Ejf Capital LP: investment adviser

Wilson previously managed both the Alternative Asset Investments and the Private Wealth Management groups at FBR and served as a Branch Chief with the U.S. Securities and Exchange Commission in Washington, DC. EJF is an investment advisory firm that started its investment advisory operations in September 2005. EJF is a Delaware limited partnership that converted from a Delaware limited liability company on January 1, 2026. Emanuel Friedman, Neal Wilson and Jason Ruggiero are the management members of EJF Capital GP LLC, the general partner of the Firm. A third-party investor, Kudu Investment Management LLC (“Kudu”), which is registered with the SEC as an investment adviser, owns a minority economic stake in EJF. EJF has one affiliated entity located in London, United Kingdom. EJF also has three relying advisers. Contact information for EJF’s headquarters, its affiliated entities, and the relying advisers is as follows: EJF Capital LP 2107 Wilson Boulevard, Suite 410 Arlington VA 22201 EJF Capital Ltd. 16 Berkeley Street London, UK W1J 8DZ EJF CDO Manager LLC 2107 Wilson Blvd, Suite 410 Arlington, VA 22201

EJF Investments Manager LLC 2107 Wilson Blvd, Suite 410 Arlington, VA 22201 Armadillo Financial Partners LLC 2107 Wilson Boulevard, Suite 410 Arlington, VA 22201 Types of Advisory Services EJF provides discretionary investment advisory services and sub-investment advisory services to pooled investment vehicles and single investor funds (each, a “Fund”, and collectively, the “Funds”). EJF serves as the manager for the Funds and is responsible for the Funds’ trading and other day-to-day activities. Armadillo Financial Partners LLC (“Armadillo”) provides portfolio management services to certain Funds that invest in loans and other financing transactions with law firms. EJF Investments Manager LLC (“EJFIM”) provides portfolio management services to certain Funds that invest in collateralized debt obligations (“CDOs”). EJF CDO Manager LLC (“CDO Manager”) provides collateral and portfolio management services to securitized asset funds and CDOs. Each of Armadillo, EJFIM and CDO Manager are included in Form ADV, Schedule R, as relying advisers. EJF does not tailor its advisory services to the individual needs of investors in its commingled Funds. EJF is subject to investment guidelines and limitations with respect to some of the Funds. These investment guidelines and limitations (if any) are described in each Fund’s offering documents (or a separate document) and monitored in EJF’s portfolio management system (to the extent practicable). EJF also provides discretionary and non-discretionary investment advisory services and subinvestment advisory services to separately managed accounts (“SMAs,” together with Funds, each a “Client”, and collectively “Clients”) and single investor Funds. With regard to SMAs, the advisory accounts are managed according to the Client’s investment guidelines and limitations as they appear in the Client’s investment management agreement or a separate document. EJF develops and maintains model portfolios and securities baskets that are comprised of securities. These models and baskets are licensed or otherwise made available (including through

the wrap program in which EJF participates) to third party investment advisers and intermediaries. Other than the Wrap Program Clients (defined below), the end-users of the model portfolio and/or basket data are granted a limited license to utilize the data for their own business purposes, which may involve utilizing such data as an investment strategy for their own investment portfolios and/or their underlying client accounts. Wrap Program EJF provides discretionary model management services as part of a wrap-fee program (“Wrap Program”) offered by an investment adviser/broker-dealer (“Sponsor”). A wrap fee program is a program where a client is charged a specified “bundled” fee (generally, a percentage of assets under management) for discretionary investment management services and trade execution costs and sometimes other services such as custody, record keeping and reporting. In connection with the Wrap Program, EJF provides model portfolio recommendations via the Sponsor’s platform, but has no discretionary authority or responsibility for asset allocation or securities selection on behalf of any account on the platform. EJF does not act as Sponsor for the Wrap Program and is not an affiliate of the Sponsor. The Sponsor provides various services to its clients (“Wrap Program Clients”), which typically include portfolio management, trade execution, custody, performance monitoring, reporting, and other services for an all-inclusive fee (“Wrap Fee”). The model management services EJF provides to Wrap Program Clients are only available to clients of the Sponsor who have opened an investment account with Sponsor or one of its affiliates who also offer the Wrap Program. The Sponsor pays EJF a portion of the Wrap Fee received by the Sponsor from those Wrap Program Clients whose accounts utilize the model managed by EJF. Under the Wrap Program, the Sponsor retains discretionary responsibility for the asset allocation and securities selection on behalf of Wrap Program Clients and is responsible for defining the Wrap Program Client’s overall investment objectives, making suitability assessments, executing transactions, contacting the Wrap Program Clients to ascertain whether there has been any change in their financial circumstances or objectives and communicating this information to EJF. EJF utilizes a third-party service provider to execute certain purchases and sales, subject to the general oversight of the Sponsor. In addition, EJF makes itself reasonably available to the Sponsor and the Wrap Program Clients for joint consultations. EJF does not offer or provide the same or similar model management services to any Clients other than the Wrap Program Clients. The model management services EJF provides for Wrap Program Clients do not reflect the impact that material economic, market and other factors would have had on EJF’s decision making if EJF were managing a portfolio of assets pursuant to a particular model. Unlike for its other Clients, EJF also does not recommend cash management activities or

include money market or cash-equivalent investments as part of its model management services. The investment results achieved utilizing EJF’s model management services at any given time could and will differ from the investment results achieved for EJF’s Funds and other Clients, including for the same or similar investments. Assets Under Management As of December 31, 2025, EJF managed client assets on a discretionary basis in the approximate amount of $6,036,600,141. As of December 31, 2025, EJF managed client assets on a nondiscretionary basis in the approximate amount of $64,675,177.

Funds As the investment adviser responsible for managing the Funds, EJF charges a maximum management fee of 2% based on AUM, and a maximum performance-based compensation of 57.5% of the Funds’ profits, or 25% of the Funds’ profits over a stated preferred rate of return. EJF could agree to charge certain Funds or certain Funds’ investors lower management fees and performance-based compensation, even if the assets are managed in a similar investment style. EJF may also decide to waive all or a portion of the Firm’s negotiated fees for a given period or for a particular Client or investors. For example, EJF may decide to negotiate its management fee because of the timing of an investor’s subscription to a Fund, the amount of investor’s assets within the portfolio, or other relationship to the Firm. Certain Clients are invested in Funds managed by EJF, in which case those Clients will be placed in a non-fee paying class of the Funds in which they are invested (certain EJF employees are in a non-fee paying class). Certain Funds calculate and pay management fees to EJF monthly in arrears, and several Funds calculate management fees on a quarterly basis in arrears. A small number of funds calculate and pay management fees to EJF in advance. In addition, EJF manages several Funds that are closed

to new investors and do not pay any management fees. Certain investors in the Funds have special management fee arrangements that are described in the Funds’ offering documents. In the case where management fees to EJF are advanced and the advisory contract with EJF is terminated before the end of the billing period, investors will receive a prorated refund from the Fund. Investors can request the refund by written notice to the Fund requesting a prorated refund. Certain Funds that are open to new investors calculate and pay performance-based fees at the end of the Fund’s fiscal year and several Funds calculate and pay performance-based fees at the dissolution of the Fund. These fees may be subject to preferred return hurdles, catch-up allocations and/or claw-backs, depending, among other things, on the strategy of the Fund. Funds - Deduction of Management Fees Management fees for all Funds are deducted either monthly, quarterly, or semi-annually from each Fund’s portfolio. Management fees are first segregated into an escrow account by EJF personnel pursuant to EJF’s written money transfer policies and procedures. Management fees remain in the escrow account until the Fund’s administrator verifies the amounts. After the administrator verifies the management fee amounts, the administrator moves the assets to an EJF bank account. Funds - Transaction/Trading Costs Broker-dealers executing Client trades generally charge a brokerage commission on equity securities and a markup or markdown on fixed income securities. For example, fixed income securities trade at a bid/ask spread and have no explicit brokerage expense. Although there is no brokerage commission charged on fixed income securities transactions, the Funds will incur the implicit trading cost reflected in the broker/dealer spreads. For additional information regarding the Firm’s trading practices, see Item 12, Brokerage Practices. Securities transaction costs are paid by the Client, not EJF. In addition to transaction costs, certain Funds also pay expenses that include but are not limited to: organization costs, modeling expenses, custodian fees, legal and audit expenses, taxes, pricing services, and administrative fees. Additional information regarding transaction costs is located in Item 12, Brokerage Practices. Funds - Other Fees or Expenses Charged to the Funds To the extent permitted under the applicable offering documents, as amended from time to time, Funds advised or sub-advised by EJF bear all of their operating expenses, including but not limited to some or all of the following expenses directly or indirectly: (i) fees or expenses associated with structured products or other securities in which the Funds invest, such as management fees associated with collateralized debt obligations, exchange-traded funds, money market mutual funds, or other securities, and, in the case of transactions that are not consummated, broken deal

expenses; (ii) investment expenses (e.g., expenses that the Fund determines to be related to the investment of the assets of the Fund, including, among others, all expenses relating to identifying, monitoring, investigating, researching, purchasing, acquiring, selecting, making, financing, hedging and disposing of investments, due diligence and research expenses (including market research), collateral valuation services, referral fees, origination fees, and costs incurred by EJF principals and employees and third parties in connection with their attendance at conferences (including all lodging, transportation, meal and entertainment expenses), risk analytical software for use by the Fund, investment-related data services (including fees, costs and expenses related to hardware (including Bloomberg terminals), software (including any order management system software) and subscriptions (including Bloomberg subscriptions)), fees or commissions of any futures commission merchant, brokerage commissions custodial fees and expenses, expenses relating to reorganizations, restructurings and workouts involving investments, costs and charges for equipment or services used in communicating information regarding the Fund’s transactions between the general partner and the Fund’s custodian or other agents, bank service fees, interest expenses, borrowing costs, fees and expenses of consultants or experts retained to provide services related to any of the foregoing, investment expenses and extraordinary expenses); (iii) sourcing fees (including referral fees, success fees, origination fees, finder’s fees and other compensation paid to third-party senior advisors, sourcing partners and/or operating partners); (iv) fees and charges of clearing agencies; (v) interest and commitment fees on loans and debit balances; (vi) income taxes, withholding taxes, transfer taxes and other governmental charges and duties (including fees, costs and expenses incurred in connection with governmental and regulatory filings) as well as expenses incurred in connection with tax preparation; (vii) fees of legal advisors (including legal expenses related to investments), independent auditors, accountants, fund administrators, trustees and expenses for oversight, or other third-party service providers that facilitate administrative and portfolio monitoring services, research services or software for the Fund; (viii) professional fees (including fees and expenses of consultants and experts) relating to investments; (ix) board members’, directors’ or advising committee (e.g., of a strategic advisory panel composed of senior attorneys with expertise in mass torts, product liability or other types of litigation and/or such other persons that EJF has determined to have specialized expertise in litigation matters or the claims that serve as collateral for or may otherwise be related to an investment) fees and expenses (including compensation of the members thereof), if any, (x) the costs of any liability insurance, deal-related insurance, or fidelity bonding obtained on behalf of or for the benefit of the Funds; (xi) the costs of maintaining the Funds’ recognition, registered agents and registered offices in a variety of jurisdictions; (xii) costs incurred costs in connection with any claim, litigation, arbitration, mediation, government investigation or dispute in connection with the business of the Fund and the amount of any judgment or settlement paid in connection therewith, or the enforcement of the Fund’s rights against any person; (xiii) the costs of any communications with investors, including providing reports and notices; (xiv) travel expenses, including, but not limited to, all lodging, transportation (including first-class arrangements), meal and other entertainment expenses incurred by employees or principals of EJF and its affiliates or

third parties in furtherance of the Fund’s activities; (xv) any broken-deal expenses; (xvi) initial and ongoing offering expenses, including expenses relating to the Fund’s organizational documents and the subscription agreement or other agreements entered into with any investors (including expenses related to negotiations with investors and potential investors (including with respect to the negotiation and entering into of side letters) and expenses or fees related to electronic subscription agreement products or platforms), as well as expenses relating to the review and processing of subscription agreements and related documentation with respect to prospective subscriptions for interests, any modification to or supplement of such documents, any distribution of such documentation to the investors and prospective investors and certain costs associated with the Fund complying with such agreements or legal requirements, and any printing costs, marketing costs and legal fees;(xvii) fees for escrows, storage, custodians and other out of pocket expenses; (xviii) expenses relating to the transfer, withdrawal or redemption of interests in the Fund; (xix) fees and expenses of a service company retained to provide accounting, administrative and/or bookkeeping services (including fees and expenses incurred in connection with the oversight and/or maintenance of the Fund and its investments); (xx) prime brokerage expenses; (xxi) quotation or valuation expenses (including fees and expenses of any third parties engaged to provide valuation or appraisal services to the Fund); (xxiii) indemnification and contribution expenses as defined in the underlying documents of the Fund or in underlying transaction documents; (xxiv) all costs and expenses incurred as a result of the restructuring, reorganization, dissolution, winding up or termination of the Fund; (xxv) costs and expenses of any third parties retained by EJF in connection with any research, third-party examinations or audits by regulatory or other similar authorities, including the costs associated with the production and review of materials requested in such examination or audit; and (xxvi) historical and ongoing expenses related to the development and licensing of a technology platform used to assist with loan administration and/or due diligence of borrowers’ cases or collateral and the tracking of such collateral, including the fees charged by any consultant retained to assist in the foregoing and any other similar or related fees and expenses. For certain Funds, the Client will pay additional fees for outside service providers, such property managers, operating partners, development or sourcing fees and other investment-related fees, some of which service providers are affiliated with the general partners. These fees and expenses will vary and may or may not be appropriate for you on your Fund. A portion of these operating expenses may be shared with other Clients, EJF or its affiliates. For more information on broken-deal expenses, refer to “Clients – Fee and Expense Allocation Generally”. EJF and its affiliates are permitted to receive transaction fees, breakup fees, “topping” fees, advisory fees, consulting fees, director’s fees (including cash and non-cash compensation) and similar fees in connection with actual or contemplated investments; provided that, in any case, EJF and its affiliates are not permitted to receive compensation that would amounts to accelerated advisory fees or fees for broker-related services. It should be noted that EJF, or its affiliates, acts as administrator for some Clients’ accounts, and it receives a fee for performing such services.

Such fees partially reduce or offset management fees for one or more but not for all of our Clients, which presents a conflict of interest. Conflicts of interest arise due to the disproportionate allocation of such fees. It should also be noted that Clients may invest in securities such as structured products that are issued or managed by entities that are owned by affiliates of EJF or other Clients. In such cases Clients may be paying management or performance fees, or economic compensation to other Clients or other affiliates of EJF, that are dilutive to Clients’ returns. EJF may also allocate economic interests in such vehicles to clients in connection with their investments to offset a portion of the related expenses or performance returns. In connection with its marketable loan strategy (described below), EJF has commissioned the development of a system to improve the administration, tracking, processing and analysis of loans, collateral underlying such loans, and various due diligence and valuation mechanics. The development of this technology platform as well as the ongoing maintenance, may be allocated to the applicable funds in this strategy. Funds – Investors Certain Fund investors in certain classes of Funds are subject to additional up-front fees of up to 2.5%, as well as ongoing fees of up to 1.0% per annum. These additional fees are ultimately paid to placement agents. The placement agent receives an up-front fee based on the dollar amount invested by the investors placed with the applicable Fund. The placement fee is ultimately paid by the Fund investor. In certain circumstances, EJF will pay a portion of its management fee and/or performance-based fee to placement agents in connection with their services for referring investors to the Funds. In these instances, an investor may be placed in a higher or lower paying fee class of the Fund than if the investor came to EJF directly. With regard to redemption fees, certain Funds could charge an investor if it redeems from the Fund prior to the one-year anniversary of each subscription date. EJF may also waive all or a portion of a certain investor’s redemption fees. Several Funds have private equity structures with investment periods of 5 years or more with no redemption rights. In general, investors are not allowed to redeem from private equity funds until the lockup period has expired. Where applicable, investors subscribing for interests at subsequent closings of a closed-ended Fund generally will participate in existing investments, diluting the interest of existing investors therein. Although such investors generally will contribute their pro rata share of previously made draws (plus an additional amount to existing investors, including affiliated investors thereon), there can be no assurance that this payment will reflect the fair value of such investment vehicle’s existing investments at the time such additional investors subscribe for interests.

SMAs As noted above, EJF manages a number of Discretionary SMAs (defined below) and nondiscretionary SMAs on a sub-advisory basis. The maximum management fee charged by EJF to Discretionary SMAs is 1.25% (on an annualized basis), payable monthly in arrears, and a 15% performance-based fee, generally payable, when applicable, at fiscal year-end. The management fee charged is based on AUM. For SMAs that are sub-advised by EJF and its affiliates, EJF will receive a portion of the management fee from the SMA’s investment adviser, but EJF will not charge the individual client any management or performance fee. Furthermore, EJF does not charge any expenses to SMAs that are sub-advised by EJF or its affiliates, but the SMAs will, depending on the type of investment, be subject to direct expenses similar to those applicable to fund Clients described above. None of EJF’s SMAs pay any management fees in advance. Fees for SMAs are negotiated and memorialized in each SMA’s investment management agreement. SMA clients could pay a management fee that is higher or lower than another client, based on factors such as the amount of assets managed for the account and the negotiated percentage of the management fee. Certain SMAs calculate and pay performance-based fees at the fiscal year end while other SMAs pay performance-based fees at the liquidation of certain investments or strategies. These performance-based fees may be subject to preferred return hurdles, catch-up allocations and/or claw-backs, depending, among other things, on the strategy of the SMA. SMA - Deduction of Management Fees SMA clients (or their representatives) are provided an invoice reflecting the amount of management fees charged for the period in question. Some SMA clients pay EJF directly; other SMA clients direct their custodian or a representative to pay the management fee to EJF. EJF employees do not deduct management fees from SMA client accounts. SMA - Other Fees or Expenses Charged to SMAs SMA clients are generally charged a brokerage commission or other form of transaction cost for trades executed in their accounts. For example, equity securities are generally charged a brokerage commission while fixed income securities incorporate a markup/markdown into the execution price. Fixed income securities trade at a bid/ask spread and have no explicit brokerage expense. Although there is no formal brokerage expense, the SMA clients will incur the implicit trading cost reflected in the broker-dealer spreads. In connection with SMAs for which EJF acts as a sub-adviser to a Wrap Program, certain accounts will be enlisted in such Wrap Program for which there is a “fee in lieu of commission” or similar

“wrap fee” arrangement. In most circumstances EJF will direct transactions for such accounts to the Sponsor in recognition that commissions are often included in the price of this “wrap fee.” In addition, SMA clients could be subject to custodian fees, wire transfer fees, and transaction fees charged by third-party custodians. All fees charged to an SMA client’s account are reflected on the brokerage account statements received by each SMA client. For additional information regarding brokerage transaction cost, please see Item 12, Brokerage Practices. Clients - Fee and Expense Allocation Generally Occasionally, EJF will incur fees or expenses that are associated with the management of a Client’s account. If permissible, in accordance with applicable operating and investment management agreements, EJF will allocate the fees or expenses to the Client or seek reimbursement from the Client’s account. When EJF incurs expenses on behalf of multiple Client accounts, in accordance with the applicable operating and investment management agreements, EJF allocates the expenses among the applicable Clients in a fair and equitable manner. In some instances, it is not possible or practical, in the Firm’s opinion, to allocate all expenses ratably across all of the Clients’ accounts. On such occasions, the Firm allocates fees or expenses disproportionately among Clients, or EJF assumes a portion or all of certain Clients’ fees or expenses. Accordingly, certain Clients will receive more favorable fee and expense treatment over other Clients’ accounts. In addition to organizational fees and expenses associated with Funds or SMA operational management, Clients may incur additional fees or expenses as they invest in special purpose vehicles, pass through vehicles, or other special investment vehicles. EJF will seek to minimize any redundant fees or expenses where possible and occasionally absorb certain organizational costs. This practice can disproportionately benefit certain Clients, especially when such costs are related to co-investment opportunities of other Clients. Expenses related to investment sourcing and diligence in a particular strategy include fees, costs and expenses of identifying, investigating (including conducting diligence with respect to), evaluating, structuring and negotiating potential investments for such strategy. A large category of sourcing and diligence expenses are those expenses incurred with respect to the pursuit of particular investments that are never actually consummated. Examples of such “broken-deal expenses” include fees and expenses of any legal, financial, accounting, consulting or other advisors or lenders investment banks and other financing sources in connection with arranging financing for transactions that are not consummated; any travel and accommodation expenses; and any deposits or down payments that are forfeited in connection with, or amounts paid as a penalty for, unconsummated transactions. These expenses are borne by Clients that conduct the majority of the origination activity for such strategy, however other Clients in the strategy from time to time

receive economic interest or investment rights in the consummated investments but did not bear the broken deal expenses. In managing a Client’s account, EJF endeavors to allocate broken deal expenses on a fair and equitable basis. Notwithstanding the foregoing, certain co-investors typically do not agree to pay or otherwise bear these broken deal expenses. This can be because the broken deal expenses have not been identified yet or their anticipated allocation has not yet been identified. In addition, coinvestors are often introduced to the investment opportunity at a later stage in the process and therefore, are not yet committed to the potential investment or are not contractually required to bear the broken-deal expenses. A conflict of interest arises when co-investors are not required to pay such broken-deal expenses while other Clients remain on the hook. Additional Compensation EJF and/or its affiliates may receive fees, other compensation (including management fees) or reimbursements for internal and external costs or expenses in connection with the provision of portfolio management, asset management and operational support in connection with asset management and/or investment advisory services to portfolio companies or issuers of securities that are owned by Clients in their managed accounts. No such fees, compensation or reimbursements for costs or expenses will be paid to the Clients (or offset against, or otherwise be applied to reduce, the management fee) provided that any such fees or other compensation paid to EJF and/or its affiliates by such portfolio companies or issuers will be charged at rates no less favorable to such portfolio companies and issuers than the rates charged by a third party provider of the applicable services in arms' length transactions. Neither EJF nor any of its employees or affiliates is paid additional compensation, such as brokerage commissions, for purchasing or selling securities placed in a Client’s portfolio. It should be noted that EJF, or its affiliates, has acted as administrator for at least one Client’s account, and it has received a fee for performing such services. Additionally, there are instances where an EJF affiliate, owned by EJF and/or Clients and controlled by EJF or its affiliate, depending on the type of Client will receive fees such as collateral management fees, and loan or property management fees in connection with such services. EJF will receive a share of such fees proportionate to EJF’s ownership interest in the affiliate, where applicable. Certain investors investing Funds will receive a partial rebate of their management fee to offset such fees received by EJF. For additional information on such rebates and offsets, refer to “Funds - Other Fees or Expenses Charged to the Funds.”

EJF believes that it has policies and procedures that will result in fair trade allocations to Clients over time, even though a particular trade allocation appears to benefit one or more accounts when viewed individually. Whenever possible, EJF will bunch trade orders to minimize trade execution cost and to assist with obtaining best execution. There could be occasions when EJF does not allocate a particular security to a Client in the same investment strategy as another Client that received a trade allocation. Reasons for not allocating a security to a Client include but are not limited to the following: the investment guidelines/restrictions do not permit the purchase of the security; the Client’s portfolio currently contain the prescribed limits of the security or a similar security that is designed to fill the same investment objective; the Client does not have a sufficient cash balance to participate in the trade; the Client has a different risk/return profile than another account, the Client has materially different tax consequences than another account, the Client has unique investment goals; the Client has different liquidity requirements; or a security is only issued in increments of a certain size and the smallest increment of the security for the allocation exceeds the Client’s limit. These limitations to allocation could result in different investment holdings, and performance returns for Clients with assets in the same investment strategy and managed by the same portfolio management team. As stated in Item 5, EJF also charges its Clients an asset-based management fee. As noted above, certain Funds managed by EJF are charged an annual performance fee. This fee is up to 57.5% of the excess, if any, of the net asset value of each series of units or shares in a Fund over a high-water mark and, in certain cases, a hurdle. Certain Funds, as well as classes within Funds, are not subject to a high-water mark. Additionally, the Firm, in accordance with applicable provisions of the Fund’s offering documents, may transfer investors between classes. Not all investors in the Funds are subject to the 57.5% performance fee charged by the Funds. In addition, certain Funds are subject to claw-back provisions with regard to performance fees. Generally, performance fees are not finally determined with regard to private equity funds until the Fund is closed and assets are returned to Fund investors. Certain other Funds and certain SMAs generally pay EJF performance fees annually. However, on a monthly or quarterly basis, a performance fee accrual is made on EJF’s books for each applicable Client.

With regard to certain SMA clients for whom EJF acts as investment adviser, not in sub-advisory capacity, EJF is entitled to receive an annual performance fee of up to 10% of any realized and unrealized capital appreciation of AUM (at least one SMA client may pay a performance fee that is less than 15%), subject, in certain cases, to a threshold amount. Performance-based fees are negotiable. EJF does not charge any of its Clients a flat fee or a fee that is calculated based on hourly rates.

The minimum investment amount to open an SMA is generally $10,000,000, and for those SMAs in which EJF acts as sub-investment adviser, including, the Wrap Program, the minimum investment amount is $100,000. EJF and its affiliates reserve the right to waive the minimum investment amount for investors in the Funds or individuals/entities opening SMAs.

EJF generally employs a value-based, fundamental approach to security selection with a macro overlay based on the regulatory environment. Regardless of the strategy utilized, EJF believes that value for Clients is ultimately achieved through a long-term view that focuses on unlocking value in the wake of new legislation and/or regulatory changes.

All Clients utilize one or more of the following strategies in accordance with their respective mandates and governing documents: Public Equity Strategies One of EJF’s equity strategies is designed to pursue absolute returns, and to achieve long-term capital appreciation from investments providing exposure to securities issued by companies primarily within the banking and broader financial services industry operating in certain regions of the world. EJF will generally emphasize individual security selection (“bottom-up” investing) and considers a wide range of factors in determining whether a security is overvalued or undervalued. EJF takes long positions in companies that it believes to be high quality with aboveaverage growth at attractive multiples, and short positions in companies that it believes are underperforming relative to the market. EJF uses an equity long/short strategy for Funds, and long-only strategies for a Fund and sub-advised SMAs, that primarily seek to invest in securities that are listed, quoted, or traded on stock markets domestically and internationally. Another equity-focused strategy seeks to take advantage of tactical investment opportunities primarily in non-bank financial services companies. Investments in this strategy are not limited to equity investments as it involves investing across the capital structure of such companies, however, it is primarily invested in equity securities issued by companies engaging in spin-off transactions and tender offers. The strategy also utilizes constructive engagement with company management teams that can benefit from EJF’s in-house capital markets expertise and historical investment acumen. Securities in this strategy are issued by either domestic or foreign companies. A Fund using this strategy may also invest in securities consisting of packages of securities that have equity-like characteristics or equity-like returns. These securities could include the purchase or sale of put or call option contracts, shorting shares of common stock or debt, and other securities that EJF finds appropriate. Private Equity and Credit Strategies EJF’s private equity focused strategies aims to capitalize on US small and community banks impacted directly or indirectly by: (1) bank and thrift recapitalizations and/or restructurings; (2) merger and acquisition activity; and (3) bank regulatory capital limitations; (4) government financial reform. Equity and debt capital provided to the companies may be used for loan growth, acquisitions, infrastructure and technology buildout or other general corporate purposes including balance sheet restructuring. EJF typically receives board seats, board observation rights and management information rights when investing in these institutions.

A changing regulatory regime has resulted in banks and similar financial institutions deleveraging their portfolios and seeking to dispose of certain higher-risk assets that they view as “capitalinefficient” (i.e., the capital requirements imposed on banking and similar financial institutions in connection with holding certain assets makes their retention by such institutions impracticable and unattractive). Additionally, while an active market has developed for the disposition of such assets by large commercial banks, the Firm believes that, as a result of having a smaller capital base and limited access to capital markets, regional and community banks have had fewer options for efficiently deleveraging and disposing of these assets. The Firm will seek to leverage its experience in the capital markets, including its experience with community banks on behalf of the strategy, to take advantage of market opportunities that are available in the financial industry and related sectors as a result of these changes and, potentially, other market opportunities that become available in the financial industry. The Fund will seek to achieve its objective of designing capital solutions with financial institutions through utilizing credit defaults swaps, debt, hybrid debt securities and collateralized debt obligations. Additionally, the strategy may incorporate the use of equity ad warrants, real estate related loans and leases, and cash and short-term investments. Periodically, EJF affiliates managing private equity funds may come into possession of material non-public information that restricts other EJF affiliates from investing in, or engaging in purchase and sale transactions with certain public issuers. CDO and CLO Securities. For certain of its Clients, EJF may design structured finance products including Collateralized Debt Obligations (“CDOs”) and Collateralized Loan Obligations (“CLOs”) which are generally limited recourse obligations of the issuer thereof payable solely from the collateral owned by such issuer or the proceeds thereof. The value of such securities generally will fluctuate with, among other things, the financial condition of the obligors or issuers of the underlying portfolio of assets of the related CDO or CLO, general economic conditions, the condition of certain financial markets, political events, developments or trends in any particular industry and changes in prevailing interest rates. Consequently, the holders of such securities must rely solely on distributions on the underlying collateral or proceeds thereof for payment in respect thereof. If distributions on the underlying collateral are insufficient to make payments on such securities, no other assets will be available for payment of the deficiency and following realization of the investment, the obligations of such issuer to pay such deficiency generally will be extinguished. The underlying collateral may consist of high-yield debt securities, loans, asset- or mortgagebacked securities and other instruments, which often are rated below investment grade (or of equivalent credit quality). High-yield debt securities generally are unsecured (and loans may be unsecured) and may be subordinated to certain other obligations of the issuer thereof. The lower ratings of high-yield securities and below investment grade loans reflect a greater possibility that adverse changes in the financial condition of an issuer or in general economic conditions or both

may impair the ability of the related issuer or obligor to make payments of principal or interest. Such investments may be speculative. Non-Marketable Loan Strategies An investment objective under this strategy is to earn interest income by providing financing to plaintiff law firms participating in mass tort litigation or other similar litigation. The investment strategy could result in highly concentrated and illiquid positions. This strategy seeks to provide loans to law firms; such loans are secured by the firms’ interests in future award settlements from selected dockets (i.e., a group of cases against one defendant or group of defendants) of mass tort cases. The strategy will primarily focus on lending in three areas of mass tort litigation: (i) pharmaceutical, (ii) medical devices, and (iii) other product liability including asbestos/mesothelioma. Additionally, the strategy may take advantage of other similar opportunities in financing plaintiff law firms participating in other types of litigation. Real Estate Strategies EJF’s real estate investment strategy is designed to take advantage of certain opportunities arising from recent tax reform in the country and can invest in a broad range of real estate and real estaterelated investment opportunities. This strategy seeks to maximize value through acquisition or funding of ownership interests in individual real estate assets, joint ventures, special purpose vehicles related to real estate or real estate related assets. Such investments are anticipated to be longer-term in nature and will involve developers or other third parties. This strategy will primarily focus on investments operating in qualified opportunity zones that can provide potential tax benefits to investors. Venture Capital Strategy EJF’s venture capital strategy seeks to achieve attractive risk-adjusted returns, principally through venture capital investing in equity, equity related investments, SAFE investments, forward purchase agreements, convertible preferred equity, debt, convertible debt, digital assets, warrants, options, and other derivatives issued by early-stage private companies related to the financial sector positioned for growth. The strategy seeks to invest in disruptive companies that aim to bridge the gap between legacy financial institutions and the financial services ecosystem of the future. The strategy may invest on an opportunistic basis and, as such, may seek to make venture or venture-like investments in sectors and industries both related and unrelated to the financial services industry and/or the technology sector, including nascent industries that are emerging or that may emerge over the life of the strategy.

Risks Relating to Investment Strategies The investment strategy for each of EJF’s Clients involve a substantial degree of risk of loss that Clients should be prepared to bear. The Firm has listed certain risks below; however, the list of risks is neither comprehensive nor complete. Clients and investors are strongly encouraged to review the risks of their investment strategy, as contained in the private placement memorandum, in organizational documents and/or as set forth in the Client’s investment management agreement. In addition, while certain risks may be more important for certain investment strategies, certain risks may overlap and apply to multiple investment strategies. For example, on certain occasions EJF and/or its related persons may engage in transactions where EJF and/or its related persons will provide liquidity for certain Clients through conflicted or cross transactions. Such transactions present the risk of costing Clients potential future investment income. On such occasions, EJF strives to provide disclosure to the Client prior to the transaction. Public Equity Strategy Related Risk EJF’s Public Equity Strategy is to seek to seize upon improperly valued publicly traded securities in the market, and sectors that EJF deems an opportunity. Each strategy may be subject to such risks as a fluctuation in securities prices and interest rates, movement in the United States’ and certain foreign countries’ economic growth rates, political events that may have an impact on equity markets, concentration risk, macroeconomic risks, contagion risk, liquidity risk, volatility, and valuation. EJF is an active manager of risk and will utilize short positions, derivatives such as put and call options and other various hedging techniques to reduce volatility and risk of loss. Private Equity and Private Credit Strategy Related Risks While the Firm strives to attain the investment objective of the Funds through its research and portfolio management skills, there is no guarantee of successful performance, that the investment objective can be reached or that a positive return can be achieved. As a general rule, investors can expect that investments with higher return potential will also have higher potential of risk of loss of capital or income. Prospective investors in the Funds should consider the following risks, which are not intended to be an exhaustive listing of all the risks involved in an investment in this strategy. Clients could have control positions in addition to advisory roles in private equity and credit investments, along with certain contractual rights to protect their investments (including shareholder agreements, redemption rights and/or placement of a designee of the Firm or an affiliate on the boards of directors or as a board observer of portfolio companies), but such Clients do not always have control over their portfolio companies. A Client runs the risk of refusal of management or shareholders of portfolio companies to adopt the recommendations of such Client, disagreement with existing management and any resulting negative impact on the value of the

portfolio company or such Client’s ability to exit from such investment at a profit as a result of such refusal or disagreement. Should such a refusal or disagreement occur, EJF or an affiliate may not be in a position to exercise control over the management of such companies, and, accordingly, may have a limited ability to protect such Client’s position in such companies. Certain investments involve a newly formed entity which has not commenced operations and therefore will have no operating history upon which an investor can evaluate its performance. The prior experience of the investment team or the performance of other investment vehicles does not provide assurance of future investment performance or returns. A Client may be called upon to provide follow-on funding for its investments or may have the opportunity to increase its investment in private companies and other investments. There can be no assurance that a Client will wish to make such follow-on investments or have available capital to do so, and the inability to make such follow-on investments could have a substantial negative impact on a portfolio company or other issuer in need of capital or may diminish such Clients’ ability to influence the portfolio company’s or other issuer’s future development. Non-Marketable Loan Strategy Related Risk The following risks are associated with the non-marketable loans within the law firm lending strategy:

No guarantee that cases (collateral for loans) will be successful; Timing and amount of case settlements could be substantially different than expectations; Borrowing law firms could cease to operate, dissolve, or file for bankruptcy; Borrowing firms may divert proceeds from cases to other creditors; Delayed payments may cause accrued income to exceed available collateral; Defendants could file for bankruptcy; Changes to law, regulation, administrative process, or the general legal and economic environment may substantially impact the success of the cases; Tort reform or award limitations could reduce tort litigation or damages awarded to plaintiffs; and Potential for conflict with state ethics bar guidelines regarding confidentiality and lending relationships with borrowing firms.

Real Estate Related Risk EJF’s strategy is based, in part, upon the premise that real estate businesses and assets will be available for purchase that are considered favorable. The strategy relies, in part, upon local market

conditions throughout the term of the investment. No assurance can be given that real estate businesses and assets can be acquired or disposed of at favorable prices or that the market for such assets will remain stable, recover, or continue to improve since this will depend upon events and factors outside of EJF’s control. Additionally, there can be no assurance that market conditions may not deteriorate during the Client’s investment period, which could have a materially adverse effect on the Client’s assets. Actual or perceived trends in real estate markets do not guarantee, predict or forecast future events, which may differ significantly from those implied by such trends. The activity of identifying, completing and realizing attractive real estate investments that fall within a Client’s investment objective is highly competitive, and involves a high degree of uncertainty. The availability of investment opportunities generally will be subject to market conditions. In particular, in light of changes in such conditions, including changes in long-term interest rates, certain types of investments may not be available to a Client on terms that were as attractive as the terms on which opportunities were previously available to the Client or other Clients. Additionally, any changes in applicable tax law or regulatory guidance may have an impact on the strategy, which could cause the Firm to revise its investment strategy. The Firm in its sole discretion may elect to change the investment strategies and/or practices in order to satisfy the provisions of the tax law. Such changes may cause the Firm to incur significant cost and/or avoid or execute on transactions it otherwise would not have, which could impact performance. Venture Capital Strategy Related Risk Making venture capital investments tends to be more speculative than later-stage investments and there is a greater risk of loss of up to the entire amount invested because the investments are generally attempting to do business in nascent or developing areas (where business models are not yet proven) and the competition for gaining market share or a proven product may be particularly intense. The securities in which the strategy will invest will generally be among the most junior in a company’s capital structure, and thus subject to the greatest risk of loss. The strategy’s investments will generally be in minority positions in companies, in many cases without power individually to exert significant control over such companies’ boards of directors and management, although on occasion a majority position of the securities of a company may be purchased. While the strategy may seek to get the appropriate governance and exit rights at the time of making minority investments, there may be instances in which EJF may not be able to exercise control over such company. In addition, in certain situations, including where the businesses are in bankruptcy or undergoing a reorganization, minority investors may be subject to the decisions taken by majority investors, and the outcome of the Client’s investment may depend on such majority-controlled decisions, which decisions may not be consistent with the Client’s objectives.

Generally, the companies will be at a relatively early stage of development, thus entailing significant operating and financing risk. In many instances, a venture capital investment may require additional infusions of capital in order to protect earlier investments, although there is no guarantee that such additional investments will lead to a successful investment or be available to the same Client who made the initial investment. Some financial technology companies are also subject to extensive governmental regulation which may limit the proposed services and profitability of such companies. Profitability is largely dependent on the ability of such newly formed companies to develop technology that is widely adopted and difficult for competitors to replicate, as well as the financial health of financial services companies that are likely to purchase technology or enter into service agreements with such financial technology companies. As the technologies and services offered by financial technology companies expand and mature, they are likely to become more exposed to wellestablished competitors. The financial technology companies in which the strategy may invest, as well as the third-party purchasers (including, without limitation, banks and other financial institutions) of products developed by such financial technology companies, operate within a highly regulated environment and may, depending on the scope of services provided and/or technology being developed, be directly or indirectly subject to extensive federal, state and international legal and regulatory restrictions and limitations, as well as supervision, examination, licensing and enforcement by regulatory authorities. The application of such laws and regulations, whether directly or indirectly, to EJF’s investments may materially impact the business and profitability of such financial technology companies. Moreover, such laws and regulations are complex and may lack clear judicial or regulatory interpretation or guidance. Violation of such laws and regulations could result in significant fines and penalties to financial technology companies and/or banks and financial institutions with which such companies transact, which in turn could have an adverse effect on the strategy. Management Risk As a result of the sector-focused investment strategy of certain EJF strategies, Clients maintain an outsized exposure to a significant portion of the U.S. banking and financial industry. As a result of such ownership and concentration in the U.S. banking sector and the close relationships between EJF and its personnel and affiliates, on the one hand, and portfolio companies in the U.S. banking sector, on the other hand, EJF may be incentivized to take into account such relationships when making decisions on behalf of its Clients. EJF often has or obtains data, information and expertise in the course of managing client accounts that provide a material benefit to EJF, other EJF accounts and/or their portfolio companies. Moreover, EJF may be incentivized to pursue and manage investments for its Clients that have data, information and other benefits, including asset

management and investment advisory fees that that benefits EJF, other EJF accounts and/or their portfolio companies. EJF’s clients and Funds will not receive any compensation or other benefits in respect thereof, unless the governing documents for such client account or Fund require otherwise. Notwithstanding these potential conflicts of interest, EJF will seek to make investments for its Clients in a manner that is consistent with its fiduciary obligations. In addition, EJF will use reasonable efforts to mitigate any potential conflicts of interest that arise as a result of the level of EJF concentration in the U.S. banking sector described herein, but may not be able to entirely mitigate the outsized influence of certain existing portfolio companies as a result thereof. Additionally, there are various business relationships between investors in several EJF Funds and the investments of other Clients. For example, from time to time a portfolio company of a Client will be a service provider to one or more of EJF’s Clients investments, including, with respect to the provision of lending, asset management, consulting, financing or brokerage services. In addition, in certain cases, portfolio companies of one Fund may compete with portfolio companies of another Client (e.g., for clients and market share). In making decisions to take or refrain from taking certain actions on behalf of certain Clients, EJF will also face conflicts of interest associated with the relationships described above. For example, EJF may be incentivized to cause or encourage existing or future investments of a Client to receive services of a portfolio company of another EJF account. The performance of such portfolio companies, and in turn, Clients, will be impacted by the performance of such service provider portfolio company of the other Client. However, EJF will only make investment decisions for a Client in good faith and in a manner that is consistent with its fiduciary obligations to the Client. One or more portfolio companies of a Client, or investors in a Fund, may also, from time to time, acquire securities issued by EJF. For example, EJF has issued debt securities of EJF, which may be traded on secondary markets. It is possible that financial institutions that are portfolio companies of Clients or investors in a Fund will from time to time acquire such debt securities without the prior knowledge, or approval, of EJF or any of its affiliates. As such, the performance of any such person that acquires debt securities of EJF may be impacted by the performance of EJF. In particular, in the event that EJF defaults on its obligations in respect of the debt securities of EJF held by portfolio companies, such clients may be adversely impacted. In addition, certain banks and other financial institutions that are portfolio companies of EJF Funds are expected to seek to invest in other EJF accounts (including potentially by investing capital obtained from the Client investments), which may create certain additional conflicts of interest for EJF. Moreover, EJF may be inclined to cause Clients to make an investment in a portfolio company in order to incentivize such portfolio company to make an investment in another Client account. Such portfolio companies may hold significant investments in such other EJF accounts and may serve on an advisory panel of such other EJF account of EJF Fund, which may exacerbate such conflicts. The performance of such portfolio companies, and in turn, Clients, will be impacted by the

performance of such other Client accounts. Notwithstanding the foregoing, EJF will act in accordance with its fiduciary duties to its Clients. Force Majeure Events Certain force majeure events (meaning those events beyond the control of the party claiming that the event has occurred, including unexplainable occurrences (acts of god), fire, flood, earthquakes, war, terrorism, outbreaks of infectious disease, pandemics, labor strikes, national and international political circumstances, and conditions in the global financial markets, all of which may give rise to trade and travel barriers, volatility in commodity prices and currency exchange rates and/or controls) may negatively affect the economy, infrastructure, the livelihood of people throughout the world, the level and volatility of securities prices, the liquidity and value of any EJF Fund’s investments and the operations of the EJF. Any such event, including a public health emergency like the COVID-19 pandemic, may also adversely affect the ability of EJF Funds and their investments, counterparties of any of the foregoing or other persons or entities to perform their respective obligations. In addition, there are increased risks relating to EJF’s reliance on computer programs and systems if EJF’s personnel are required to work remotely for extended periods of time as a result of events such as the outbreak of infectious disease or other adverse public health developments (such as the COVID-19 pandemic), natural disasters or other force majeure events, including an increased risk of cyber-attacks and unauthorized access to EJF’s computer systems, which risks may also apply counterparties of EJF and the Funds. Many businesses, including EJF, may also permit their personnel to continue to work from home in response to future public health emergencies. Derivative, Futures, Forwards and Other Security Risk Each of the strategies could use derivatives, futures, forwards, synthetic instruments, staking validators or other mechanisms or instruments as supplemental instruments to implement leverage, hedges, yield enhancement, protection or exposure to certain areas such as: currency, interest rates, geographic locations, sectors, credit, commodities, and other fields. There is no guarantee that use of such instruments will achieve their intended objective, and their use may create unintended consequences and risks for EJF’s Clients. Additionally, use of such instruments has inherent risks. The use of such instruments involves a variety of material risks, including the possible use of leverage and the possibility of counterparty non-performance, as well as of material and prolonged deviations between the actual and the theoretical value of a derivative (e.g., due to nonconformance to anticipated or historical correlation patterns). In addition, the markets for certain instruments are frequently characterized by limited liquidity, which can make it difficult, as well as costly, for Clients to close out positions in order to realize gains or to limit losses. Some of the instruments

that Clients trade are “principal-to-principal” or “over-the-counter” (“OTC”) contracts between the Clients and third-party dealer firms (typically major securities firms) entered into privately, rather than on an organized exchange. The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) comprehensively regulates the OTC derivatives markets. The Dodd-Frank Act requires that a substantial portion of OTC derivatives that were historically executed on a bilateral basis in the OTC markets be executed on qualified, regulated exchanges or execution facilities and submitted for clearing to clearing houses. The Commodities Future Trading Commission (“CFTC”) and other regulators also have imposed margin requirements on non-cleared OTC derivatives, increasing the trading counterparties’ costs, which are expected to be passed through to other market participants. Clearing, margining and exchange-trading requirements make it more difficult and costly for investment funds, to enter into OTC transactions. They also render certain strategies in which a Client might otherwise engage impossible or so costly that they will no longer be economical to implement. Finally, the clearing requirement will centralize risk in a small number of clearing houses and their members, thereby increasing the impact of the failure of a clearing house. Market Liquidity In some circumstances the markets can be illiquid, making it difficult to acquire or dispose of investments at the prices quoted on the various exchanges or at normal bid/offer spreads quoted off exchange. During periods of limited liquidity, the strategies’ ability to acquire or dispose of investments at a price and time that the strategies deem advantageous may be impaired. As a result, in periods of rising market prices, the strategies may be unable to participate in price increases fully to the extent that they are unable to acquire desired positions quickly; conversely, the strategies’ inability to dispose fully and promptly of positions in declining markets will cause their NAV to decline as the value of unsold positions is marked to lower prices. In addition, given the sizeable positions held by various Clients, EJF may be limited in its ability to efficiently and/or profitably exit or reduce exposure to particular positions or strategies. Cybersecurity and Cloud Infrastructure Risk As part of its business, EJF processes, stores and transmits large amounts of electronic information, including information relating to the transactions of its clients. Similarly, EJF’s service providers and its clients may process, store and transmit such information. Some information is stored on off-site servers by certain vetted cloud-based service providers. EJF has controls, procedures and systems in place designed to protect such information and prevent data loss and security breaches. However, such measures cannot provide absolute security. The techniques used to obtain unauthorized access to data, disable or degrade service, or sabotage systems change frequently and

may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design or manufacture or other problems that could unexpectedly compromise information security. Network connected services provided by third parties to EJF may be susceptible to compromise, leading to a breach of EJF’s network. EJF’s systems or facilities may be susceptible to employee error or malfeasance, government surveillance, or other security threats. Online services provided by EJF to its clients may also be susceptible to compromise. Breach of EJF’s information systems may cause information relating to clients (including client transactions) to be lost or improperly accessed, used or disclosed. EJF’s service providers and its Clients are subject to the same electronic information security threats as EJF. If a service provider fails to adopt or adhere to adequate data security policies, or in the event of a breach of its networks, information relating to Clients (including Client transactions) may be lost or improperly accessed, used or disclosed. The loss or improper access, use or disclosure of EJF’s or its Clients’ proprietary information may cause EJF or its Clients to suffer, among other things, financial loss, business disruption, liability to third parties, regulatory intervention or reputational damage. Any such event could have a material adverse effect on Clients and their investments. Model Management EJF provides model portfolios and other model management services pursuant to data licensing and other agreements. The risks of using a model portfolio allocation depend on the risks of the underlying investments represented in such model portfolio. Model portfolio users are also subject to the risk that the selection of model constituents and the allocation and reallocation of assets among such constituents might not produce the desired investment result. Model portfolios are typically constructed using forward-looking assumptions, forecasts, and estimates, and as a result, will not reflect the impact of subsequent material economic developments and future market factors that are not available to be considered, and the constituents of a particular model have changed and may change in the future. Errors may occur in the design, writing, testing, validation, maintenance, monitoring and/or implementation of a particular model portfolio or technological systems utilized in the construction of a model portfolio or the provision of model management services. Moreover, the case of the Wrap Program, updates to a particular model EJF provides in connection with its model management services may be delayed or contain an error. While updates are provided periodically in accordance with a defined, randomized production schedule, there is no guarantee that an enduser will timely receive model portfolio data. Accordingly, such end-users should be aware they may be competing for applicable investment or disposition opportunities with other end-users who have also received the same data.

Although EJF takes reasonable steps to develop a model, there can be no assurance that EJF will successfully do so. There is no guarantee that the use of a model portfolio or model management services will result in effective investment outcomes. Fraud In making certain investments, EJF may rely upon the accuracy and completeness of representations made by the issuer of such investment, but it cannot guarantee the accuracy or completeness of such representations. The issuer of an investment may make a material misrepresentation or omission with respect to the issuer of the investment. Such inaccuracy or incompleteness may adversely affect the strategies or the valuation of any investment. Instances of fraud and other deceptive practices committed by senior management of certain companies in which the strategies may invest may undermine the ability of EJF to conduct effective due diligence on, or successfully exit investments made in, such companies. In addition, financial fraud may contribute to overall market volatility, which can negatively impact the strategies’ investment programs. Under certain circumstances, payments to Clients may be reclaimed if they are later determined to have been made with an intent to defraud creditors or make a preferential payment, which can result in a mismatch of remedy to those harmed if Fund investors reduce or redeem their investment before such payment is received by the Fund. Certain Clients may also be exposed to significant risk due to a service provider’s failure to prevent fraudulent conduct, including wire fraud. While EJF oversees all service providers and has instituted reasonable measures to mitigate risk through its due diligence and oversight activities, there is no guarantee that such activities will be effective. Failure of Custodians and Key Service Providers The custodians, banks, brokerage firms and other key service providers selected by EJF may become insolvent, causing the strategies to lose all or a portion of the funds or securities held by the custodian, secondary custodian or such banks or brokerage firms or other counterparty acting as a custodian or to encounter delays recovering assets and hamper day to day operations. Environmental, Social, Governance Risks The Firm recognizes the importance of considering environmental, social and governance factors on its investment. The Firm may evaluate the importance of these risks differently between Clients and strategies.

These notice filings allow EJF to market certain Funds to prospective investors in the countries where the filings have occurred. Relationships Material to Advisory Business As discussed above in Item 4, EJF has a number of affiliated entities; these entities are: EJF Capital Ltd. (the “UK Affiliate”), CDO Manager, EJFIM and Armadillo. EJF established the UK Affiliate in the United Kingdom (“UK”), which performs research activities. EJF owns 100% of the interests in the UK Affiliate. CDO Manager is a relying adviser on EJF’s Form ADV and serves as collateral manager for certain CDOs and note securitization products. EJFIM owns 51% of the interests in CDO Manager.

EJFIM is a relying adviser on EJF’s Form ADV, serves as manager of certain funds. EJF owns 100% of the interests in CDO Manager. Armadillo is a relying adviser on EJF’s Form ADV and serves as manager for certain funds. EJF owns approximately 51% of the interests in Armadillo. Also, as noted previously, Kudu, an investment adviser registered with the SEC, owns an economic minority stake in EJF. Kudu’s investment is passive and non-controlling, and the Firm does not believe it presents a material conflict of interest with any Client. From time to time, Kudu recommends that its clients invest in the Clients or refers its clients to EJF. However, such referrals are not material to EJF’s business. Broker-Dealers EJF has entered into a number of solicitation agreements with registered broker-dealers. Under the solicitation arrangements, broker-dealers refer to EJF high net worth individuals or entities that the broker-dealer has determined are qualified to invest in EJF’s products. Broker-dealer solicitors are generally paid a percentage of the management fee and/or the performance fee received by EJF from the Fund in which the high net worth individual or entity invests. These broker-dealers may issue, underwrite, sponsor or facilitate certain securities in the capital markets for themselves or the benefit of their clients. EJF will purchase and sell such securities for Client accounts as an investment for their account. While these investments are made independent of the aforementioned business relationship, they nonetheless present a conflict of interest for EJF. EJF also has arrangements with broker-dealers that receive a placement fee for placing investors in certain EJF Funds. The broker-dealer placement agent could receive a fee that is up to 2.5% of the assets invested in the Fund by the placed client (this is a one-time fee ultimately paid by the investor). Certain broker-dealers also receive an ongoing fee up to 0.5% per annum of assets invested in a Fund by the placed investor (this fee is also ultimately paid by the investor). It should be noted that an investor’s account can be charged higher or lower Management and/or Performance-based fees of the Fund than if the investor came to EJF directly. A full description of applicable fees can be found on the applicable Fund’s offering memorandum, EJF’s subscription documents, as well as the investor’s account statements. EJF may maintain placement agent agreements with broker-dealers that may also act as executing brokers, prime brokers, custodians, trustee, or other vendors of Clients. EJF does not believe such relationships are material, but could pose a conflict of interest for its Clients. Additionally, EJF also issued notes, bonds and other borrowing facilities with certain lending institutions that are affiliated with broker-dealers or other financial institutions. EJF believes such

relationships are may pose a conflict of interest for EJF and its Clients and will restrict Clients from owning such securities. Pooled Investment Vehicles EJF manages the following pooled investment vehicles: EJF Debt Opportunities Master Fund II, LP, EJF Debt Opportunities Fund II, Ltd, EJF Debt Opportunities Master Fund, LP, EJF Debt Opportunities Fund, LP, EJF Debt Opportunities Offshore Fund, Ltd, EJF Financial Services Fund LP, EJF Financial Services Offshore Fund, Ltd, EJF Opzone Fund I LP, EJF Opzone Fund II LP, EJF Sidecar Fund, Series LLC – Small Financial Equities Series and EJF Sidecar Fund, Series LLC – Series F, LP, EJF Ventures Fund LP, EJF Ventures Offshore Fund LP, EJF Financial Debt Strategies Fund LP, EJF Financial Debt Strategies Offshore Fund LP, EJF Funding Offshore LP, EJF Tactical Opportunities Fund LP, EJF Tactical Opportunities Offshore Fund LP, Rocade Capital Fund IV LP, Rocade Capital Offshore Fund IV LP and EJF Rocade Fund V LP collectively, the “Rocade Funds”). For additional information on the Rocade Funds, refer to “Law Firm Lender Joint Venture.” In addition, CDO Manager, Armadillo and EJFIM manage or advise pooled investment vehicles. Specifically, Armadillo manages or advises Armadillo Financial Offshore Fund III LP and Armadillo Financial Holdings III LP. EJFIM serves as the manager for EJF Investments Limited and EJF Investments LP. CDO Manager serves as the collateral manager for the following securitized asset funds: Attentus CDO I, Ltd., Attentus CDO II, Ltd., Kodiak CDO I, Ltd., Kodiak CDO II, Ltd., TruPS Financials Note Securitization 2022-1 Ltd., TruPS Financials Note Securitization 2025-1 Ltd., TruPS Financial Note Securitization 2025-2 Ltd., TruPS Financial Note Securitization 2025-3 Ltd and TruPS Financial Note Securitization 2026-1 Ltd. SMAs generally invest in Funds and certain of our Funds with a private credit strategy invest in securitization. EJF manages multiple Client accounts with similar mandates, strategies and even similar holdings which may create conflicts of interest. The Firm is not obligated to devote any specific amount of time, resources, or effort in managing any Clients’ accounts. Furthermore, Clients’ accounts from time to time compete for investment opportunities, research, internal resources, or even allocation of trades. Certain Clients from time to time also invest in different parts of the capital structure of the same issuer, which may advance or conflict with interests of other Clients, and may directly or indirectly provide economic benefit to other Clients. These transactions impact the valuation, solvency, liquidity and ultimately the performance of Client accounts, and subsequently EJF’s fees, which poses a conflict of interest. For addition information on the conflicts that relate to such investments, refer to Item 12, Brokerage Practices – Conflicts

of Interest. Certain Clients’ accounts also restrict the trading of other Clients’ accounts by availing themselves of non-public information in commonly held securities, or ownership limitations. Alternatively, where appropriate and in the best interest of its Clients EJF may implement information barriers between individuals within the Firm to prevent adversely impacting the ability of persons at EJF, especially persons who are involved in trading or the making of trading recommendations, to perform their usual functions. Given the industry in which EJF performs advisory services, EJF interacts with various entities in many different capacities on behalf of its Clients. Certain managers of pooled investment vehicles, and their affiliates, from time to time act as: competitor, partner, purchaser, seller, investor, coinvestor, counterparty, financer, or trader with EJF’s Clients at various points and in different capacities. While EJF does not retain any material relationships with such entities, such interactions could present a conflict of interest. Banking or Thrift Institutions For information regarding EJF’s relationships with banking or thrift institutions, see “Item 8— Methods of Analysis, Investment Strategies and Risk of Loss—Management Risk” Law Firm Lender Joint Venture EJF and various investment affiliates of Barings LLC, a subsidiary of MassMutual (the “Barings Entities”), capitalized a newly formed entity, Rocade Holdings LLC (together with its subsidiaries, the “Joint Venture”), which pursues a litigation finance platform. EJF owns common equity of the Joint Venture. The Barings Entities maintain a controlling interest in the Joint Venture. The Armadillo investment team of Brian Roth, Jake Cantrell, and Harry Devens became employees of the Joint Venture, with Brian Roth serving as Chief Executive Officer and Chief Investment Officer of the Joint Venture. Such persons are no longer directly employed by EJF, but will provide certain services to EJF. The investment committee of the Joint Venture is composed of Brian Roth, Jake Cantrell, Harry Devens and two members appointed by the Barings Entities. EJF has provided certain administrative and back-office services to the Joint Venture pursuant to a transition services agreement. EJF has received a fee from the Joint Venture for such services based on the invested capital of the Joint Venture and its subsidiaries. The Joint Venture provides certain administrative services to EJF in respect of its remaining litigation finance funds in exchange for an administrative fee based upon such funds’ invested capital. The administrative fee will be borne by EJF. There are conflicts of interests associated with Brian R. Roth and Jacob K. Cantrell serving as both members of the Investment Committee of the Rocade Funds and as officers, directors and/or

investment committee members of the Joint Venture. In addition, there are conflicts of interests associated with Mr. Roth’s former employment at EJF and current employment at the Joint Venture. Mr. Roth formerly served as Portfolio Management Senior Managing Director of EJF and as CEO and CIO of Rocade Capital LLC, a former subsidiary of EJF that previously served as manager of the Rocade Funds. Messrs. Roth and Cantrell may have incentives to take actions that benefit the Joint Venture at the expense of the Rocade Funds. Additionally, the equity interest owned by EJF and its employees in the Joint Venture may present conflicts of interests in connection with EJF’s management of the Rocade Funds. The interests of Rocade Funds might also differ from the interests of the Joint Venture. There are also conflicts related to all investments in which both the Joint Venture and the Rocade Funds participate as the Joint Venture will advance loans to borrowers or otherwise hold the applicable investments directly and issue participation interests in such investments to the Rocade Funds on the same economic terms. This poses a conflict because once the investment is made, neither the Rocade Funds nor EJF will have control over the management of the investment (including those related to restructurings, modifications, consents or exits) and the Rocade Funds will have limited if any consent rights. The Joint Venture will take such actions regarding the loans and other investments as it determines in its sole discretion, without regard for the interests of the Rocade Funds. Lastly, EJF will generally not have the ability to control the outcome of matters requiring a vote of the members or the board of managers of the Joint Venture. Data Providers and Data Management EJF receives or obtains various kinds of data and information in the course of managing Clients, or other non-Client accounts (“Other EJF Accounts”), including data and information relating to business operations and functionality, investment research, trends, budgets, customers and other metrics, some of which is sometimes referred to as “big data.” EJF may be better able to anticipate macroeconomic and other trends, and otherwise develop investment themes, as a result of its access to (and rights regarding) this data and information from the investment activities of Clients and Other EJF Accounts. Although EJF believes that these activities improve EJF’s investment management activities on behalf of the Clients and Other EJF Accounts, information obtained from the Clients and Other EJF Accounts also provides material benefits to EJF or Other EJF Accounts without compensation or other benefit accruing to the Clients or their investors. For example, information from portfolio entities owned by the Clients enables EJF to better understand a particular industry and execute trading and investment strategies in reliance on that understanding for EJF and Other EJF Accounts that do not own an interest in the portfolio company, without compensation or benefit to the Clients or their portfolio entities. Furthermore, except for contractual obligations to third parties to maintain confidentiality of certain information, and regulatory limitations on the use of material nonpublic information, EJF is generally free to use data and information from the Clients’ activities to assist in the pursuit of

EJF’s various other activities, including to trade for the benefit of EJF or an Other EJF Account. For example, EJF’s ability to trade in securities of an issuer relating to a specific industry may, subject to applicable law, be enhanced by information of a portfolio company in the same or related industry. Such trading could provide a material benefit to EJF without compensation or other benefit to the Clients or their investors. The sharing and use of “big data” and other information presents potential conflicts of interest and the Client investors acknowledge and agree that any benefits received by EJF or its personnel (including fees (in cash or in kind), costs and expenses) will not be subject to the management fee offset provisions or otherwise shared with the Clients or their investors. As a result, EJF has an incentive to pursue investments that have data and information that can be utilized in a manner that benefits EJF or Other EJF Accounts. Recommending/Selecting Investment Advisers for Clients EJF does not recommend or select unaffiliated investment advisers for its clients.

As a general matter, any transaction in a publicly traded or privately traded security for an EJF employee’s personal brokerage account (or an account he or she has beneficial ownership) must be pre-cleared by the Firm’s Chief Compliance Officer or her designee. Once the transaction is pre-cleared, employees may sell the relevant securities held in their personal brokerage accounts. Other transactions are permissible without pre-clearance by the Compliance Department, for example open-ended mutual funds, Treasurys, futures on Treasurys and any security where the employee has no knowledge of the transaction before it is completed can be purchased without pre-clearance. These transactions are also exempt from the 30-day restriction discussed in “Recommendations to Clients” below. Under the Firm’s Code, certain transactions are prohibited. EJF employees are prohibited from purchasing certain securities, including, but not limited to, common or preferred stock, bonds, options, and futures (other than Treasury securities futures) in

an account over which the employees have direct or indirect influence or control. Employees are also prohibited from executing short sales in their brokerage accounts. The pre-clearance process is designed to compare an employee’s proposed transaction against trades considered or executed for the Firm’s clients. By pre-clearing employee trades, EJF is attempting to prevent employees from front-running Client traded securities and causing EJF to violate its fiduciary duty to its Clients. Employees that maintain discretionary accounts managed by third parties must ensure that monthly/quarterly statements are provided to the Firm’s Compliance Department. Employees that maintain discretionary accounts are also subject to periodic certifications. All employees that maintain brokerage accounts are required to instruct their respective brokerage firms to provide EJF’s Compliance Department with duplicate brokerage account statements and trade confirmations in paper or electronic format. The Firm’s electronic pre-clearance system reviews this information to determine if an employee has violated any provision of the Code. Violations of the Code must be reported to the Chief Compliance Officer. Successive violations are subject to increasingly serious consequences, including termination of employment. A section of the Code addresses EJF’s fiduciary duties, including placing the client’s interest first and the handling of a client’s confidential information. The Code also contains a gift policy that requires all employees to record information in the Firm’s electronic database used to track gifts accepted or given to individuals or entities that are conducting business with EJF or seeking to conduct business with EJF. Employees are generally not permitted to accept or give gifts that exceed a certain dollar value. In addition, the Code requires certain employees to post information in the Firm’s electronic database when they entertain or are being entertained by individuals or entities conducting business with EJF or seeking to conduct business with EJF. The entertainment opportunities in which employees participate should not be so frequent or so expensive that it would cause one to question the integrity of EJF or the employee. The Code also describes when a normal entertainment event is classified as a gift by the Chief Compliance Officer. Finally, the Code discusses the sanctions that may be imposed if an employee fails to comply with the Code’s guidance. A non-EJF sponsored activity engaged in by an EJF employee may create a conflict of interest. All EJF employees are required to complete an outside business activity form prior to engaging in any form of outside business activity (this includes, but is not limited to, serving on the board of directors of an unaffiliated entity). Pre-authorization is required for an EJF employee to serve as an officer, director or trustee of a publicly traded or private company (other than EJF) or a nonprofit organization (including as a trustee for a family related account).

EJF maintains a restricted/watch list. The restricted/watch list is loaded into the database used by the Firm to pre-clear personal securities transactions. Securities pre-cleared by an employee are compared to the Firm’s restricted/watch list. The Code also restricts certain actions of independent investment strategy consultants, independent consultants resident in the Arlington, Virginia office and interns resident in the Arlington, Virginia office. Exceptions to the Code may be made on a limited basis with the approval of the Chief Compliance Officer. EJF will provide a copy of the Code to any SMA client, Fund investor, prospective SMA client or prospective Fund investor upon request. Such requests should be directed to Compliance@ejfcap.com or EJF Capital LP, Attention: Compliance, 2107 Wilson Boulevard, Suite 410, Arlington, VA 22201. Recommendations to Clients EJF employees are prohibited from purchasing an exchange-traded instrument that is held by a Client (a “Client Security”). If an EJF employee wishes to sell a Client Security, the employee will be subject to a 7-day blackout period if the Fund or SMA executed a trade in the same security prior to the employee’s transaction. In addition, EJF employees are prohibited from shorting securities. Employees are prohibited from purchasing a security and selling the same security within 30 days of the original purchase transaction. Additionally, employees are prohibited from selling a security and repurchasing the same security within 30 days of the original sale transaction. There are certain security transactions exempt from the pre-clearance requirement and exempt from these requirements, for example open-ended mutual funds, Treasurys, futures on Treasurys and any security where the employee has no knowledge of the transaction before it is completed can be purchased without pre-clearance. For a discussion on the Firm’s investment in the same securities as a Client, please refer to “Investment in Same Securities Recommended to Clients” below. Investment in Same Securities Recommended to Clients Qualified EJF employees are permitted to invest in Funds managed by EJF. In addition, in limited circumstances referenced below, the Firm may acquire interests in securities as a seed investment for a new client account, or to manage its balance sheet investments.

The Firm, with the approval of the Chief Compliance Officer and Co-Chief Executive Officer, may conduct securities transactions for its own account under the following conditions: Seed Investment for New Client: The Firm may acquire securities which are intended to seed a client account that is not yet established or does not yet have external investors. If the vehicle is not yet formed, such investments may be contributed to the client account, once established, and the Firm’s economic interest in the account will be diluted or replaced as external investors increase their economic interest. Balance Sheet Investments: The Firm may acquire securities to invest on its own behalf. The Firm shall seek to avoid investing in a Client Security, but may do so subject to of each of the Firm’s Co-Chief Executive Officers. In conducting all transactions for its own account, the Firm shall follow the same principles of the Code and operate at all times consistent with its fiduciary duty.

In addition to other issues, the best execution committee meeting is designed to determine and analyze where trades are executed and the commission rates charged for the transactions. EJF has also employed the services of a third-party vendor to assist with the best execution analysis for equity securities. The vendor conducts an analysis of execution performance by broker and by security. EJF maintains an approved broker list which is generally designed to limit trading to those brokerdealers that are able to demonstrate knowledgeable sales coverage in the Firm’s area of trading, quality research, access to securities not traded by other firms, and financial responsibility. EJF maintains relationships with a number of broker-dealers including some that have affiliated entities or a department within the same entity that provide services to EJF. Examples of services provided (other than trade execution) by a broker-dealer or a broker-dealer affiliate to EJF include the following, which EJF considers in selecting broker-dealers:

The broker-dealer (that provides trade executions) or an affiliate serves as the prime broker for a Fund’s assets; The broker-dealer (that provides trade executions) or an affiliate refers prospective investors to the Funds; The broker-dealer (that provides trade executions) or an affiliate provides trade executions for Funds or SMA clients; The broker-dealer (that provides trade executions) or an affiliate provides pricing information for Funds; The broker-dealer (that provides trade executions) or an affiliate conducts underwriting or investment banking activity for EJF or its affiliates; The broker-dealer (that provides trade executions) or an affiliate provides EJF with internally generated investment research; and The broker-dealer (that provides trade executions) or an affiliate provides custodian services to Clients.

Additionally, affiliates of certain brokers-dealers on the Firm’s approved broker list may invest in the Funds. EJF’s order management system assists traders in calculating the appropriate trade allocations between multiple Clients. EJF’s staff will monitor trade allocations to determine if decisions are consistent with its policies and procedures. Best Execution EJF seeks to obtain the best available price for the orders placed by its portfolio management team. The objective is to obtain the most favorable total cost or proceeds with regard to the transaction. With regard to best execution, the lowest commission charged on a trade may not be the optimal indication of best execution. EJF is not obligated to merely get the best price or lowest commission, but should also determine whether the transaction represents the best qualitative execution for the account. Additionally, certain transactions require specific services that are not available at the lowest possible commission rates. Research and Other Soft Dollars EJF does not utilize any “soft dollar” credits, but EJF’s portfolio management teams for different Clients sometimes share investment research and have discussions regarding investment ideas and EJF occasionally produces “white papers” which are made available to certain existing and prospective Clients or Fund investors. Certain Clients pay for broker-dealer proprietary research with “hard dollars.” Other Clients from time to time benefit from that research. EJF uses brokerdealer proprietary research to assist with its investment decision-making process. To obtain

broker-dealer proprietary research, EJF pays a higher brokerage commission to execute a trade. Brokerage commissions paid to broker-dealers that do not provide investment research are generally lower than those paid to broker-dealers that do provide proprietary research. EJF could trade more through broker-dealers that provide EJF with proprietary research. By using proprietary research, EJF is receiving research that it does not have to produce internally (EJF or an affiliate may occasionally purchase proprietary research to assist with the decision-making process). This provides EJF with an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on its Clients’ interest in receiving most favorable execution. In addition, this practice creates conflict of interest between EJF’s Clients as resources and investment opportunities could be allocated disproportionately. Aside from broker-dealer proprietary research, EJF does not use its commission dollars to obtain research products and services through third-party vendors. Brokerage for Client Referrals EJF does not use its Client’s brokerage commissions to pay for client referrals. EJF’s employees, however, are occasionally offered by certain broker-dealers the option to participate in or attend conferences, provide EJF employees access to issuers’ management teams, to present non-public investment opportunities such as equity or debt raises, or make prospective investor introductions. Such introduction opportunities may assist EJF in raising capital and thus poses a potential conflict of interest. However, EJF occasionally executes trades on behalf of its Clients with broker-dealers that also receive placement agent fees from Fund investors. Such brokers are not compensated by EJF or its Clients for providing such introduction opportunities. Trade Errors The execution of trading and investment strategies at EJF often necessitates quick trade execution, high trade volumes, complex trades, and the use of negotiated terms with counterparties (particularly when dealing with derivatives or less common and novel instruments). These factors can introduce various risks. For example, due to the high volumes, intricacy, and global scope of these activities, issues such as slippage, errors, and miscommunications with brokers and counterparties may arise, potentially leading to client losses. In such instances, EJF will assess the viability of pursuing damage claims against brokers and counterparties deemed responsible, and will make efforts to recover losses where feasible. However, success in this regard is not guaranteed. Moreover, we reserve the right, at our discretion, to decide against pursuing claims on behalf of our clients, based on factors such as the cost of pursuing claims relative to the expected recovery or the desire to preserve business relationships with brokers and counterparties.

Directed Brokerage EJF may have SMAs with directed brokerage arrangements. In some circumstances, clients can designate a particular broker-dealer through which trades are to be executed, typically under such terms as the client negotiates with the particular broker-dealer. Clients may be incentivized to engage in such arrangements for various reasons such as participating in a rebate or commission recapture program. In those instances where a client directs or influences EJF to execute transactions on behalf of its account with or away from a particular broker-dealer, EJF is not in a position to negotiate commissions or select brokers-dealers based on their ability to provide best execution to such client. Under these circumstances a disparity typically exists between the commissions and execution price between clients who direct brokerage transactions and other Clients who do not instruct EJF to use a particular broker-dealer. As a result, EJF may be unable to achieve most favorable execution of client transactions. Directed brokerage transactions may disadvantage clients as EJF may place directed brokerage transactions after aggregated block transactions (see below). Accordingly, transactions for clients that direct brokerage can be subject to price movements of other Clients, which may be more acute in illiquid securities or large orders. Ultimately clients with directed brokerage arrangements can result in less favorable net prices than might be the case if EJF were able to negotiate commission rates or select brokers or dealers based on best execution. Similarly, certain SMAs where EJF acts as sub-adviser may also instruct EJF not to execute transactions on its behalf with a particular broker-dealer. Clients may desire to instruct EJF in order to avoid certain conflicts of interest that can be created by executing such transactions. By limiting EJF’s ability to execute trades with certain broker-dealers, EJF’s ability to perform its best execution duties may be diminished and potentially result in less favorable prices, which could ultimately impact performance. Wrap Program Trading Wrap fee account transactions are typically executed with the Sponsor due to the all-inclusive fee structure. The Sponsor’s ability to execute transactions is vastly different than that of brokerdealers EJF selects to execute on behalf of its other Clients. This disparity can affect timing, pricing and ultimately performance of Client accounts. Only in very limited circumstances will EJF trade away from the Sponsor, for example when the Sponsor does not have the capability to execute the transaction in a particular security or size. Commissions, and other expenses incurred in connection with any transactions executed with broker-dealers other than the Sponsor, are typically borne by the client. Therefore, it is important for clients who enroll in a Wrap Program where EJF serves as the investment adviser to satisfy

themselves that the program is suitable for them due to the additional commission incurred by them when EJF trades away from the Sponsor. When execution occurs through the Sponsor, EJF does not have the ability to negotiate commissions or other costs for the execution of transactions in the client’s account since such execution costs are included in the all-inclusive fee charged by the Sponsor. Therefore, it is essential the clients in a Wrap Program satisfy themselves that the Sponsor is able to provide best price and execution of orders. Brokerage Aggregation/Allocation Purchases and sales of securities for a Client could be aggregated or bunched when an order is placed with a broker-dealer. EJF may not bunch or aggregate orders if the portfolio management team’s decisions for different accounts are made separately, if the Firm determines that bunching or aggregating would be inconsistent with its investment management duties or with a Client’s direction, or if the orders from the portfolio management teams are not received at approximately the same time. EJF and/or its affiliates have potential conflicts of interest in connection with the allocation of investments or transaction decisions for its Clients, including situations where EJF, its affiliates, and their personnel have a financial interest. EJF and its affiliates may manage accounts that have investment objectives that are similar and/or that seek to make investments in the same securities. This creates potential conflicts of interest and potential differences among the accounts, particularly where there is limited availability or limited liquidity for those investments. EJF has developed allocation policies and procedures that describe how EJF will allocate investment opportunities in a manner it considers to be reasonable and equitable over time. EJF allocates investment opportunities based on relative size of an order, investment objectives, guidelines/restrictions, risk tolerance, availability of other investment opportunities, and available cash for investments. EJF will also take into consideration whether the client account is allowed to use leverage. Although allocating orders among accounts may create potential conflicts of interest, EJF will not make investment allocation decisions based on the allocation that generates higher fees for the Firm. EJF could determine that an investment opportunity or purchases/sales are appropriate for one or more SMA clients, but not for a particular Fund. EJF may also determine that one Fund may participate in a transaction, but based on guidelines/restrictions, cash availability, or duration of investment another Fund may not purchase a particular security. EJF could also determine that an investment is good for one Client but may be appropriate for another Client in different sizes, terms, portion of the capital structure, or at a later time. Such determinations by EJF can result in Clients having differing or even adverse positions in the same security, conflicting rights in the security, or proceeds indirectly exchanged between Client accounts. EJF is keenly aware of

potential conflicts of interest associated with trading allocations and routinely monitors for such conflicts and mitigate them wherever possible. EJF does not anticipate aggregating any orders of Discretionary SMAs that are sub-advised by EJF with any orders that are on behalf of a Fund it manages. Cross-Trades On occasion, EJF and its affiliates engage in transactions in which it causes one of its Clients to purchase securities or other investments from, or sell securities or other investments to, other Clients advised by EJF and/or its affiliates (“Cross-trades”) for purposes of portfolio rebalancing, liquidation, loan syndication or for other reasons as may arise from time to time. EJF and/or its affiliates will not take brokerage commissions or otherwise be compensated for effecting Crosstrades. Prior to effecting any Cross-trade, EJF will make a good faith determination that the transaction is in the best interests of the relevant clients. As a general matter for determining valuation of the Cross-trade, EJF will reference the most recent valuation as calculated by EJF’s Valuations Policies and Procedures. Periodically, EJF will seek additional consent from Clients or their respective Boards or representative limited partners to effect the transaction. Principal Transactions On occasion, EJF may determine that it is appropriate and in the best interests of its Clients if a Client purchases an investment from or sell an investment to EJF or its related persons. EJF will seek preapproval for such transactions consistent with the respective Client’s offering memorandum or governing documents and in accordance with Section 206(3) of the Investment Advisers Act of 1940. Initial Public Offerings Initial public offerings (“IPOs”) are offerings of securities that have limited availability. An IPO may trade at a price above the offering price. If EJF’s Clients are permitted to participate in an IPO, the offering will be made available to all appropriate Clients equitably, however, the Firm, in its sole discretion, could decide that a certain Client may not participate in IPOs for various reasons, including the aforementioned non-standard trade allocations referenced above. This creates a disproportionate allocation of IPOs among Clients which could materially impact the performance and subsequently fees paid by Clients, and ultimately pose a conflict of interest. Conflicts of Interest Employees of EJF could have a conflict where they receive personal benefit by virtue of executing trades for Clients’ accounts with certain broker-dealers. Some of the Firm’s employees previously

held positions at other financial institutions, and as a result may have personal or familial relationships with personnel at such companies. Additionally, certain employees maintain a legacy pecuniary interest in financial institutions (e.g., employee stock). Additionally, EJF has also issued bonds to various financial institutions that are affiliated with broker-dealers, insurance companies, or other financial institutions. EJF does not believe such relationships are material, but could pose a conflict of interest for its Clients. The Firm’s Compliance Department is cognizant of these conflicts and monitors Client trades, employee personal trades, and communication between employees and brokers to mitigate the potential conflicts of interest. EJF Funds will frequently establish a master oversight board or a board of directors (collectively the “Boards”) to review and approve certain actions. The composition of the Boards may include EJF officers, directors, employees or affiliates. Several individuals that serve as directors of the Boards, including but not limited to Messrs. Friedman and Wilson are also investors in the Funds. Certain individuals may also serve on the Boards for multiple Funds. Additionally, certain Boards include directors appointed by a company which has several affiliated entities and employees. From time-to-time EJF has engaged these affiliates to perform legal, regulatory, or consulting purposes. In addition to EJF officers, certain Board members may invest in EJF Funds or affiliated products. EJF does not believe any of these investments or engagements to be material or influential on the Boards. Certain Funds from time to time nominate individuals (including EJF officers, directors, employees or affiliates) to a portfolio company’s board, which could create fiduciary duties to the company and its owners, alongside those owed to the Fund. As a result, such individuals may, from time to time, face conflicts of interest between their duties to the portfolio company and its owners and their duties to the Fund. In certain circumstances, a Fund, on the one hand, and one or more other accounts managed by EJF or its affiliates, on the other hand, from time to time invest in securities or other instruments of the same issuer (or affiliated group of issuers) having a different seniority in the issuer’s capital structure. If the issuer faces insolvency, restructuring, or financial distress, conflicts commonly arise between the Fund and these other EJF accounts, as the issuer may be unable to meet the claims of all its creditors and security holders, creating competing claims for the issuer’s remaining assets. In such cases, EJF may not be able to reconcile these conflicting interests in a way that protects a Fund’s position. In addition, EJF or its nominees hold board memberships and in the future will hold other board or creditors’ committee memberships which may require EJF or its nominees to vote or take other actions in such capacities that might be conflicting with respect to certain Funds managed by EJF in that such votes or actions may favor the interests of one account over another account. Furthermore, the EJF’s fiduciary responsibilities in these capacities with respect to one client would conflict with the best interests of the other clients.

These statements include, but are not limited to, details on the securities held in the portfolio, monthly trading activity, management/incentive fee calculations, and performance information. Unlike Fund clients, SMA clients do not receive audited financial statements on an annual basis. Investors in EJF Funds receive audited financial statements on an annual basis, unaudited financial statements on a quarterly basis and some receive monthly account statements or other customized reporting materials . Such monthly account statements and materials include the same information described above.

It should be noted that a Fund investor’s account can be charged higher or lower Management and/or Performance-based fees within the Fund than if the investor came to EJF directly. EJF also enters into arrangements with unaffiliated third-party broker-dealers to assist with the placement of units of the Funds. Under these arrangements, investors referred by these brokerdealers to certain Funds are subject to a one-time upfront fee of up to 2.5% as well as an ongoing fee of up to 0.5% per annum. The upfront and ongoing placement fees are based on the assets

invested by the referred investor. Currently, only a few Funds are subject to these upfront and ongoing placement fees. Placement fees are paid by the referred Fund investor in addition to the management/performance fees. Such fees can be found on the applicable Fund’s offering memorandum, EJF’s subscription documents, as well as the investor’s statements. With regard to referred clients, EJF will comply with the applicable sections of Rule 206(4)-1 under the Investment Advisers Act, requiring such third parties provide clear and prominent disclosures to any current or prospective Client at the time of endorsement. Such disclosures should include whether or not the person giving the endorsement is an investor, if there is any cash or non-cash compensation being provided for the testimonial or endorsement, and a brief statement of any material conflicts of interests on the part of the person giving the testimonial or endorsement. EJF relies on the promoter to provide the disclosure documents (referenced above) to the Client, as described in Rule 206(4)-1. No entity or individual provides EJF with economic benefits such as sales awards or other prizes.

The Custody Rule allows an investment adviser to deliver audited financial statements to investors in limited partnerships and limited liability companies within 120 days of a fund’s fiscal year end. EJF is not required to comply with certain provisions of the Custody Rule (including the requirement to send quarterly brokerage statements to Fund investors) with regard to the Funds, because it provides audited financial statements to Fund investors within 120 days of the Funds’ fiscal year end. The audited financial statements for the Funds are prepared by more than one public accounting firm. EJF does not have custody of SMA clients’ funds or securities. SMA clients’ assets are held by qualified custodians such as banks and registered broker-dealers, with whom the SMA client establishes and maintains a custodial relationship. When SMA clients receive statements from their custodians, such statements should be reviewed carefully and compared to monthly performance reports provided by EJF, if applicable. EJF does not have control over the SMAs in which EJF acts as sub-investment adviser or other client assets held by unaffiliated custodians.

EJF does not deduct its management or performance fees directly from SMA client custodian accounts.

Clients with Discretionary SMAs have the ability to place investment guidelines/restrictions on the management of their account. The most common investment guidelines/restrictions are those which prohibit EJF from purchasing specific securities or specific types of securities. EJF employees periodically have conversations with SMA clients to review the SMA and its investment guidelines/restrictions. In the case of SMAs where EJF acts as a sub-adviser, each Client account will execute an investment management agreement with its investment adviser, who then delegates such authority to EJF pursuant to a written agreement. EJF shall retain discretion over such sub-advised accounts, and each Client will have the ability to place reasonable restrictions on their account.

Persons involved with voting proxies should avoid discussing the proxy vote with anyone who has conflicting interests to those of the Client (e.g., management personnel of the issuer, EJF affiliates with conflicting interests, etc.). If any EJF employee determines that a material conflict of interest exists with respect to the

voting of proxies, such employee shall inform the Compliance Department, and a member of the Compliance Department will implement an appropriate course of action to minimize the influence of any conflict. In the event that EJF votes a proxy for a security in which it has a conflict of interest, it will generally vote in accordance with its pre-established guidelines. Fund investors cannot direct EJF’s proxy votes. SMA investors either retain the vote or if the voting is by proxy, the SMA will vote in accordance with EJF proxy voting policies. Upon request, EJF will provide a copy of its proxy voting policies and procedures as well as information on how a particular proxy was voted. Investors should direct requests for information concerning EJF’s proxy voting policies and procedures to Compliance@ejfcap.com or EJF Capital LP, Attention: Compliance 2107 Wilson Boulevard, Suite 410, Arlington, VA, 22201.