Ranger Investment Management,L.P.: investment adviser

McCullough, and Brian Busby are limited partners of the Firm. To facilitate the December 31, 2020, separation from Ranger Capital Holdings, LP, Kudu Investment US, LLC (“Kudu”) became a Preferred Limited Partner (“PLP”) of RIM. Kudu is an independent provider of permanent capital solutions to asset and wealth managers worldwide. Kudu receives a revenue share percentage as a PLP, but Kudu does not exercise any control over the management or policies of RIM. In February 2022 Marta Cotton, Head of Marketing & Client Relations, and Dana Ousley, Chief Financial Officer, became limited partners of the Firm. In February 2023, the Firm announced that Brown McCullough was named a Portfolio Manager, and Devin Holland, Senior Analyst, became a Partner of the Firm. Effective December 31, 2023, Dana Ousley, Chief Financial Officer, retired from the Firm, no longer a partner, and no longer holds an ownership interest. Matthew Wade assumed the position of Chief Financial Officer and was named a partner of the Firm. Partnership units previously owned by Dana Ousley were transferred back to the General Partnership and subsequently transferred to Matthew Wade in January 2024. In February 2025, Kevin Zhu, Senior Analyst and Jeff Dalton, Manager of Risk & Sustainability, became limited partners of the Firm. As of December 31, 2025, the Firm managed a total of $1,483,846,197 in regulatory assets under management. Additionally, the Firm advised $413,239,089. in Model Account assets. Services provided to Model Accounts are detailed in the last paragraph of Item 4. Investment Advisory Services RIM provides continuous discretionary investment advisory services and sub advisory services to separately managed accounts (“Separate Accounts”), private pooled investment vehicles (“Private Funds”), Collective Investment Trust (“CIT”), mutual funds (“Mutual Funds”) and together with the Private Funds and Separate Accounts, the “Discretionary Accounts” or

"Clients". Additionally, RIM provides non-discretionary security recommendations in the form of model accounts (“Model Accounts” or “Model Account Clients”). Separate Accounts may include Client assets obtained through a Bank Trust relationship. Investment supervisory services include: (1) establishing a Discretionary Account’s or Model Account’s investment objectives within their applicable investment strategies; (2) buying or selling portfolio securities on behalf of each Discretionary Account; and recommending Model Account security transactions to Model Account Clients; (3) periodically reporting to Discretionary Accounts with respect to current investment holdings, valuations, transactions, capital gains or losses, investment performance, and/or outlook, and (4) periodically reporting to Model Account Clients with respect to current recommended investment holdings, recommended transactions, model investment performance, and/or outlook . The discretionary and Model Accounts (the “Portfolios”) advised by the Firm consist primarily of U.S. exchange traded equity securities of growth-oriented companies within predetermined capitalization ranges,. Generally, the Firm seeks to uncover quality investments by implementing a bottom-up, fundamental research driven security selection process by investing in companies characterized by accelerating revenue and earnings growth, high recurring revenues, strong balance sheets and strong free cash flow generation. The Firm offers the option to participate in its offered investment strategies through either Separate Accounts, interest or shares in pooled investment vehicles, or Model Accounts (as set forth below). Separate Accounts and Model Accounts may provide greater flexibility for a Client with respect to the investment parameters used within the Firm’s investment strategies or other terms of investment. Please see Item 8 – Methods of Analysis, Investment Strategies & Risk of Loss. Investment Strategies RIM provides discretionary and non-discretionary investment advisory services to institutional investors such as mutual funds, private pooled investment vehicles, public and private pension plans, insurance companies, foundations, endowments, and high net worth individuals (which invest through Private Funds or Mutual Funds). In addition, RIM provides indirect investment advisory services to both institutional and non-institutional investors, through shares and interests in registered and unregistered pooled investment vehicles. RIM’s investment process has never and will never incorporate the use of shorting or the use of leverage in any of the Firm’s investment offerings. The Firm primarily manages portfolios of growth-oriented companies characterized by accelerating revenue and earnings growth, high recurring revenues, strong balance sheets and strong free cash flow generation within the following strategies: •

Small Cap Growth Strategy: The Small Cap Growth Strategy seeks long-term growth of capital by investing primarily in common stocks of growth-oriented domestic issuers

which, at the initial time of purchase, are within the capitalization range of issuers represented within the Russell 2000® Growth Index. •

Micro Cap Growth Strategy: The Micro Cap Growth Strategy seeks long-term growth of capital by investing primarily in common stocks of growth-oriented domestic issuers which, at the initial time of purchase, are within the capitalization range of issuers represented within the Russell Microcap® Growth Index.

The Smid Cap Growth Strategy was closed in February 2025; the All Cap Focused and Healthcare Select strategies were closed effective February 2024. In addition to each of the above-mentioned investment strategies, the Firm may, at the request of a Client or otherwise, offer advisory services in sub-strategies dedicated to industry specific segments of an investment strategy, sub-capitalization ranges or expanded capitalization ranges within an investment strategy, or high concentration versions of an investment strategy. In each case, a detailed description of the applicable investment strategy will be set forth in the applicable offering documents and/or investment management agreement. Separately Managed Accounts A separately managed account is a portfolio of securities managed on a discretionary basis by the Firm on behalf of a Client, in accordance with a pre-established investment strategy. Separately managed accounts are initiated through investment advisory, bank trust arrangement, or sub advisory agreements (“Investment Management Agreements”) with the Firm, which define the terms of the Firm’s engagement, the investment strategy, and any thirdparty custodian or other service provider chosen by the Client. The Client generally drafts the Investment Management Agreement, although at the request of the Client such agreement can be provided by the Firm. Investment Management Agreements are therefore highly negotiated agreements, the terms of which can and do differ significantly on a Client-to-Client basis, including without limitation, with respect to fees or investment guidelines. Likewise, Clients may request specific terms with respect to investment guidelines and/or objectives for inclusion within the Investment Management Agreement; and therefore, Clients can, subject to the consent of the Firm and inclusion in the Investment Management Agreement, have portfolios within a specific Investment Strategy which differs in holdings. Generally, the minimum investment threshold required by the Firm to open a separately managed account is five million dollars ($5,000,000). This minimum is negotiable on a caseby-case basis. Private Funds The Firm serves as a general partner and investment adviser to the Ranger Investment Master Fund, L.P., a Delaware limited partnership which is a pooled investment vehicle exempt from registration under the Investment Company Act of 1940. The Ranger Investment Master Fund currently offers one class of limited partnership interest to new investors but has the discretion

to add additional classes of limited partnership interest dedicated to any investment strategy, at any time without prior notice to limited partners: •

Small Cap Portfolio Class maintains a diversified growth-oriented portfolio consisting of approximately 40 to 60 U.S. exchange traded equity securities. The Small Cap Portfolio Class employs the Small Cap Strategy (as described above). This class is managed pari pasu with the Small Cap Growth Strategy.

Client The Private Fund is exempt from registration pursuant to Section 3(c)-1 of the Investment Company Act of 1940. The Firm solicits investors for the Private Fund in accordance with Rule 506 of Regulation D, the Private Fund is available to a limited number of accredited investors. Current and prospective investors should ensure that they can evaluate the merits and risks of an investment in the Private Fund, as set forth in the Private Placement Memorandum of the Private Fund and/or as may be specific to such prospective investor. Mutual Funds The Firm serves as the investment adviser to the Ranger Small Cap Fund, and the Ranger Micro Cap Fund, each a series of the Spend Life Wisely Funds Investment Trust (formerly the Ranger Funds Investment Trust – name change November 30, 2024), an investment company registered with the Securities and Exchange Commission under the Investment Company Act of 1940. The Firm has no control over the board or day-to-day operations of Spend Life Wisely Funds Investment Trust. •

The Ranger Small Cap Fund seeks long-term capital appreciation by investing in growth-oriented U.S. exchange traded equities of small capitalization companies in accordance with the Small Cap Growth Strategy.

•

The Ranger Micro Cap Fund seeks long-term capital appreciation by investing in growth-oriented U.S. exchange traded equities of micro capitalization companies in accordance with the Micro Cap Growth Strategy.

Each Mutual Fund may issue Institutional and Investor Classes of share, with the only difference between the share classes being that Institutional Share Classes have a higher minimum investment requirement and are not subject to 12b-1 fees. Currently only the Institutional Class is open and available to investors. Additional information regarding each Mutual Fund can be found in the mutual fund’s Prospectus and Statement of Additional Information, copies of which can be obtained by accessing www.spendlifewiselyfunds.com, www.rangerinvestmentsfunds.com or by contacting the Mutual Funds’ transfer agent at (866) 458-4744. Model Accounts

The Firm provides Model Account services for particular investment strategies to Clients. Model Accounts are initiated through Model Account agreements (“Model Account Agreements”) with the Firm, which define the terms of the Firm’s engagement, the investment strategy, and other investment parameters. The form of the Model Account Agreement is generally drafted by the Client, although at the request of the Client such agreement can be provided by the Firm. Under this arrangement, the Firm provides Model Account Clients with investment recommendations on a non-discretionary basis based on the agreed upon investment strategy, other investment parameters, and timing. Model Accounts are advised on a nondiscretionary basis, and as such the Firm does not possess the authority or responsibility to determine which securities a Model Account Client purchases or sells within any of such Client’s portfolios, nor does the Firm execute any trade or engage with any broker dealers on behalf of the Client. Each Model Account Client is responsible for determining which securities to buy and sell, the execution of trades, and/or engaging with broker dealers on behalf of its underlying portfolio. Therefore, a Model Account Client’s portfolio performance and security weightings under this product may differ greatly from the Firm’s other portfolios using similar investment strategies.

Accordingly, Management Fees incurred by Clients can vary substantially. In addition, with respect to Separate Accounts, all other terms of such investment, including terms relating to expenses and redemption terms, are negotiable on a case-by-case basis. As such, Client investments in Separate Accounts may provide flexibility with respect to investment terms which are not as readily afforded to investors in the Private Fund or Mutual Funds. Management Fees: Private Fund (Qualified Investors Only) – The Firm currently manages one Private Fund Class under the Ranger Investment Master Fund, LP– Ranger Investment Small Cap Fund. Portfolio. Management Fees may be negotiable for the Ranger Investment Small Cap Fund, are calculated and accrued monthly, payable quarterly in advance per the Private Placement Memorandum (“PPM”). Limited Partners of the Small Cap Portfolio Class are not subject to a performance allocation. To the extent that a limited partner in a Private Fund redeems its investment, the Firm will promptly refund all fees paid in advance for periods after such

applicable redemption date. It is important for private fund investors to carefully read the Fund PPM for a full description of management fees. A second Fund Class (AP3 Small Cap) was established in 2020 that included one Limited Partner. This AP3 Class was subject to a performance-based fee arrangement. This Fund Class was liquidated and closed in March 2024. Mutual Funds – Management Fees are calculated and accrued daily and wired to the RIM account on a quarterly basis by the Mutual Fund’s transfer agent. Collective Investment Trust – (Qualified Plans Only) – The CIT is available as a qualified plan investment vehicle. The CIT remains unfunded currently. Separately Managed Accounts – The time, manner, and fee schedule in which fees are invoiced and paid are negotiable on an account-by-account basis. The Firm calculates the fee based on a reconciled account valuation on a quarterly basis. Generally, the fees are calculated in arrears, but Clients do have the option to choose to be billed in advance. A detail of the fee schedule and manner of invoicing are included in the Investment Management Agreement. The Firm does not charge a minimum fee. The Firm does not maintain authority to unilaterally deduct fees from Separate Account Clients. As described in Item #6 below, performance-based fees are negotiated on a Client-by-Client basis for Qualified /Accredited investors only. Standard Fee Schedule for Available Classes of the Private Funds Private Fund – Classes of Interest

Annual Management Fee

Small Cap Portfolio Class

One Percent (1.00%)

Standard Fee Schedule for Available Classes of the Collective Investment Trust (“CIT”) CIT – Classes of Interest

Annual Management Fee

Unfunded at this time

To be determined

Standard Fee Schedule for Available Ranger Mutual Funds Mutual Fund

Annual Management Fee

Ranger Small Cap Mutual Fund (RFISX)

One Percent (1.00%)

Ranger Micro Cap Mutual Fund (RFIMX)

One Percent (1.00%)

* Non-Institutional share classes of each Mutual Fund listed above may be subject to 12b-1 fees of up to 0.25%.

Standard Fee Schedule for RIM Separately Managed Accounts in Available Strategies RIM Strategy

Annual Management Fee First $25mm

Next $25mm

$50-100mm

RIM Small Cap Strategy

100 Basis Points (1.0%)

Eighty Basis Points (0.80%)

Seventy Basis Points (0.70%)

RIM Micro Cap Strategy

110 Basis Points (1.10%)

Ninety-Five Basis Points (0.95%)

Eighty Basis Points (0.80%)

Above $100 mm Negotiable Negotiable

Fees for RIM Model Accounts The Firm anticipates that the range of services provided with respect to Model Accounts will significantly differ on a Client-by-Client basis. As such, the Firm does not maintain a standard fee schedule with respect to Model Accounts. However, advisory or management fees with respect to Model Accounts generally fall below equivalent fees charged for full service, discretionary accounts based on the same investment strategy. Management Fees and Other Expenses Management Fees are negotiable, depending on the size of the investment and other factors. Management Fees are exclusive to expenses associated with investments in Separate Accounts, Mutual Funds, the Private Funds and/or Model Accounts. Although the Firm is responsible for its overhead expenses, Clients generally bear the cost attributable to their investment activities and operations, which can include, without limitation, expenses associated with a portfolio’s investment program, trading, administration, custody and/or operations. Separate Account Expenses Separate Account agreements are highly negotiated in terms and may differ materially on a Separate Account Client by Client basis. However, on a general basis Separate Accounts directly bear their own costs with respect to the service providers they engage directly, including, without limitation, qualified custodians, accountants, and administrators. Pursuant to the terms of their Separate Account agreements, a Separate Account Client directly or indirectly bears the costs attributable to such Separate Account’s investment activities, including without limitation, costs charged by third party and unaffiliated broker-dealers attributable to trading shares within their portfolios. Additionally, Separate Accounts may be subject to certain indemnification requirements, as set forth within their applicable Separate Account Agreement. Separate Accounts are not charged any expenses attributable to any accounting, operational, legal or compliance services performed by the Firm in connection with such Separate Account.

Private Funds & Mutual Funds The prospectus of each Mutual Fund advised by the Firm and the offering memorandum, subscription agreement and/or other governing document of each Private Fund sets forth the applicable expenses to which a shareholder or limited partner may be subject; and any descriptions of fees and expenses set forth above and below should be deemed examples and/or summaries of the types of expenses a Private Fund or Mutual Fund investor may be subject to, are not intended to be all inclusive, vary on a fund to fund basis, and are qualified in their entirety by the prospectuses and memorandums of the applicable Private Fund or Mutual Fund. Private Funds and Mutual Funds bear the cost attributable to their investment activities and operations, which could include, without limitation, expenses associated with a portfolio’s investment program, trading, administration, custody and/or operations. Such expenses may include, depending on terms set forth within a Private Fund or Mutual Fund’s applicable prospectus or memorandum, and without limitation: (i) expenses incurred in connection with the evaluation, acquisition or disposition of investments, including private placement fees, sales commissions, appraisal fees, due diligence expense, travel costs, expenses associated with tender offers, proxy or consent solicitations, brokerage fees, underwriting commissions and discounts, and legal, accounting, investment banking, consulting, information services and professional fees, (ii) withholding or transfer taxes; (iii) legal fees and costs (including settlement or award costs) arising in connection with any litigation or regulatory investigation instituted against a Fund, or in certain circumstances, the Firm; (iv) specific expenses incurred in obtaining systems, research and other information utilized for portfolio management purposes that facilitate valuations and accounting, including the costs of statistics and pricing services, service contracts for quotation equipment and related hardware and software; (v) the allocated costs of any liability insurance obtained on behalf of a Private Fund or Mutual Fund or, in certain circumstances, the Firm; (vi) expenses incurred in connection with the carrying or management of investments, including, with respect to the Mutual Fund, custodial, trustee, transfer agent, and administrator fees; (vii) the cost of the audit of a Private Fund’s or Mutual Fund’s financial statements and the preparation of such fund’s tax returns; (viii) the fees and expenses of the accountants servicing the Client (including with respect to the Private Fund, reasonable compensation for the Firm’s in-house accountants, which is currently set at an amount equal to five basis points (0.05%) of assets under management) in connection with accounting advice relating to the Client’s day-to-day affairs and all costs related to the keeping of the books and records of a Private Fund or Mutual Fund; (ix) legal fees for services provided to the Private Fund or Mutual Fund by such Fund’s counsel; (x) the costs and expenses of holding any meetings of partners or shareholders which are required to be held under the terms of any agreement or by law; and (xi) all costs and expenses associated with reporting and providing information to existing and prospective investors in the Funds. In addition, NonInstitutional Classes of the Ranger Small Cap Mutual Fund and the Ranger Micro Cap Mutual Fund may be subject to distribution and/or service (12b-1) fees of up to 0.25%. Notwithstanding the above, (i) the Firm may, in its sole discretion, choose to absorb any such expenses incurred on behalf of a Client, and (ii) certain Private Funds or Classes of the Ranger Investment Master Fund, LP (the “Master Fund”) may require the Firm to pay administrative

expenses of such applicable Private Fund or Class, as set forth in greater detail with the Private Placement Memorandum or Limited Partnership Agreement of the Master Fund or such applicable Class. Expense Cap Limitation Agreements The Firm has entered into an expense limitation agreement with the Ranger Small Cap Mutual Fund and the Ranger Micro Cap Mutual Fund to reduce the Firm’s fees and to reimburse expenses, at least until November 30, 2026, such that total annual Fund operating expenses after fee waiver and/or reimbursement (exclusive of any Rule 12b-1 distribution or shareholder servicing fees, taxes, interest, brokerage commissions, acquired fund fees and expenses, or extraordinary expenses such as litigation) will not exceed (i) 1.10% of the Ranger Small Cap Mutual Fund's average daily net assets, and (ii) 1.25% of the Ranger Micro Cap Mutual Fund's average daily net assets, subject to possible recoupment from the appropriate Fund in future years on a rolling three year basis (within the three years after the fees have been waived or reimbursed) if such recoupment can be achieved within the foregoing expense limits. Broker–Dealers The Firm is not affiliated with any broker-dealer. For information describing the factors that the Firm considers in selecting or recommending broker-dealers for Client transactions and determining the reasonableness of their compensation, please see Item 12 – Brokerage Practices. Performance Fees Performance fees are advisory fees which are charged as a percentage of the appreciation of the net asset value of a Client’s account. The Firm, in limited situations and generally at a Client’s request, will consider the application of performance fees as a full or partial alternative to Management Fees. Please refer to Item 6 – Performance Based Fees and Side by Side Management. Compensation to Promoters The Firm may enter into agreements with an affiliated or unaffiliated marketing group or individuals to act as a Promoter of the Firm to Separate Accounts or investors for the Private Funds or Mutual Funds. For their services, such Promoter may receive cash compensation based on a negotiated percentage of the Firm’s Management Fee directly related to the services the Firm may provide to the relevant account or investor. The cash compensation paid by the Firm to t h e Promoter is borne exclusively by the Firm and is not charged back to the Clients who have been solicited by such Promoters. However, because the Firm pays such compensation out of the Management Fees it collects from a Client, such Client may be indirectly impacted pursuant to the level of Management Fees it is able to negotiate with the Firm.

The Firm’s arrangements with an affiliated or unaffiliated marketing group or Promoter may result in a potential conflict of interest by creating an incentive for the Promoter to recommend RIM investment advisory products and services based on compensation received rather than the investor’s needs. The Firm has implemented procedures to ensure compensation arrangements with an affiliated or unaffiliated third-party who act as a Promoter will comply with the new Marketing Rule under the Adviser’s Act. Additional Information •

Additional information regarding the Ranger Small Cap Mutual Fund and the Ranger Micro Cap Mutual Fund can be found in such mutual fund’s prospectus and SAI, a copy of which can be obtained by accessing www.spendlifewiselyfunds.com , www.rangerinvestmentsfunds.com or by contacting RIM at (214) 871-5260 or crteam@rangerinvestments.com.

•

Additional Information regarding the Private Fund can be found in the private placement memorandum and limited partnership agreement, copies of which can be obtained by contacting the RIM at (214) 871-5260 or crteam@rangerinvestments.com.

The Firm employs procedures designed and implemented to treat all Clients fairly and equally, to mitigate potential conflicts of interest attributable to performance-based fee arrangements from influencing the allocation of investment opportunities among Clients. For example, the Firm has implemented a policy whereby all Client orders for a particular security are aggregated and allocated on a pro rata basis electronically prior to making a trade. The Firm’s traders review and monitor Client orders on a real-time basis and the Operations Manager confirms these orders once they are complete. In addition, all accounts with similar investment guidelines are managed pari passu.

Generally, the minimum investment thresholds to open an account are: (i) five million dollars ($5,000,000.00) for a Separate Account, (ii) one million dollars ($1,000,000.00) for a limited partnership interest in a Private Fund, and (iii) between twenty-five thousand dollars ($25,000.00 Investor Class) and two hundred fifty thousand dollars ($250,000.00 Institutional Class), for shares of the Ranger Small Cap Fund and the Ranger Micro Cap Fund, depending on the class of shares (select broker dealers may offer a lower minimum investment). However, the Firm, in its discretion, can waive these minimum investment thresholds.

Following the analysis of these quantitative and qualitative characteristics, the investment team then determines whether a company it believes is undervalued and has sufficient upside to the stock price to warrant an investment. The investment team performs independent, bottom-up, fundamental research on potential portfolio companies and their underlying securities prior to making investment decisions which includes a variety of sources of publicly available information and data. Examples include information produced by publicly traded companies such as audited financial statements and other financial reports. The investment team also considers information obtained through its industry contacts, Wall Street firms, financial news feeds, third party research companies and other publicly available sources. Discussions with company management are also an important source of information. The Firm integrates ESG factors into its investment selection process and philosophy for all strategies. With a focus on financial materiality informed by the Sustainability Accounting Board’s (SASB) industry-specific approach, The Investment Team evaluates a company’s ESG strengths and weaknesses based on original research and management engagement. Research is collected from public company documents, websites, SEC filings, and third-party ratings. Engagement allows the Investment Team to learn first-hand the most important sustainability issues affecting each company and how management is addressing them.

The Firm’s investment team takes a comprehensive and collaborative approach to risk management. This approach starts with security selection and analysis. The research process includes a deep fundamental analysis of each company’s financial profile, growth prospects, and current valuation. It also includes a comprehensive analysis of each company's management team, business model, and competitive landscape. Once a company is purchased, the investment team considers several factors to ensure that each company continues to warrant continued inclusion in the portfolio. The investment team will regularly review each company’s investment thesis, checking for changes in the competitive landscape or diminished growth opportunities. The investment team watches for significant changes, such as transformational acquisitions or management changes, which may signal operational challenges. The Firm’s investment team also takes a competitive approach to capital allocation within the portfolio, ensuring the best ideas receive capital, weaker positions are exited, and stocks trading at less compelling valuations are trimmed or sold. We believe this comprehensive risk mitigation approach helps optimize portfolio construction and improves overall portfolio quality. RISK FACTORS AN INVESTMENT IN ONE OF THE FIRM’S PRIVATE FUNDS, MUTUAL FUNDS OR SEPARATELY MANAGED ACCOUNTS OR PARTICIPATION IN A FIRM ADVISED MODEL ACCOUNT (TOGETHER, A “RIM ACCOUNT”) ENTAILS A HIGH DEGREE OF RISK, INCLUDING THE POTENTIAL FOR LOSS OF ALL OR PART OF AN INVESTMENT. THEREFORE, AN INVESTMENT SHOULD BE UNDERTAKEN ONLY BY INVESTORS CAPABLE OF EVALUATING AND BEARING THE RISKS OF SUCH AN INVESTMENT. THERE CAN BE NO ASSURANCE THAT THE FIRM WILL BE ABLE TO AVOID LOSS, ACHIEVE ITS INVESTMENT OBJECTIVE OR RECEIVE A POSITIVE RETURN ON INVESTMENT CAPITAL. PROSPECTIVE INVESTORS SHOULD CAREFULLY CONSIDER THE FOLLOWING FACTORS IN CONNECTION WITH AN INVESTMENT. PLEASE NOTE THAT THE FOLLOWING LIST IS NOT A COMPLETE LIST OF ALL RISKS INVOLVED IN CONNECTION WITH AN INVESTMENT IN A SEPARATE ACCOUNT OR MODEL ACCOUNT. WITH RESPECT TO A PRIVATE FUND OR RANGER MUTUAL FUND, ADDITIONAL RISK DISCLOSURES CAN BE FOUND IN THE PRIVATE PLACEMENT MEMORANDUM, PROSPECTUS AND/OR SAI OF SUCH APPLICABLE FUND. REFERENCES AND DISCLOSURES RELATING TO ANY PUBLIC OR PRIVATE FUND PRESENTED HEREIN, INCLUDING BUT NOT LIMITED TO: (I) THE INVESTMENT OBJECTIVE, STRATEGIES, RESTRICTIONS AND MANAGEMENT OF FUND, (II) RISKS AND CONFLICTS OF INTEREST ASSOCIATED WITH AN INVESTMENT IN A FUND, (III) DESCRIPTIONS OF SECURITIES PERMISSIBLE FOR INVESTMENT BY A FUND, AND (IV) TERMS FOR INVESTMENT WITHIN A FUND ARE QUALIFIED IN THEIR ENTIRETY BY AND SHOULD BE READ IN CONJUNCTION WITH SUCH FUND’S OFFERING DOCUMENTS AND OPERATING AGREEMENTS, INCLUDING WITHOUT

LIMITATION, ANY PRIVATE PLACEMENT MEMORANDUM, PROSPECTUS, STATEMENT OF ADDITIONAL INFORMATION, LIMITED PARTNERSHIP AGREEMENT, INVESTMENT MANAGEMENT AGREEMENT OR SUBSCRIPTION AGREEMENT. PROSPECTIVE INVESTORS ARE STRONGLY ENCOURAGED TO REVIEW OFFERING DOCUMENTS AND OPERATING AGREEMENTS CAREFULLY, AND CONSULT THEIR INDIVIDUAL FINANCIAL, LEGAL OR TAX ADVISORS PRIOR TO MAKING AN INVESTMENT. INFORMATION ABOUT WHAT OFFERING DOCUMENTS AND OPERATING AGREEMENTS ARE AVAILABLE FOR REVIEW BY A PROSPECTIVE INVESTOR, ALONG WITH APPLICABLE COPIES OF SUCH DOCUMENTS, IS AVAILABLE BY CONTACTING THE FIRM AT (214) 871-5260 OR CRTEAM@RANGERINVESTMENTS.COM Security Selection and Market Risk Security selection risk is defined as the risk that the Firm may not select and size positions appropriately within the Portfolio. An associated market risk arises from the influence of the movements of the overall market, or the value of the individual securities in the Portfolio. The profitability of a significant portion of the Firm’s investment program depends largely upon correctly assessing the future course of price movements and/or the general value of securities and other investments. There can be no assurance that RIM will be able to accurately predict these price movements or future valuation; nor can assurance be given that the Firm’s investment Portfolios will generate income or appreciate in value. With respect to RIM’s investment strategies, there is also a degree of market risk. For these reasons, the Portfolio may also incur losses. Equity Securities RIM Accounts invest in long positions in equity securities. Equity securities fluctuate in value, often based on factors unrelated to the value of the issuer of the securities. The market price of equity securities may be affected by general economic and market conditions, such as a broad decline in stock market prices or in the prices of issuers in a particular market, geographic or industry sector, or by conditions affecting specific issuers, such as changes in earnings forecasts. Micro, and Small Capitalization Companies Micro and Small Cap stocks often involve higher risks in some respects than investments in stocks of larger companies. For example, prices of micro, and small capitalization stocks are often more volatile than prices of large capitalization stocks, and the risk of bankruptcy or insolvency of many smaller companies is higher than for larger, “blue-chip” companies. In addition, due to thin trading in some small capitalization stocks, an investment in those stocks may become illiquid. Micro and small cap companies may be newly formed or have limited product lines, distribution channels and financial and managerial resources. The risks associated with those investments are generally greater than those associated with investments in the securities of

larger, more established companies. This may cause such account’s net asset value to be more volatile when compared to investment strategies that focus only on large capitalization companies. Generally, securities of micro and smaller capitalization companies are more likely to experience sharper swings in market value, less liquid markets in which it may be more difficult for the Firm to sell at times and at prices that the Firm believes appropriate and generally are more volatile than those of larger companies. Compared to large companies, micro and smaller capitalization companies are more likely to have (i) less information publicly available, (ii) more limited product lines or markets and less mature businesses, (iii) fewer capital resources, (iv) more limited management depth and (v) shorter operating histories. Limited Liquidity The investments made by the Micro Cap and Small Cap portfolios may be less liquid than in portfolios that invest in larger companies. Consequently, Micro Cap and Small Cap portfolios may not be able to sell such investments at prices that reflect the Firm’s assessment of their value, or the amount paid for such investments by Micro Cap and Small Cap portfolios. Illiquidity may result from limited daily trading volumes in any particular equity investment or the absence of an established market for the investments as well as legal, contractual or other restrictions on their resale by the Micro Cap and Small Cap portfolio and/or other factors. Furthermore, the nature of the Micro Cap and Small Cap portfolio’s investments may require a long holding period prior to profitability. The operative documents of a Client account may authorize the Firm to make distributions in-kind of securities in lieu of or in addition to cash. In the event the Firm makes distributions of securities in-kind, such securities could be illiquid or subject to legal, contractual, and other restrictions upon transfer. Concentration Risk Generally, the Firm’s investment strategies invest in significantly fewer holdings than that represented by the index benchmarks the Firm uses for comparison purposes. Accordingly, the Firm’s investment strategies may therefore be subject to more rapid changes in value than would be the case if these strategies maintained wide diversification among companies, securities, and types of securities. Potential Loss of Investment There is a risk that an investment in a RIM Account will be lost entirely or in part. An investment in a RIM Account is not a complete investment program and should represent only a small portion of an investor’s portfolio management strategy. Each prospective investor must have enough knowledge and experience in financial and business matters to be capable of evaluating the merits and risks of an investment in a potentially risky investment like a RIM Account, whose performance may be highly volatile. No guarantee or representation is made that the investment strategy of a RIM Account will be successful, that the targeted return or risk will be achieved or maintained, or that the various investment strategies utilized, or investments made through a RIM Account will have low correlation with each other or with the markets.

Overall Investment Risk All securities investments risk the loss of capital. The nature of the securities purchased and traded by the Firm, and the investment techniques and strategies employed to increase returns may increase this risk. While the Firm will devote its best efforts to the management of investment portfolios, many unforeseeable events, including but not limited to actions by various government agencies, the Federal Reserve Board, and/or domestic and international political events, may cause sharp market fluctuations which may negatively impact the investment strategies managed by the Firm. The prior investment performance of a Fund, Separate Account, Model Account, or composite may not be indicative of the future results. Sustainability and Environmental, Social and Governance (“ESG”) Considerations The Firm integrates ESG analysis throughout the investment process. Applying sustainability and/or ESG factors as part of the fund’s security selection process may impact the sub-adviser’s investment decisions. Sustainability and ESG factors are not uniformly defined and applying such factors involves subjective assessments. Sustainability and ESG ratings and assessments of issuers can vary across investment advisers (including subadvisers) and third-party data providers and may change over time. Sustainability and ESG factors can be difficult to apply consistently across issuers, regions, countries, industries, or sectors. The application of these factors could negatively impact the fund’s performance. Sustainability and ESG information from issuers and from third party data providers may be incomplete, inaccurate, or unavailable, which could lead to an incorrect assessment of a company’s sustainability or ESG characteristics. Portfolio Turnover Private Funds, Mutual Funds and Separate Accounts that the Firm advises will not be restricted in effecting transactions by any specific limitations with regard to the Portfolio turnover rate. Market conditions or other unforeseen events may result in substantial Portfolio turnover, which may result in an increase in expense for the investors and/or enhanced volatility. Securities Lending RIM does not participate or manage a securities lending program; however, Clients may participate in a securities lending program through their respective qualified custodian in the ordinary course of its business. Parties that borrow securities from RIM Accounts may not be able to return these securities on demand and may also default on the payment obligations owed to the RIM Accounts in connection with such securities loans. In addition, assets pledged by the borrower as collateral for the borrowed securities may decline in value. The RIM Accounts may be subject to loss with respect to the value of the securities they lend to defaulting borrowers. The Firm does not have authority to lend securities on behalf of Separate Account Clients. Cybersecurity Risks

The Firm and its service providers, counterparties, and other market participants rely extensively on information technology systems to conduct business and manage Client accounts. These systems are subject to cybersecurity, operational, and technological risks that could adversely affect the Firm, its Clients, and the Funds, notwithstanding the Firm’s efforts and the efforts of third parties to implement reasonable safeguards designed to protect the confidentiality, integrity, and availability of information. Unauthorized third parties may attempt to gain access to, modify, disrupt, or disable the Firm’s systems or those of its service providers, counterparties, or other market participants, including through cyberattacks or social engineering techniques intended to induce employees, Clients, or third parties to disclose sensitive information. Cybersecurity incidents may also result from employee error, malfeasance, system failures, or vulnerabilities in third-party systems. If such incidents occur, they could result in the loss or theft of Client or investor information or assets, the inability to access critical systems, loss of proprietary or confidential information, data corruption, business interruption, or costs associated with remediation, system repair, or enhanced cybersecurity measures. The Firm and other affected parties could also be subject to regulatory scrutiny, enforcement actions, reputational harm, additional compliance obligations, or financial losses. Similar cybersecurity and operational risks are present at portfolio companies and other issuers in which Clients invest. Cybersecurity breaches, technology failures, or operational disruptions at such entities could materially adversely affect their business operations and financial condition and, as a result, may negatively impact the value of Clients’ investments.

Legal, Regulatory and Political Uncertainties The Firm and its affiliates are subject to extensive and evolving governmental laws, regulations, and regulatory oversight in the United States and other jurisdictions. Compliance with existing and future legal, regulatory, and tax requirements may result in additional compliance costs, operational constraints, and other burdens, which could adversely affect the operations of the Firm and the performance of a RIM Account. The legal, tax, and regulatory environment applicable to investment advisers, alternative investment funds, the instruments they employ, and the markets in which they operate is subject to ongoing change and interpretation. It is difficult to predict the nature, scope, or impact of future regulatory, legal, tax, or political developments, including changes that have been proposed or adopted but are not yet effective. Such changes, or increased regulatory scrutiny, could adversely affect the efficiency and liquidity of financial markets, limit investment opportunities, reduce the attractiveness or viability of certain investment strategies, increase operational or compliance costs, or require material changes to the structure or operations of the Firm or a RIM Account. Any of the

foregoing could have a material adverse effect on a RIM Account and the value of a Client’s investment. RISKS SPECIFIC TO PRIVATE FUND INVESTMENTS Classes of Interest. The Ranger Investment Master Fund, LP (the “Master Fund”) may issue Classes of Limited Partnership Interest whose investment exposures correspond with segregated portfolios. Each segregated portfolio serves as a fund with a differing investment strategy. As such, each Class of Limited Partnership Interest exclusively participates in the gains and losses attributable to a corresponding portfolio, which is segregated in the books and records of the Master Fund. However, Classes of Limited Partnership Interest are not legally segregated and as such may share in certain expenses and liabilities of the Master Fund as a whole. Although investment portfolios managed on behalf of each Class generally do not invest in products which, in the aggregate, pose liabilities exceeding such Class’s aggregate net asset values, each Class of Limited Partnership Interest could otherwise suffer liabilities and losses to the extent that a liability attributable to a Class exceeds the asset value of such Class. Such cross-liability may originate from any potential liability attributable to any Class of Limited Partnership Interest, including those that are contractual or tortuous in nature, including without limitation such liabilities which are awarded pursuant to litigation or imposed pursuant to a bankruptcy proceeding, including without limitation, contractual or other rights to seek indemnification against the Master Fund or any of its Class by any affiliated or third party (including the Investment Manager) service provider. Unlike legally segregated classes of interests, no assurances can be given that a Limited Partner’s interest in any particular Class of Limited Partnership Interest will not be adversely affected by the liabilities of other Classes within the Master Fund. Dependence Upon Personnel. The success of an investment strategy is significantly dependent upon the expertise of certain investment or support personnel, and any future unavailability of their services could have an adverse impact on a RIM Account’s performance. The success of a RIM Account is also significantly dependent upon the ability of the Firm to hire talented investment and support personnel. No assurances can be given that the Firm will be able to attract or retain necessary personnel. Indemnification of the Firm. The Limited Partnership Agreement of the Master Fund contains broad indemnification and exculpation provisions. These provisions protect the Firm and its respective Affiliates, officers, partners, directors, members, managers, shareholders, employees, or agents and/or legal representatives and Affiliates of such persons (the “Indemnified Persons”) from actions brought by third parties against a Private Fund, the Master Fund, the Firm, and such other persons. In addition, such indemnification and exculpation provisions limit the right of a Limited Partner to maintain an action against the Firm to recover losses or costs incurred by a Private Fund or the Master Fund as a result of the Firm’s actions or failures to act.

Lack of Control by a Limited Partner. Substantially all decisions with respect to the management of a portfolio within the Master Fund are made exclusively by the Firm. The Limited Partners have no right or power to take part in the management or control of a Class or a portfolio. The Master Fund and each Class (or their corresponding portfolios) are managed solely by the Firm. Investors must rely solely on the judgment of the Firm in selecting investments and should not invest in a Class or a Fund unless willing to entrust all aspects of management to the Firm. In the event of the withdrawal or bankruptcy of the Firm, the Master Fund and any of its classes or portfolios may be liquidated. Restriction on Withdrawals and Transfers. There are varying restrictions on withdrawals from the Master Fund and each Class (which may be settled in owned securities rather than cash) and on transfers of Limited Partnership Interests in a Class. The prior written consent of the Firm is required for a transfer of the Limited Partnership Interest of any Limited Partner. Because of the restrictions on withdrawals and transfers, an investment in the Master Fund, its Class or any portfolio may be a relatively illiquid investment and involves a high degree of risk. A subscription for Limited Partnership Interests in any Class within the Master Fund should be considered only by persons financially able to maintain their investment and who can accept a total loss of their investment. Illiquid Investment. An investment in the Master Fund, any Class, or any portfolio must be considered an illiquid investment and involves a high degree of risk. There is no public market for Limited Partnership Interests in any Class, and it is not expected that a public market will develop. An investment in a Private Fund provides limited liquidity since there are substantial restrictions on the ability of a Limited Partner to withdraw capital or to transfer its Limited Partnership Interests in a Class. Involuntary Redemption of Limited Partnership Interests. The Master Fund or any Class may compel the withdrawal of any Limited Partner’s interest, in part or in its entirety, as of the end of any Fiscal Quarter (or any other fiscal period, at the discretion of the Firm) on not less than thirty (30) days’ prior written notice (or not less than five (5) days’ prior written notice if the Firm determines in its sole discretion that such Limited Partner’s continued participation in a Class may cause the Master Fund or the Firm to violate any applicable law). Market Disruption and Lack of Liquidity. A Limited Partner’s ability to withdraw capital from the Master Fund or any Class may be subject to suspension, in whole or in part, based upon the inability of the Firm to value its investments. Significant market events or circumstances attributable to single securities, generally outside of the control of the Firm, could cause a Limited Partner to be required to maintain (and unable to withdraw) its investments in the Master Fund or any Class.

Management Fees. The Management Fee that the Firm will receive has not been established on the basis of an arms-length negotiation between the Master Fund or any Class and the Firm. The Limited Partnership Agreement of the Master Fund or any Class will permit the Firm to receive the Management Fee based on both realized and unrealized appreciation in a Private Fund’s investments. Private Offering Exemption. The Master Fund intends to offer Limited Partnership Interests in any Class on a continuing basis without registration under any securities laws in reliance on an exemption for “transactions by an issuer not involving any public offering.” While the Firm believes reliance on such exemption is justified, there can be no assurance that factors such as the manner in which offers and sales are made, concurrent offerings by other companies, the scope of disclosure provided, failures to make notices, filings, or changes in applicable laws, regulations or interpretations will not cause the Master Fund or any Class to fail to qualify for such exemptions under U.S. federal or one or more states’ securities laws. Failure to qualify could result in the rescission of sales of Limited Partnership Interests at prices higher than the current value of those Limited Partnership Interests, potentially materially and adversely affecting a Private Fund’s performance and business. Further, even non-meritorious claims that offers and sales of Limited Partnership Interests were not made in compliance with applicable securities laws could materially and adversely affect the Firm abilities to conduct the Master Fund or any of its Classes’ business. Lack of Registration. The Limited Partnership Interests in the Master Fund or any Class have not been registered under the Securities Act nor the securities laws of any state nor, in most cases, will they be so registered. The Limited Partnership Interest are subject to specific registration exemptions under the provisions of the Securities Act and laws that depend, in part, upon the investment intent of each investor. Each Limited Partner will be required to represent that he is purchasing his Limited Partnership Interest for his own account and not with a view toward resale or distribution. Neither the Master Fund nor the Firm has any plans nor has assumed any obligations to register these Interests. Accordingly, the Limited Partnership Interests may not be transferred in the absence of an opinion of counsel to the Master Fund that the transfer will not involve a violation of the registration requirements of the Securities Act. Ordinarily, this means that transfers will be restricted to instances of death, gift, passage by operation of law, or transfers to other persons who are accredited investors. These restrictions on transfers are in addition to those found in the Limited Partnership Agreement. Neither the Master Fund nor any of its Classes are registered as an investment company under the Investment Company Act. Investors are not afforded the protective measures resulting from registration under such legislation.

Legal and Compliance Requirements. The Master Fund and each of its Classes must comply with various legal requirements, including requirements imposed by the securities laws, tax laws, anti-money laundering laws and regulations and pension laws in various jurisdictions. Should any of those laws change the legal requirements to which the Master Fund and the Limited Partners may be subject could differ materially from current requirements. Increased oversight or more burdensome compliance requirements could result in increased expenses for the Master Fund or any of its Classes. Possible Effect of Substantial Withdrawals. Substantial withdrawal of Limited Partnership Interest from the Master Fund or any Class could require the Master Fund or any Class to liquidate its investments in securities more rapidly than otherwise desired in order to raise the cash necessary to fund the redemptions or withdrawals. Illiquidity in certain markets could make it difficult for the Firm to liquidate positions on favorable terms, which could result in losses or a decrease in the net asset value of any applicable Class. POTENTIAL CONFLICTS OF INTEREST The non-exhaustive information contained below describes certain potential material conflicts of interest relating to the Firm’s advisory services. No list of potential conflicts of interest can be expected to be full and complete. Each prospective investor should review the relevant disclosure documents and operating agreements carefully, and consult their individual financial, legal or tax advisor prior to making an investment. Information about what offering documents and operating agreements are available for review by a prospective investor, along with applicable copies of such documents, is available by contacting the Firm at (214) 871-5260 or email to: crteam@rangerinvestments.com. Trade Allocation The Firm manages and expects to continue to manage other Client accounts. The Firm has discretionary authority over the investment Portfolios for which it manages on behalf of Clients including proprietary investment Portfolios that it manages on behalf of the Firm. As a general matter, the Firm believes that aggregation of orders for the same security for multiple Clients is consistent with its duty to seek best execution for its Clients. However, in any case in which the Firm believes that aggregation is not consistent with its duty to seek best execution for its Clients, it will not affect the transaction on an aggregated basis. Typically, the Firm allocates orders for the same securities for multiple Client accounts on a pro rata basis in accordance with each account’s investment guidelines as determined exclusively by the Firm’s portfolio manager or his designee. The Firm also allocates orders for initial public offerings on a pro rata basis to the accounts of non-restricted investors or in accordance with de minimis exceptions. Differences in allocation proportions may occur due

to tax considerations, avoidance of odd lots or de minimis numbers of shares, and investment strategies of the accounts. To verify compliance with these policies and procedures, the Firm conducts periodic reviews of the order allocation process. Additional information regarding the Firm’s trade allocation procedures is found in Item 12 – Brokerage Practices. Model Account Trade Recommendations Trade recommendations with respect to Model Accounts are released to Model Account Clients after all discretionary Client accounts participating in the same trade have been executed. The Firm, at its discretion, accepts written instructions from Model Account Clients as to the specific dates or times for the distribution of trade recommendations. The Firm may release the distribution of trade recommendations, at a Model Account Client’s written request, to accommodate the dates and times in which the Model Account Client prefers receipt of such recommendations, but no Model Account Clients shall be distributed a trade recommendation prior to the date and time it is otherwise entitled pursuant to the trade rotation policies set forth above. Model Account Clients may thereby experience account performance and portfolio security weightings that are different from the results obtained when the Firm exercises investment discretion due both to the timing and implementation of recommended trades by a Model Account Client and the impact on market prices with respect to recommended securities, resulting from the Firm’s execution of discretionary trades. Performance Fees. The Firm may, in limited circumstances, charge a performance fee. A performance fee is a variable fee on which the Firm receives a greater level of compensation corresponding to the performance of the Client’s portfolio. Performance Fees may create an incentive for the Firm to invest in securities which may be riskier or more speculative than the securities it would invest in under a different fee arrangement. In addition, the Performance Management Fee arrangements may create an incentive for the Firm to favor performance fee-paying accounts over other accounts with respect to the allocation of investment opportunities, as a performance fee would allow the Firm to indirectly benefit from the gains attributable to such opportunities. Personal Trading Potential conflicts can arise with respect to Firm employees’ personal trading activities in relation to trading on behalf of the Firm’s Clients. An employee trading securities in his or her account prior to trading the same security on behalf of Clients (commonly known as “frontrunning”) is an example of such a conflict. To mitigate this conflict, Employees are required to receive pre-clearance from a member of the RIM compliance team (“Compliance”) and/or a Portfolio Manager prior to purchasing or selling an individual security (with a market cap of $20 Billion or below) owned or to be owned in a personal account. Additional information regarding the Firm’s Personal Trading Policy is found in Item 11 – Code of Ethics.

Soft Dollar Credits The Firm seeks to employ a soft dollar policy that falls within the safe harbor established by Section 28(e) of the Securities Exchange Act of 1934 (“1934 Act”). The Firm’s use of soft dollar credits to pay for research and brokerage products or services might otherwise be borne by the Firm. Accordingly, the authority to use soft dollar credits may give the Firm an incentive to select brokers or dealers for securities transactions, or to negotiate commission rates or other execution terms, in a manner that considers the soft dollar benefits received by the Firm rather than giving exclusive consideration to the interests of the Firm’s Clients. Additional information regarding the Firm’s use of soft dollars and broker selection is found in Item 12 – Brokerage Practices. Outside Business Activities Employees may, from time to time, serve as officers, directors, or trustees of publicly held companies, privately held companies, and/or non-profit organizations. Firm principals, or employees that serve as officers, directors or trustees of companies or organizations generally have fiduciary duties to such companies or organizations, which could motivate them to act in a manner that conflicts with the interests of our Clients. These relationships create potential conflicts of interest because the Firm or an employee of the Firm may have a financial or other interest in, or have an incentive to devote more resources to, companies or organizations for which our employees serve as officers, directors, or trustees. To mitigate this conflict, outside business activities where a conflict may exist require preapproval from Firm principals. Investing in the Private Funds, Mutual Funds, CIT and/or Separate Accounts involves risk of loss that investors should be prepared to bear.

RIM expects employees to place the interests of Clients and the Firm above their own personal interest and to avoid any actual or potential conflicts of interest. Among other things, the Firm’s Code of Ethics requires that all employees comply with applicable provisions of the federal securities laws and report in a timely manner any violations or potential violations of the Firm’s compliance policies and procedures to the Chief Compliance Officer. Personal Trading Policy All employees or Access Persons are prohibited from front running Client accounts and/or acting upon inside information. Under no circumstance may an Employee, or family member living in the Employee’s household, or any account over which an Employee has control, benefit at the expense of investors or the Firm. Personal securities transactions are to be conducted consistent with Firm policy and in such a manner as to avoid any actual or potential conflict of interest or any abuse of an individual’s responsibility and position of trust. The Firm has instituted a Personal Securities Trading Policy whereby Access Persons may trade for their own account(s) or any account where the Access Person has a beneficial interest in securities which may have been recommended to and/or purchased for the Firm’s Clients at some time in the past, is currently owned by Firm Clients, or may be under consideration for purchase or sale for Firm Clients. Under certain circumstances the Firm may recommend to Clients that they purchase securities in which its employees have a financial interest. Access Persons must complete a pre-clearance request via the web-based compliance platform. Permitted investments include, but may not be limited to, equity securities including options, warrants or other derivative, fixed income (corporate and municipal), treasury securities, certificates of deposit, commercial paper, open- and closed-end mutual funds, ETFs, and private placements. Depending on the market cap of the security, transactions can receive automatic approval. Trade requests outside of the market cap minimums will require CCO and Portfolio Manager approval. There is a 30-day holding period for individual securities. The Firm will maintain the pre‐clearance forms and/or periodic e‐mail approvals in conjunction with the record‐ keeping rule.

Notwithstanding the above, the Firm’s consultants, and or service providers may have personal trading policies which differ from the Firm. The Firm’s compliance department may review the personal trading policies of consultants and/or service providers in cases where such persons or entities have access to the Firm’s portfolio information. Based on the activity of the individual(s), they may be required to attest to the Firm’s compliance policies and procedures. In addition to personal trading activities, other policies and procedures found in the Code of Ethics provide guidelines the Firm and/or employees follow with respect to: • Insider Trading

• Political Contributions

• Outside Business Activities

• Gifts and Entertainment

A copy of the Firm’s Code of Ethics is available to current and prospective Clients upon written request to crteam@rangerinvestments.com or rimcompliance@rangerinvestments.com.

the quality, comprehensiveness and frequency of available research products or other services the Firm considers to be of value; and the competitiveness of commission rates in comparison with other brokers satisfying the Firm’s other selection criteria. With respect to research and brokerage products or services provided by broker-dealers, the Firm seeks to maintain a soft dollar policy that falls within the safe harbor established by Section 28(e) of the Securities Exchange Act of 1934 (“1934 Act”). Research and brokerage services, as that term is used in Section 28(e), may include both services generated internally by a broker’s own research staff and services obtained by the broker from a third-party research firm. The research and brokerage services obtained may include a broad variety of financial related information and services, including written or oral research and information relating to the economy, industries or industry segments, a specific company or group of companies, software or written financial data, electronic or other quotations or market information systems, financial or economic programs or seminars, or other similar services or information believed to assist the Firm and its advisory functions and services. The Firm believes that its ability to obtain

such products and services is an integral factor in the level of the advisory fees charged to Clients. The Firm will attempt to place portfolio transactions with broker-dealers who, in its opinion, provide the best combination of price and execution (including brokerage commissions). However, the Firm may pay a broker-dealer a commission for effecting a transaction in excess of a commission charged by another broker or dealer as long as the Firm makes a good faith determination that the amount of commission is reasonable in relation to the value of the brokerage and research services provided by the broker-dealer. The Firm maintains formal and informal internal allocation procedures to identify those brokers who provided it with research and execution services that the Firm considers useful to its investment decision-making process. The amount of commission allocated to any broker will be based, in part, on the cost of such research to the broker, and the amount allocated may be higher than that which the Firm would pay for the research were it to pay for it in cash using its own funds. Clients should consider that there is a potential conflict of interest between their interests in obtaining best execution and the Firm’s receipt of and payment for research through brokerage allocations as described above. To the extent the Firm obtains brokerage and research services that it otherwise would acquire at its own expense, the Firm may have incentive to place a greater volume of transactions or pay higher commissions than would otherwise be the case. The soft dollar research and brokerage services the Firm obtains normally benefits many accounts rather than just the one(s) for which the order is being executed, and not all research may be used by the Firm in connection with the account(s) which paid commissions to the broker providing the research. For example, the Firm may use the commissions paid by its Clients who invest in mid cap securities to obtain small cap securities research services. In this situation, the small cap securities research may benefit only a select group of the Firm’s Clients which is different from the group whose commissions generated the soft dollar credits. Best Execution Reviews On at least a quarterly basis, the Firm holds the Best Execution Committee Review Meeting to determine the quantitative and qualitative value ach broker dealer brought to the Firm over the previous three (3) month period. In attendance at the meeting are members of the Firm’s investment team, traders, and a compliance officer. At the meeting, the participants address issues such as, but not limited to, execution quality, research quality, broker responsiveness, and access to analysts and company management. The meeting participants discuss issues with respect to the active broker-dealers on the approved list to determine whether the commissions earned are commensurate with the value received from the broker-dealers. Following the review, the Firm’s head trader makes appropriate revisions and, together with the compliance department, documents the results of the best execution review.

Periodically, as part of the best execution review, members of the investment team, traders and a compliance officer will discuss general soft dollar activities and possible changes, if any, to the list of all soft dollar services. Examples of soft dollar issues discussed during the best execution review may include: •

Changes to the current level of service

•

Prospective products and services being considered

•

Services that are not being fully utilized are obsolete or redundant and should be eliminated

•

Whether the soft-dollar budget targeted for the current quarter or year is in line with the budgeted amounts

•

Mixed-use allocation determinations

The Firm’s compliance department documents and maintains information discussed during the best execution review. Order Aggregation and Allocation The Firm aggregates trades for the same security in the same strategy and allocates Client orders on a pro rata basis electronically prior to making a trade using RIM’s order management system, Advent Moxy. The traders review and monitor Client orders on a real-time basis. Once a trade is complete, the Operations Manager confirms Client orders. All accounts with similar investment guidelines are managed pari passu. Trading is not segmented across product platforms. The trading desk centrally manages all trades. RIM aggregates trade orders to seek best execution. However, in any case in which the Firm believes that aggregation is not consistent with its duty to seek best execution for its Clients, it will not affect the transaction on an aggregated basis. On such occasions, the Firm’s trading desk will report such exception along with the basis for such exception to the compliance department to appropriately document such exception within an exception report. Directed Brokerage A Separate Account may instruct the Firm to affect securities transactions from said Separate Account through a specific broker-dealer. The Firm considers this instruction to be a “directed brokerage arrangement.” In such circumstances, the Separate Account is responsible for negotiating the terms and arrangements for their account with that broker-dealer. The Firm will not seek better execution services or prices from other broker dealers and may not be able to aggregate the Separate Account’s transactions for execution through other broker-dealers with orders for other accounts advised or managed by the Firm. As a result, the Firm may place a directed trade following aggregated trading activity for a particular security. In addition, the Firm may not obtain best execution on behalf of the Separate Account, who may pay materially

disparate commissions, greater spreads, or other transaction costs, or receive less favorable net prices on transactions for the account than would otherwise be the case. To accommodate certain directed brokerage arrangements, the broker-dealer to whom the trades are directed may not meet the Firm’s standards with respect to institutional quality execution capabilities. In such cases, the Firm may resort to “step out” trades to meet the directed brokerage objectives while continuing to maintain the Firm’s best execution objectives. For example, the Firm places an aggregated trade for a particular security with an institutionally oriented broker-dealer which includes instructions to “step out” the portion of the commission to the broker-dealer designated in the directed brokerage arrangement. Essentially, the brokerdealer the Firm selected executes the trade and sends a check for the portion of the commission amount specified in the instructions to the broker-dealer designated in the directed brokerage arrangement. Soft Dollar Reviews In addition to initial reviews, the Firm conducts quarterly periodic evaluations of its soft dollar products and services to, (1) ensure the products and services continue to provide the value to the investment manager which was originally established upon the initial evaluation; and (2) prepare an annual soft dollar program which it believes is in the best interest of the Firm’s Clients. The Firm reviews the annual soft dollar items to ensure the products and services meet Section 28(e) requirements. Each month, a member of the accounting department reviews and verifies all invoices for soft dollar products and services and then submits them to the Firm’s head trader for verification before forwarding them to the relevant soft dollar broker for payment. The soft dollar broker submits a monthly summary of all payments made for research, as well as a detailed listing of commissions generated with the executing soft dollar brokers. A member of the accounting department reviews all research payments and the Firm’s head trader reviews commissions to ensure payments between the commission list submitted by the soft dollar broker(s) and a commission report generated by the Firm’s portfolio management system has been properly reconciled. The soft dollar broker(s) resolves any issues, and any unresolved disputes will be promptly brought to the attention of the compliance department and the Chief Financial Officer. Mixed-Use Soft Dollar Products and Services In some instances, brokerage and research products or services the Firm receives may also be used by the Firm for functions that are not entirely brokerage or research related (i.e., not related to the investment decision-making process). Where a research or brokerage product or service has a mixed-use, the Firm will make a reasonable allocation according to its use and will pay for the non-research or non-brokerage portion in cash using its own funds. The Firm bases its mixed-use allocation decisions on a reasonable combination of factors such as, but not limited to:

•

The percentage of time devoted to the Firm’s use of the product for research or brokerage in relation to non-research or non-brokerage applications.

•

The relative value of the product for each use as the compliance department determines to be reasonable and appropriate; and,

•

The availability and value of comparable products and services.

The compliance department, in consultation with the investment and trading teams, oversees the evaluation of all mixed-use soft dollar items upon initial receipt of the product or service, and then again on a periodic basis. This evaluation concludes in the establishment of final mixed-use allocation decisions.

The Firm typically remits monthly written reports to its Clients, which set forth various financial data and information. Quarterly and annual reports are also provided on a Client-by-Client basis as directed in the Investment Advisory Agreement. RIM’s operations staff reviews the accounts’ valuation, including net asset value calculations, securities positions and pricing information, interest accrual calculations, and cash balance reports generated by the Firm’s accounting system, custodian, prime broker and/or brokerage firms. Investors in a Private Fund or a Mutual Fund receive an audited annual financial report and the information necessary for the investor to complete annual federal income tax returns.

Fees it collects from a Client, such Client may be indirectly impacted pursuant to the level of Management Fees it is able to negotiate with the Firm. The Firm’s arrangements with a marketing group or Promoter may result in a potential conflict of interest by creating an incentive for the Promoter to recommend RIM investment advisory products and services based on compensation received rather than the investor’s needs. The Firm has implemented procedures to ensure compensation arrangements with an affiliated or unaffiliated third-party who act as a Promoter will comply with the new Marketing Rule under the Adviser’s Act. From time to time the Firm may include the name and/or logo of current separate account clients in marketing materials. Approval by the client is required prior to the use of this information. There is no direct cash compensation from the Firm; as disclosed in Item 5, separate account fees are negotiable. Use of a client name and/or logo is not dependent on any preferential filter or sorting and does not imply that the client is promoting a certain level of skill of the Firm.

The Firm must also comply with additional bookkeeping, auditing, and disclosure requirements, which includes providing investors in the Firm’s Private Fund(s) with audited financial statements on an annual basis. RIM strongly encourages investors and their advisors to closely monitor their account statements, audited financial statements and any other important investment-related materials they receive from the Firm. Any potential discrepancies should be promptly brought to the Firm’s attention by contacting (214) 871-5260.

Client directed restrictions, Client directed “no trading days,” pre-notification of a capital loss, or if a Model Account (the Firm has no discretion over Model Account assets). Discretionary authority only occurs upon full disclosure to the Client and authorization by such Client pursuant to the operative documents and subscription agreement of each Private Fund, the prospectus for a Mutual Fund or an investment management agreement for a Separate Account. Trades made by RIM on behalf of Client accounts for which it has discretion will be in accordance with that portfolio’s investment objectives and goals.

The option to direct the way the Firm votes particular proxy related topics is limited to Separate Account investors only, pursuant to guidelines established in the applicable Separate Account agreement. The Firm has engaged the services of a third-party proxy voting service (the “Proxy Service”) to assist it with administration of the proxy voting process. In addition to general administration assistance, the Proxy Service also includes proxy voting recommendations based upon research and guidelines it publishes. However, the Firm’s proxy voting policies and case-by-case evaluation of each issue may result in proxy votes on certain issues that differ from Proxy Service recommendations. The Firm votes proxies on behalf of the Private Funds, Mutual Funds, and a majority of the Separately Managed Accounts. In connection with any security which is the subject of a proxy vote, the Firm will determine whether any conflict of interest exists between the Firm on the one hand, and the beneficial owners of the securities, on the other hand. If a conflict of interest is identified, the Firm’s portfolio managers, Chief Compliance Officer, and internal or external legal counsel will consult with each other relating to the best method to resolve any actual or apparent conflict between the interest of the Firm and its Clients, in a manner that seeks to vote the best interest of the Client without regard to the conflict. As such, the Firm will determine whether it is appropriate to disclose the conflict to the affected Clients, to give the Clients an opportunity to vote the proxies themselves, or to address the voting issue through other objective means such as voting in a manner consistent with the voting guidelines set forth by the Proxy Service or receiving another independent third-party recommendation. The Firm will maintain a record of the voting resolution of any conflict of interest.

The Firm complies with the SEC N-PX reporting requirement for 13F filers which became effective August 1, 2024. The Firm’s written proxy voting policies and procedures are available for review by investors in each Private Fund, Mutual Fund or Separate Account advised by the Firm. In addition, the Firm maintains a record of all proxy votes cast on behalf of the Private Funds, Mutual Funds, and many of the Separate Accounts it advises; such records are available for review by the Client upon written request to crteam@rangerinvestments.com. Class Action Lawsuits From time to time, the Firm may receive notices regarding class action lawsuits involving securities that are or were held by the portfolios of a Private Fund, a Mutual Fund or upon request, certain Separate Accounts it advises. As a matter of policy, the Firm refrains from serving as the lead plaintiff in class action matters and refrains from submitting proofs of claim where the Firm believes, in its sole discretion, which either the recovery amounts are likely to be negligible, or such participation is not in the interest of the applicable account. As a result, the Firm may on behalf of Clients forgo participation in class action lawsuits.