-dealer’s financial responsibility, its responsiveness and operational capabilities, and its maintenance of the confidentiality of orders. The determinative factor is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution under the circumstances. As a result of any or a combination of the above factors, transactions will not always be executed at the lowest available price, commission, and/or mark-up/mark-down. Fixed income securities may be purchased from the issuer or broker-dealer or primary marketmaker acting as principal for the securities on a net basis, with no brokerage commissions being paid by the client, although the price usually includes certain undisclosed compensation to the dealer. Rather than purchasing from a broker-dealer on a principal basis, in certain circumstances consistent with its responsibilities in seeking best execution, the Firm may engage a broker-dealer to act as agent (for which such broker-dealer may be paid a negotiated commission or mark-up) in purchasing fixed-income securities for client accounts. Securities also may be purchased from underwriters at prices that include underwriting fees.

The Firm has established a Senior Management Committee (the “Committee”) that has oversight responsibility for the Firm’s brokerage practices. The Committee meets quarterly or more frequently as needed. Research and Other Soft Dollar Benefits The Firm currently does not have soft dollar relationships and does not receive research services as a result of commissions paid to broker-dealers. Brokerage for Client Referrals The Firm does not receive client referrals from executing broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Note that the Firm does receive client referrals from certain third-party solicitors under written agreements with such firms. See Item 14 below. Directed Brokerage The Firm determines which broker to use to execute each order, consistent with its duty to seek best execution of the transaction. However, certain clients limit the Firm’s selection of brokers or instruct the Firm to direct trades through a particular broker. In these cases, the Firm at times will place separate, non-simultaneous, transactions for its clients and a directed client account that could temporarily affect the market price of the security or the execution of the transaction, or both, to the detriment of all accounts. Directing clients at times will receive worse prices, and/or pay higher commissions than non-directing clients. Alternatively, from time to time, the Firm may endeavor to aggregate the directed brokerage order with non-directed brokerage orders for execution and then step out the trade to the directed broker for clearance and settlement. This arrangement facilitates two purposes. First, a step-out allows the directed broker to receive the commissions. Second, aggregation of directed brokerage orders with non-directed orders allows directed brokerage clients to participate on the same terms and conditions as other non-directed brokerage clients Aggregation of Trades The Firm may, in its discretion, aggregate orders being placed for execution at the same time for the accounts of two or more clients, which may include the Registered Fund, Private Funds and SMAs, where it believes such aggregation is appropriate and in the best interest of its clients. This practice may enable the Firm to seek more favorable executions and net prices for the combined order. However, the Firm is not obligated to aggregate orders or to include any particular account in an aggregated order if portfolio management decisions for different accounts are made separately or if the Firm determines that aggregating trades would be inconsistent with the Firm’s investment management duties or with any investment objectives, guidelines or restrictions applicable to a particular client. All orders placed for execution on an aggregated basis are subject to the Firm’s allocation policies and procedures. Firm employees will aggregate orders where appropriate for the participating clients and consistent with the Firm’s duty to seek best execution.

Allocation of Partially Filled Orders If the Firm is unable to fill an aggregated transaction completely, it allocates the partially filled orders according to the Firm’s allocation policy among accounts participating in the order. The objective of the Firm’s allocation policy is to achieve fair treatment of all clients’ accounts through its trade allocation process. No preference is given with respect to portfolio size, or tenure of client.

From time to time, the Firm enters into written solicitation agreements for the referral of the Firm’s investment advisory services under which persons and/or firms introducing new clients to the Firm (“Solicitors”) receive a referral fee. When entering such agreement, the Firm complies with all applicable securities requirements under the Advisers Act. In the event the Firm enters into such agreements, we require Solicitors to provide the prospective client or investor with a copy of this document (our Firm Disclosure Brochure) and a separate disclosure statement at the time of the referral. If you become a Client or invest in one of our Funds, the Solicitor that referred you to our Firm will either receive: a) a percentage of the advisory fee applicable to your investment for as long as you are a Client or investor with our Firm, or b) a onetime, flat referral fee upon your investing with our Firm, or c) other form of compensation as negotiated between our Firm and such Solicitor. You will not pay additional fees because of any such referral arrangement. Solicitors have a financial incentive to recommend our Firm and/or funds managed by the Firm. This creates a conflict of interest; however, you are not obligated to retain our Firm for advisory services or invest in any fund managed by our Firm. Comparable services and/or lower fees may be available through other firms.

Some of the Firm’s clients and investors use consultants to evaluate and recommend investment advisers and their services, including the Firm and its related entities. The Firm is not affiliated with any consultant (although one consultant is a limited partner of a Private Fund managed by the Firm; another consultant is the owner of a separately managed account for the benefit of its clients). These consultant firms represent multiple clients and prospects and, therefore, have frequent interactions with the Firm and related entities. The Firm may pay nominal fees to be listed and include information about our investment strategies in consultant registries or databases that describe services provided by investment managers, including the Firm.

There are no legal or disciplinary events that are material to a Client’s or a prospective client’s evaluation of TJH’s advisory business or the integrity of its management.

The portfolio managers for each client account review those accounts on a regular basis. The Firm’s investment advisory accounts are under constant review because of the commonality of holdings among the relatively low number of accounts under management and the limited number of different portfolio securities. These factors facilitate the continual monitoring of client portfolios in relation to changes in market prices and available information (e.g. earnings and dividends). All reviews are conducted pursuant to the guidelines established by, or in connection with, the applicable account. The Firm provides reports to the Registered Fund and the Private Funds (and their respective investors) and to SMA Clients as required by the applicable Governing Documents. Investors in the Registered Fund and Private Funds should refer to the applicable Governing Documents for further information on the reports provided to a particular Registered Fund’s and Private Fund’s investors.

The Firm does not maintain physical custody of the funds or securities of any Client. However, under Rule 206(4)-2 promulgated by the SEC under the Advisers Act, the Firm is deemed to have custody of certain assets held in its Private Funds as a result of acting as or having control over the Private Funds or a Private Fund’s general partner. As a result, those assets are administered in compliance with applicable rules and regulations related to the custody of client assets. The Private Funds generally undergo audits by a PCAOB-registered auditing firm. All audit reports are disclosed to investors in those Private Funds.

The Firm has discretionary authority to manage securities accounts on behalf of its clients. The Firm’s discretionary authority is generally limited by the investment objectives, strategies, policies, and restrictions set forth in the Governing Documents.

To the extent that the Firm holds securities that require it to vote proxies or in circumstances in which the Firm’s employees are serving on the board or other governing body and are required to vote on a matter, the Firm has a responsibility to vote the proxies in a manner in which it views to be in the best interests of its clients. In this regard, in accordance with Rule 206(4)-6 under the Advisers Act, the Firm has adopted written policies and procedures regarding the voting of client proxies that are designed to ensure that the Firm fulfills its fiduciary obligations to clients, including policies for addressing material conflicts that may arise between the Firm and its clients. In the event a proxy raises material conflicts involving the Firm employees, whether arising from any material business, personal or familiar relationship with employees at a portfolio company or a material arrangement with any such company, the Chief Compliance Officer will determine the manner in which such proxies should be voted so that the vote is in the best interests of clients. Under such policies and procedures, the Firm is authorized to vote proxies on behalf of its clients unless a client specifically retains or delegates this authority to another party in writing. The Firm has adopted written Proxy Voting Policies and Procedures that are designed to reasonably ensure that all proxy voting decisions are made in the best interests of advisory clients for whom the

Firm has voting authority. The Firm will act in a prudent and diligent manner intended to enhance the value of the assets of the client’s account. TJH has contracted with Proxy Edge, a third party proxy voting administrator, to assist the Firm in the administration of its proxy voting responsibilities. The Firm will review proxy proposals for conflicts of interest as part of the overall vote review process. If material conflicts of interest arise between the Firm and its clients with respect to voting a proxy, the Firm will convene an internal group of senior employees who are independent from the conflict of interest at issue. The internal group will consider the proxy and the conflict and determine a course of action that is in the best interest of the client.

Clients may obtain a copy of the Firm’s Proxy Voting Policies and Procedures, as updated from time to time, as well as information on how the Firm voted their accounts’ securities upon written request to: Thomas J. Herzfeld Advisors, Inc. Attn: Compliance Department 119 Washington Avenue, Suite 405 Miami Beach, FL 33139 or by contacting Thomas K. Morgan, TJH’s Chief Compliance Officer, at (305)-777-1660 and/or via electronic mail to tmorgan@herzfeld.com. Class Action Lawsuits and Settlements

Securities issuers are, on occasion, the subject of class action lawsuits where the class of potentially injured parties is defined to be purchasers of the issuer’s securities during a specific period of time. These cases may result in an award of damages or settlement proceeds to the class members who file claims with the settlement administrator. We do not determine if securities held in your account are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation. Additionally, we do not initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held in your account. In addition, we will not take any action or render any advice as to received materials relating to any class-action lawsuit. The Firm does not provide any legal advice to clients in connection with class action litigation. Other Legal Proceedings

As a general matter, except as required by law, the Firm does not monitor, advise or act for a client in legal proceedings, including, but not limited to bankruptcies or other legal proceedings involving securities purchased or held in a client’s account. Clients should instruct their custodians to promptly forward any communications relating to legal proceedings involving such assets.

The Firm does not require or solicit prepayment of fees by any client six months or more in advance, and thus has not included a balance sheet for its most recent fiscal year. The Firm is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients, nor has the Firm been the subject of a bankruptcy petition at any time.