Tilden Park Capital Management LP

Advisory Business A. Tilden Park Capital Management LP (“TPCM”), a Delaware limited liability company, is a registered investment adviser located in New York, New York, founded on February 19th, 2009. Tilden Park Management I LLC, a wholly-owned subsidiary and relying adviser of TPCM, serves as investment manager to pooled investment vehicles, which operate in master-feeder structures (collectively, the “Funds”): Tilden Park Investment Master Fund LP (collectively with its feeder funds, the “Tilden Park Investment Funds”); Tilden Park CMBS Opportunity Master Fund LP (collectively with its feeder funds, the “CMBS Fund”); and Tilden Park Credit Opportunities Master Fund LP (collectively with its feeder funds, the “COF”). The Funds are exempt from registration under the Investment Company Act of 1940, as amended (the “Investment Company Act”), pursuant to Section 3(c)(7) of the Investment Company Act. Interests in the Funds are privately offered only to qualified investors, and in the United States these interests are offered under the private placement exemption provided by Section 4(a)(2) of the Securities Act of 1933 and Regulation D promulgated thereunder. Tilden Park also serves as an investment adviser to separately managed accounts (each, a “Managed Account” and collectively with the Funds, the “Clients”). Tilden Park Management II LLC is also a wholly-owned subsidiary and relying adviser of TPCM. An affiliate of Tilden Park serves as the general partner (the “General Partner”) of the applicable Funds. Tilden Park or its affiliates may be entitled to receive performance-based compensation from the Clients as discussed below. Josh Birnbaum is the principal owner of the Firm. B. Tilden Park offers discretionary investment advisory services to its Clients. The Firm seeks to generate attractive risk-adjusted returns through a multi-disciplinary investment approach using a broad array of securities (and related financial instruments) and strategies in accordance with the investment mandate of each Client. C. Tilden Park utilizes a similar investing approach for all its Clients; however, some Clients may differ in their particular mandate. Tilden Park may also tailor the advisory services it provides to the Clients to the extent that certain investments cannot be held by certain Clients for legal and tax purposes. Managed account clients may impose guidelines or restrictions relating to the investments made in their managed account. D.

Tilden Park does not participate in wrap fee programs.

E. As of December 31, 2025, Tilden Park had $6,836,633,114 of regulatory assets under management, all of which it managed on a discretionary basis.

Fees and Compensation A/B. Tilden Park deducts management fees directly from the Funds’ assets on a quarterly basis. Tilden Park invoices management fees to the Managed Accounts’ beneficial owners on a quarterly basis. With respect to Funds that are structured as open-end or “hedge” funds (the “Open-End Funds”), an affiliate of the Firm is eligible to be allocated performance-based compensation in an amount equal to up to 20% of the net realized and unrealized gains earned by each investor, subject to a modified high-water mark, on an annual basis; provided, that such performance-based compensation may also be received upon an interimyear withdrawal as if the withdrawal date were the end of the year. With respect to Funds that are structured as closed-end or “private equity” funds (the “Closed-End Funds”), an affiliate of the Firm is eligible to be distributed an amount up to 20% of the proceeds realized upon the disposition of the assets of such Fund, subject to a preferred return and the return of capital contributions to investors. With respect to the Managed Accounts, the Firm is eligible to be paid performance-based compensation, which may be equal to a portion of (i) the net realized and unrealized gains earned by such Managed Account, subject to a high-water mark, which is invoiced to the beneficial owner on an annual basis, or (ii) the net realized gains earned by such Managed Account, which is invoiced to the beneficial owner when earned. Please refer to Item 6 and Item 11.B for additional disclosures about performance-based compensation. This brochure is only delivered to “qualified purchasers” as defined in the Investment Company Act. C. The Funds will generally bear their own expenses, as disclosed in each Fund’s offering documents. Expenses that the Funds may bear include, but are not limited to, the following: investment expenses (e.g., custodial fees, interest expenses, initial and variation margin, broken deal expenses, consulting and other professional fees relating to particular investments, research related investments and travel expenses incurred in connection with due diligence and monitoring), legal expenses, expenses associated with regulatory filings made in connection with the Funds’ operations and portfolio holdings, systems and technology, insurance, audit and tax preparation expenses, organizational expenses, expenses relating to the offer and sale of interests in the Funds and extraordinary expenses, expenses related to services performed by the administrator, fees of pricing services and valuation firms, and expenses incurred by members of an advisory committee in connection with the fulfillment of their duties to the Funds, including their legal and advisory fees, and reasonable travel expenses to attend meetings. Please see each Fund’s respective offering documents for additional information related to expenses. Managed accounts may bear expenses similar to those disclosed above. Expenses allocated to managed accounts may be negotiated individually with respect to each managed account. At its discretion or pursuant to the terms of an investment advisory agreement, the Firm may pay expenses that would otherwise be allocated to a Client. The Firm and Clients that do not pay expenses benefit from services paid for by other Clients or the Firm, as applicable. Clients that invest in money market mutual funds, ETFs or other registered investment companies will bear a proportionate share of the related fees and expenses in addition to the fees paid to Tilden Park. Clients will incur brokerage and other transaction costs. Please see Item 12 “Brokerage Practices” for more information. Any description of the expenses that a Client may bear (including those listed herein) is not exhaustive. Tilden Park determines, in its sole discretion, whether an expense is to be categorized as an expense of one Client or another or an expense of the Firm. This analytical process is inherently subjective and Tilden Park may be viewed as biased in making such determinations. The allocation of expenses presents an inherent conflict of interest, as different allocations would result in Clients and the Firm bearing more (or less) expenses. Tilden Park has adopted and implemented written compliance policies and procedures designed to address this conflict and ensure that Tilden Park abides by its duty to act in the interests of

Clients. Tilden Park makes these determinations in accordance with provisions in Client governing documents and the Firm’s written expense allocation policies and procedures. D. Management fees are paid in advance by the Funds on a quarterly basis and in advance or arrears by the Managed Accounts. In the event Tilden Park does not provide services to a Client for the full period, the Management Fee is typically required to be returned. In general, the amount of fees returned is calculated based on the number of days remaining in the applicable period. E. Neither Tilden Park nor any of its supervised persons accept compensation for the sale of securities or other investment products.

Methods of Analysis, Investment Strategies and Risk of Loss A. The Firm seeks to generate attractive risk-adjusted returns through a multi-disciplinary investment approach using a broad array of securities (and related financial instruments) and strategies in accordance with the investment mandate of each Client. The Firm focuses on, without limitation, structured products and interest rate, corporate credit, equity and related derivative positions and other complementary and/or similar positions. Strategies to achieve this objective may include among others: Distressed, Long/Short and Relative Value, and Macro. The Firm has a global mandate, and there are no limitations on the strategies and/or instruments that the Firm may employ in seeking to achieve its investment objective. Distressed The Firm believes opportunities arise in the distressed space to buy assets at a substantial discount to their intrinsic value. Long/Short and Relative Value The Firm’s long/short strategies may include (i) long debt, equity and/or real estate investing which includes purchasing assets that the Investment Manager believes will appreciate in value and/or generate positive cash flow returns, (ii) long event-driven investing, which includes selective positions where the Firm believes certain events may transpire and result in an increase in value of such positions, and (iii) short positioning as a hedge for the long positions and/or as a valuation-driven view involving equity or debt. In employing its long or short strategies, the Firm seeks to employ the same principles that the Firm utilizes in its distressed, relative value, and macro investing to evaluate a broad range of investments. In implementing its relative value strategies, the Firm seeks to exploit relative mispricings both within asset classes and between asset classes. These strategies entail buying certain securities and shorting similar but relatively less attractive securities. Macro The Firm may take directional views on certain macro themes such as the level of credit spreads, equity prices, interest rates, foreign exchange rates and volatility. There can be no assurance that the Firm will achieve its investment objectives or that investment strategies employed by Tilden Park will be successful. Each Client’s investment program is speculative and entails substantial risks, including risk of loss of the entire investment, a risk that the Clients and its investors should be prepared to bear. Investors in the Funds should ultimately refer to their Fund’s respective offering documents for disclosures that specifically address the methods of analysis and investment strategies employed with respect to such Funds. The information contained herein with respect to the Funds is a summary only.

B and C. All investing involves a risk of loss that Clients should be prepared to bear. The identification of securities and other assets believed to be undervalued is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. The Firm cannot give any guarantee that it will achieve a Client’s investment objectives or that Clients will receive a return on their investment. Investors in the Funds should ultimately refer to their Fund’s respective offering documents for additional detailed risk disclosures that specifically address risks of each Fund’s investment strategies, methods of analysis, and/or particular types of investments recommended. Below is a summary of potentially material risks for each significant investment strategy used, the methods of analysis used, and/or the particular type of security recommended. Risks of Investments Generally All investments risk the loss of capital. No guarantee or representation is made that a Client’s investment program will be successful. A Client’s investment program may involve, without limitation, risks associated with limited diversification and concentration, leverage, investments in speculative assets and the use of speculative investment strategies and techniques, interest rates, volatility, basis risks in hedged positions, and credit deterioration or default risks. Investments may be materially and adversely affected by conditions in real estate markets, the structured products markets, the financial markets and overall economic conditions occurring globally and in particular markets where a Client may invest its assets. Tilden Park’s methods of reducing such risks may not accurately predict future risks. Risk management techniques are based in part on the observation of historical market behavior, which may not predict market divergences that are larger or different than historical indicators. Also, information used to manage risks may not be accurate, complete or current, and such information may be misinterpreted. Moreover, prospective investors should consider that: (i) performance achieved under prior market conditions may not be representative of performance under future market conditions; (ii) there may be substantially greater regulation of the financial markets, reducing profit opportunities generally; (iii) previously successful strategies may no longer be viable; and (iv) the capital allocated to alternative strategies may decline significantly, with possibly material adverse effects on the alternative investment sector in general. Risks Related to Structured Products Investing The investment characteristics of asset-backed securities (“ABS”), commercial mortgage-backed securities (“CMBS”), residential mortgage-backed securities (“RMBS,” and together with CMBS, “MBS”) and other structured products, such as collateralized loan obligations (collectively, “Structured Products”) differ from traditional debt securities. Among the major differences are that interest and principal payments are made more frequently, usually monthly, and that principal may be prepaid at any time because the underlying assets generally may be prepaid at any time (with certain exceptions). The performance of a particular structured product will be affected by a variety of factors, including its priority in the capital structure of the issuer, the availability of any credit enhancement, the level and timing of payments and recoveries on and the characteristics of the underlying receivables, loans or other assets that are being securitized, remoteness of those assets from the originator or transferor, the adequacy of and ability to realize upon any related collateral and the capability of the servicer of the securitized assets. In addition, investments in structured products may be illiquid in nature, with no readily available secondary market. Because they are linked to their underlying markets or instruments, investments in structured products generally are subject to greater volatility than an investment directly in the underlying market or instrument. Total return on a structured product is derived by linking the return to one or more characteristics of the underlying instrument. Because certain structured products of the type in which a Client may invest may involve no credit enhancement, the credit risk of those structured products generally would be equivalent to that of the underlying instruments. Clients may invest in a class or tranche of structured products that is either subordinated or unsubordinated to the right of payment of another class or tranche. Subordinated structured products typically have higher yields and present greater risks than unsubordinated structured products. ABS. ABS includes securitizations backed by credit cards, student loans, auto loans, inventory loans, auto

dealer floorplan loans, franchise loans, venture capital loans, trade receivables, equipment leases, tax liens, PACE loans, single-family rental homes, structured settlements, royalties (e.g., franchise, pharmaceutical, film, music) and aircraft leases, as well as ABS backed by other assets. CMBS. CMBS includes securitizations backed by commercial mortgage loans, typically comprising office, industrial (including storage facilities and data centers), retail, residential, hotel and/or multifamily mortgages without government or agency guarantees. The value of CMBS will be influenced by factors affecting the value of the underlying real estate portfolio, and by the terms and payment histories of such CMBS. RMBS. RMBS includes securitizations backed by residential loans of various types, including those originated as Prime, Alt-A, Option Adjustable Rate Mortgages, subprime, second lien mortgages, nonperforming or re-performing mortgages without government or agency guarantees. Agency MBS. Certain RMBS or CMBS that are guaranteed by the Government National Mortgage Association or another government-sponsored enterprise or instrumentality (e.g., the Federal National Mortgage Association and the Federal Home Loan Mortgage Corporation (collectively, each, an “Agency” or “GSE”), including forward contracts, specified pools and Collateralized Mortgage Obligations formed from these passthroughs, along with related derivative products. Structured Products – Generally. Investing in Structured Products involves particular risks, which include, without limitation: §

Counterparty Risk. Tilden Park has established counterparty relationships that facilitate its ability to trade in any variety of markets or asset classes; however, there can be no assurance that Tilden Park will be able to maintain such relationships or establish new relationships. An inability to maintain or establish such relationships would limit its trading activities and could create losses by preventing the firm from trading at optimal rates and terms. Some of the markets in which the Partnership may make its Structured Products transactions are “over-the-counter” markets. The participants in such markets are typically not subject to credit evaluation and regulatory oversight as are members of “exchange-based” markets. This exposes the risk that a counterparty will not settle a transaction in accordance with its terms and conditions because of a dispute over the terms of the contract (whether or not bona fide) or because of a credit or liquidity problem, thus a Client to suffer a loss. The ability of the Firm to transact business with any one or more counterparties, the lack of complete and “foolproof” evaluation of the financial capabilities of such counterparties and the absence of a regulated market to facilitate settlement may increase the potential for losses. In addition, there are risks involved in dealing with the custodians or brokers who settle trades. Assets deposited with custodians or brokers may not be clearly identified as being assets of a Client, and hence a Client may be exposed to a credit risk with regard to such parties. In some jurisdictions, a Client may only be an unsecured creditor of its broker in the event of bankruptcy or administration of such broker. Further, there may be practical or time problems associated with enforcing a Client’s rights to its assets in the case of an insolvency of any such party.

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Credit Scores May Not Accurately Predict the Performance of Underlying Loans. Tilden Park may rely on credit scores as part of its investment process. Credit scores are obtained by many lenders in connection with loan applications to help them assess a borrower’s creditworthiness. Credit scores are generated by models developed by a third party that analyzes data on consumers in order to establish patterns that are believed to be indicative of the borrower’s probability of default over a two-year period. The credit score is based on a borrower’s historical credit data, including, among other things, payment history, delinquencies on accounts, levels of outstanding indebtedness, length of credit history, types of credit, and bankruptcy experience. A credit score purports to be a

measurement of the relative degree of risk a borrower represents to a lender (i.e., a borrower with a higher score is statistically expected to be less likely to default in payment than a borrower with a lower score). Lenders have varying ways of analyzing credit scores and, as a result, the analysis of credit scores across the industry is not consistent. In addition, the two-year period contemplated by credit scores typically does not correspond to the life of a loan. There can be no assurance that the credit scores of the borrowers will be accurate predictors of the likelihood of repayment of the related loans. §

Credit Support Limitations. The amount, type and nature of insurance policies, subordination, overcollateralization, excess spread, letters of credit and other credit support, if any, with respect to certain ABS and MBS may not be sufficient to ensure timely payment of interest and principal on such securities, and the considerations used to structure such credit support at the time of issuance are inherently limited in their ability to predict events in the future. There can also be no assurance that data derived from a large pool of assets accurately predict the delinquency or loss experience of any particular asset pool.

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Types of Clients As detailed above in Item 4 “Advisory Business,” Tilden Park provides investment advice to the Funds and other institutional investors. Fund investors are required to meet certain eligibility and suitability standards as set forth in each Fund's governing documents and subscription materials. In general, the minimum investment in a Fund is $5,000,000; however, the Funds may accept lesser amounts. There is no minimum investment for managed accounts.

Performance-Based Fees and Side-By-Side Management As set forth in Item 5 “Fees and Compensation,” the Firm or its affiliates may be entitled to receive performance-based compensation based on the investment performance of a Client’s account, as specified in each Client’s governing documents. Such performance-based compensation creates an incentive for the Firm to recommend investments that are riskier or more speculative than those which would be made under a different fee arrangement and a conflict of interest to favor Clients or accounts that pay more in fees. However, the Firm is committed to fulfilling its fiduciary duty to its Clients to act at all times in the best interests of the Clients. To this end, the Firm has implemented written compliance policies and procedures that are designed to address conflicts of interest.

Other Financial Industry Activities and Affiliations A. Neither Tilden Park nor any of its management persons are registered, or have an application pending to register, as broker-dealers or registered representatives of a broker-dealer. B. Tilden Park Management I LLC is a member of the National Futures Association and registered with the Commodity Futures Trading Commission as a commodity pool operator. As a result of this registration, Samuel Alcoff and Joshua Birnbaum are registered as associated persons of Tilden Park Management I LLC in accordance with the rules, regulations and bylaws of the National Futures Association. Other than as set forth in this Item 10.B, neither Tilden Park nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor or an associated person of the foregoing entities. C. The Relying Advisers and General Partners of the Funds are affiliated with Tilden Park by common ownership. Tilden Park’s Relying Advisers, General Partners, employees and the persons acting on its behalf are subject to the registered adviser’s supervision and control and are therefore “persons associated with” the registered adviser and subject to Tilden Park’s compliance program. Please refer to Item 10.B above for disclosures regarding Tilden Park’s affiliated commodity pool operator. Tilden Park’s Clients include the COF and CMBS Fund, each of which pursues a subset of the investment program of the Tilden Park Investment Funds. Tilden Park faces inherent conflicts of interest in providing services to multiple Clients, such as conflicts of interest related to the allocation of expenses and investment opportunities. These conflicts of interest are heightened because Related Persons (as defined below) own different percentages of the Funds. Tilden Park has implemented policies and procedures designed to mitigate these conflicts of interest. Tilden Park’s principals founded and serve as directors of the Anza Group Inc. (collectively with its subsidiaries, “Anza”), a regulated insurance company. While Anza operates within the broader financial services industry, its business activities are distinct from, and do not compete with, the investment advisory services provided by Tilden Park. Anza does not manage securities or seek the same client mandates as Tilden Park, and Tilden Park does not recommend the insurance products of Anza to its Clients or obtain services from Anza for the benefit of its Clients. Tilden Park’s principals devote a portion of their time to Anza and certain Tilden Park resources and personnel are utilized by Anza, for which such employees or Tilden Park are generally compensated directly or indirectly by Anza. D. Tilden Park does not recommend or select other investment advisers for its Clients and receive compensation from those advisers.

Code of Ethics, Participation or Interests in Client Transactions and Personal Trading A. Tilden Park has adopted a Code of Ethics (the “Code”), which describes the Firm’s fiduciary duties and responsibilities to its Clients and requires the Firm’s employees to (i) place Clients’ interests before the Firm’s and its employees’ interests, (ii) act in good faith and in an ethical manner and (iii) identify and manage conflicts of interest to the extent that they arise. Tilden Park’s employees are also required to comply with applicable provisions of the federal securities laws and make prompt reports to the Firm or other appropriate party of any actual or suspected violations of such laws by Tilden Park or its employees. In addition, the Code sets forth formal policies and procedures with respect to the personal securities trading activities of Tilden Park’s employees. The Code prohibits employees from engaging in personal trading in the securities of issuers on the Firm’s restricted lists without receiving pre-clearance, requires employees to provide duplicate brokerage accounts statements to the Firm or to report all securities transactions and holdings on a quarterly and annual basis, respectively. The Code also includes policies and procedures to prevent the misuse and disclosure of material nonpublic information and other confidential information, as well as policies and procedures addressing conflicts of interest, outside activities of employees, gifts and business entertainment, and political contributions. Tilden Park will provide a complete copy of its Code to any Fund investor, Client or prospective Client upon request to (212) 754-1700 or info@tildenparkcapital.com. B. Tilden Park manages multiple “master-feeder” structures. The use of a master-feeder structure creates a conflict of interest in that different tax considerations for each feeder fund may result in the master fund structuring or disposing of an investment in a manner that is more advantageous to investors in one feeder fund. Tilden Park Investment Master Fund LP also invests through the COF and special purpose vehicles, which include, without limitation, investing through U.S. or offshore limited liability companies, limited partnerships and trusts, profit participation notes issued by Irish designated activity companies, and Irish Collective Asset-Management Vehicles for which Tilden Park acts as investment manager. Each Fund’s respective offering documents provides additional disclosures with respect to master-feeder arrangements and the use of trading vehicles. When a Fund invests in another Fund, fees are waived, adjusted or offset as necessary to avoid layering or duplication. Tilden Park, its employees, or a related entity (collectively “Related Persons”) have committed their own capital to the Funds. Thus, although the Funds may, at times, buy or sell securities in which Related Persons have a financial interest, the capital that Related Persons have in the Funds aligns the interests of the Funds and Related Persons, and helps to mitigate potential conflicts that exist. C/D. With limited exceptions, Tilden Park restricts personal investment in the same securities that the Firm or any Related Person recommends to Clients, as such activity may present an inherent conflict of interest to favor personal investment transactions over Client transactions. To address this and any related conflict of interest, the Firm maintains personal trading pre-clearance requirements and a personal trading restricted list (which, among other things, includes all securitized products (e.g., CMBS, RMBS, ABS, Agency CMO, etc.), securities about which the Firm may have material non-public information, and all securities held by Clients with certain limited exceptions (e.g., ETFs, certain treasury-related securities, or interest rate products). If an employee acquired a security that is restricted prior to joining the Firm or the Firm and its Related Persons recommend a security to Clients that is already held by an employee, the employee generally will be permitted to continue to hold the applicable security but will need to obtain preclearance for any future trading of that security. Please also see Item 10.C above.

Brokerage Practices A.1. Tilden Park generally has the authority to select the broker-dealers used in Client transactions and to negotiate the fees paid to the broker-dealers in connection with such transactions. Tilden Park places trades for Client accounts subject to its fiduciary duties, including the duty to seek best execution for Clients’ securities transactions. In choosing broker-dealers for Client transactions and determining the reasonableness of broker-dealer compensation, Tilden Park generally seeks the best combination of brokerage expenses and execution quality. Factors considered by Tilden Park include, but may not be limited to: the ability of the brokers or dealers to effect the transactions (i.e., the access of the brokers or dealers to the asset in which Tilden Park desires to transact) and, when multiple brokers or dealers are able to effect a transaction, the ability of the brokers or dealers to effect the transactions at the best price, their facilities, reliability and financial responsibility, and the use of brokerage or research products or services which Tilden Park considers to be of benefit to its Clients. Selecting broker or dealers on the basis of considerations that are not limited to commission rates may result in higher transaction costs than would otherwise be obtainable. Tilden Park is not required to solicit competitive bids for execution services or to select the broker or dealer that charges the lowest transaction cost. Accordingly, the transactions costs (or dealer markups and markdowns arising in connection with riskless principal transactions) charged to a Client by broker-dealers in the foregoing circumstances may be higher than those charged by other brokers who may not offer such services. In seeking best execution for transactions on behalf of Clients, the Firm, from time to time, may instruct the broker-dealer that executes a transaction to allocate a portion of the execution fee for such transaction to another broker-dealer who was involved in the transaction (e.g., provided research products). In such instances, the applicable Client generally bears the same execution costs that it would otherwise be subject to. Tilden Park does not engage in formal soft dollar arrangements with counterparties. To mitigate (potential) risks and conflicts associated with trading, the Firm has implemented written compliance policies and procedures, including a policy to seek best execution for Clients’ securities transactions. Further, to the extent applicable, Tilden Park’s policy is to follow the safe harbor in Section 28(e) of the Securities Exchange Act of 1934 and periodically make a good faith determination that the amount of commissions paid is reasonable in light of the products or services provided by a broker or dealer. The selection of a broker to execute transactions, provide financing and securities on loans, hold cash and short balances, etc.) may be influenced by their provision of products and services without charge, including, without limitation, proprietary or third-party research, special execution capabilities, monthly broker pricing, economic and market information, industry and company and sector comments, technical data, recommendations, general reports, efficiency of execution and error resolution, quotation services, the availability of investments to borrow for short sales, marketing assistance and access to capital introduction services, consulting services with respect to, without limitation, technology, operations and/or equipment, and similar services (“Products and Services”). Many of these Products and Services are made available to Tilden Park on an unsolicited basis and without regard to transaction costs charged or the volume of business Tilden Park directs such broker. However, Tilden Park may not receive such Products and Services if it did not utilize such broker (e.g., if its Client accounts were not held at such prime broker or custodian). In addition, but on a more limited basis, the selection of a service provider other than a broker may be influenced by their provision of Products and Services without charge. As with brokers, these

Products and Services may be made available to Tilden Park on an unsolicited basis and without regard to any particular retention; however, Tilden Park may not receive such Products and Services if it did not utilize such service provider. All such Products and Services may benefit Tilden Park and many, but not necessarily all, of its Clients and Tilden Park may have a conflict and incentive to select or recommend a service provider (including a broker) based on its interest in receiving such Products and Services as disclosed above. Further, if Tilden Park receives Products or Services as a result of doing business with a service provider (including a Broker), Tilden Park will receive a benefit because it does not have to produce or pay for those Products and Services 2.

Tilden Park does not consider Client referrals when selecting or recommending a broker-dealer.

3.

Tilden Park does not engage in directed brokerage.

B. Tilden Park seeks to allocate investment opportunities in a manner that is in the best interest of all Clients, including those Clients with overlapping investment strategies. Tilden Park owes each Client a duty of loyalty and a duty to act in the Client’s best interests. Accordingly, under no circumstances will Tilden Park intentionally favor one Client over another. The Firm has an inherent conflict of interest in allocating investment opportunities as a result of both the relative compensation it receives and relative investor composition among its Clients. Accordingly, it is the policy of Tilden Park to allocate investment opportunities fairly and equitably over time. When it is determined that it would be appropriate for multiple Clients to participate in an investment opportunity, Tilden Park will ordinarily seek to execute orders for all such Clients on a basis that it deems fair and equitable. Tilden Park determines for which of its Clients in a respective investment is considered appropriate and the allocation of such investment among such accounts, taking into account such factors as, without limitation: (a) the relative amounts of capital available for new investments; (b) relative exposure to market trends; (c) the investment programs and portfolio positions of all such Clients; (d) whether the risk-return profile of the proposed investment is consistent with the Client’s objectives; (e) the potential for the proposed investment to create an imbalance in the Client’s portfolio; (f) liquidity requirements; (g) potentially adverse tax consequences; (h) regulatory restrictions that would or could limit a Client’s ability to participate in a proposed investment; (i) the need to adjust the risk in the Client’s portfolio; and (j) each Client’s strategy with respect to a specific investment (e.g., whether to obtain a smaller profit margin and a greater volume of transactions or to try and obtain a greater profit margin with each transaction). Such considerations may result in allocations among the Clients on other than a pari passu basis. When it is deemed to be appropriate, orders may be combined for Clients, and if any order is not filled at the same price, they may be allocated on an average price basis or on any other basis deemed fair and equitable by Tilden Park. Similarly, if such an order cannot be fully executed under prevailing market conditions, securities may be allocated on a basis that Tilden Park considers fair and equitable. The timing of entry into or exit from an investment could vary among Clients for reasons such as differences in strategy, existing portfolio or liquidity needs, and such variations could be detrimental to the non-entering or -exiting Clients. Please also see Item 10.C above.

Client Referrals and Other Compensation A. No one other than the Clients provides an economic benefit to Tilden Park for providing investment advice or other advisory services to the Clients. B. Neither Tilden Park nor any related person directly or indirectly compensates any person who is not a supervised person for Client referrals.

Disciplinary Information In the past ten years, there have been no legal or disciplinary events involving either Tilden Park or any of its management persons that are material to Tilden Park’s advisory business.

Review of Accounts A. Tilden Park’s Chief Investment Officer, Chief Risk Officer, Chief Financial Officer, Chief Operating Officer, and Deputy Chief Compliance Officer review the contents of the Clients’ portfolios informally on a continual basis. B. The Firm does not utilize any specific criteria to trigger a review of Client investments at this time. Nevertheless, as noted in Item 13.A above, Tilden Park reviews the contents of the Clients’ portfolios informally on a continual basis. C. Within 120 days after the Firm’s fiscal year-end, written audited financial statements are delivered to each investor in the Funds. The Firm also intends for investors to receive written unaudited performance information for the Funds after each month, as well as a monthly report providing additional detail on the Funds’ investments. Such reports will include the value of such investor’s interest in the Fund as determined based on the unaudited fair market value of the holdings in the respective Fund. Managed accounts may receive reports as negotiated and reflected in the related investment advisory agreement.

Custody The Firm adheres to the applicable requirements of Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended (the “Custody Rule” and such act, the “Advisers Act”) with respect to each Fund for which it or an affiliate serves as general partner or managing member and ensures that funds and securities are custodied with at least one qualified custodian. The Firm’s CFO is responsible for arranging for the annual audits of the Funds by an independent auditor in accordance with generally accepted accounting principles, and for delivery of the Funds’ audited financial statements to investors within 120 days of the Funds’ fiscal year end. The Firm does not have custody over the assets of the Managed Account, as set forth in the Managed Account’s governing documents. Tilden Park will comply with the Custody Rule for any managed account should the Firm be deemed to have custody.

Investment Discretion Tilden Park has discretionary authority to manage the assets of its Clients. This authority is granted to Tilden Park through an investment advisory agreement, or similar agreement, signed by the Client and Tilden Park or one of its affiliates. Limitations on Tilden Park’s discretionary authority are included in such investment advisory or similar agreements, Fund offering documents and/or Tilden Park’s internal compliance policies and procedures.

Voting Client Securities In the event that any Funds come into possession of securities with voting rights, the Firm has the authority to vote proxies. In accordance with its fiduciary duty to clients and Rule 206(4)-6 of the Advisers Act, Tilden Park has adopted and implemented written policies and procedures governing the voting of Client securities. The Firm’s policy is to vote proxies, or abstain from voting, solely in the best interests of its Clients. Tilden Park will vote all proxies in a prudent manner, considering the prevailing circumstances at such time and in a manner consistent with its fiduciary duties to its Clients. Proxy voting decisions are generally made by an individual member of the investment team that is authorized by Tilden Park to make such decisions, but may also be made collectively by the members of the Firm’s investment team. Clients may not direct Tilden Park to vote proxies in a particular solicitation. Should Tilden Park identify a material conflict of interest in voting a proxy, Tilden Park may defer to the voting recommendation of an independent third-party provider of proxy services or take such other action that Tilden Park determines to be in the best interest of its Clients. Clients may obtain a copy of the Firm’s proxy voting policies and can arrange to view information about how proxies were voted on-site by contacting us at (212) 754-1700 or info@tildenparkcapital.com. For the Managed Account, Tilden Park generally does not accept proxy voting authority, formally advise on particular solicitations or forward proxies. Managed accounts should contact their third-party managers and/or custodian(s) with questions about receiving proxies and the process for voting on such proxies.

Financial Information Tilden Park is not required to include a balance sheet for its most recent fiscal year, does not believe there are any financial conditions reasonably likely to impair its ability to meet contractual commitments to Clients and has not been the subject of a bankruptcy petition at any time during the past ten years.