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Castlelake, L.P.: investment adviser

Castlelake, L.P. is an investment adviser registered with the SEC (file 801-72310, CRD 145165). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.

Assets managed
$35.3B
Discretionary
100%
Accounts
50
Employees
251
In advisory roles
98
Disclosures
0

SEC adviser record · Full Form ADV (PDF)

The firm reports that it or a related person has custody of client cash and securities.

Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.

Clients and fees

Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.

Client typeClientsAssetsShare
Private funds and other pooled vehicles46$35.1B99.4%
Insurance companies1$100.0M0.3%
Corporations2$51.7M0.1%
Other: Other businesses1$61.5M0.2%

How it is paid

  • A percentage of assets under your management
  • Performance-based fees
  • Other: Servicing fees

Services

  • Portfolio management for pooled investment vehicles (other than investment companies)
  • Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles)

Who owns it

Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.

Direct owners (Schedule A)

OwnerTypeRoleStakeSinceControlPublic company
Ro Management, LPCompany (U.S.)Limited partnerE 75% or moreDec 2005Yes

Indirect owners (Schedule B)

OwnerOwns a stake inTypeStakeControlPublic company
Evan Andrew CarruthersThe Bevaring Revocable TrustPersonF General partner, trustee or managing memberYes
Evan Andrew CarruthersCastlelake Group GP, LLC MemberPersonF General partner, trustee or managing memberYes
Evan Andrew CarruthersCastlelake Management Member Aggregator, LLCPersonF General partner, trustee or managing memberYes
Castlelake Group GP, LLCCastlelake Group Topco, L.P. PartnerCompany (U.S.)F General partner, trustee or managing memberYes
Castlelake Group GP, LLCCastlelake Group Holdings, L.P. Partner Holdings, L.P. PartnerCompany (U.S.)F General partner, trustee or managing memberYes
Yen-Wah LamCastlelake Group GP, LLC MemberPersonF General partner, trustee or managing memberYes
Craig William Alexander NobleCastlelake Group GP, LLC MemberPersonF General partner, trustee or managing memberYes
Rory Joseph O'NeillThe Rory O'Neill Revocable TrustPersonF General partner, trustee or managing memberYes
Rory Joseph O'NeillCastlelake Group GP, LLC MemberPersonF General partner, trustee or managing memberYes
Hadley Peer MarshallCastlelake Group GP, LLC MemberPersonF General partner, trustee or managing memberYes
Ro Management, LLCRo Management, LPCompany (U.S.)F General partner, trustee or managing memberYes
Brookfield Asset ManagementBrookfield USCompany (outside the U.S.)E 75% or moreYes
Brookfield US Holdings, Inc.Brookfield US Inc.Company (outside the U.S.)E 75% or moreYes
Brookfield US Inc.Brookfield CL Holdings, LLCCompany (U.S.)E 75% or moreYes
Castlelake Group Topco, L.P.Ro Management, LPCompany (U.S.)E 75% or moreYes
Castlelake ManagementCastlelake GroupCompany (U.S.)E 75% or moreYes
Rory Joseph O'NeillCastlelake Management Member Aggregator, LLCPersonE 75% or moreYes
Brookfield CorporationBrookfield Asset Management Ulc Management Aggregator, LLCCompany (outside the U.S.)D 50% to 75%Yes
Castlelake Group Holdings, L.P.Castlelake Group Topco, L.P. PartnerCompany (U.S.)D 50% to 75%Yes
Brookfield Asset ManagementBrookfield AssetCompany (outside the U.S.)C 25% to 50%YesYes
Brookfield CL Holdings, LLCCastlelake Group Topco, L.P. PartnerCompany (U.S.)C 25% to 50%Yes
The Bevaring Revocable TrustCastlelake Group Holdings, L.P. PartnerCompany (U.S.)C 25% to 50%Yes

Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.

Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.

Disciplinary history

The firm answered No to every disciplinary question on Form ADV (Item 11).

The brochure

Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.

Castlelake L.P., Form ADV 2A Brochure, filed Mar 27, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

- Advisory Business

Castlelake, L.P., which does business under the name “Castlelake” (“Castlelake”) was established in 2005 and serves primarily as: (1) the investment adviser to private investment funds, separately managed accounts and co-investment funds or other similar types of entities (“Fund” or “Funds”) that focus primarily on investments in aviation, real assets and specialty finance; and (2) the servicer of securitization trusts, ABS securitization-like vehicles, warehouse and term facilities and other financing structures (the “Vehicles”) for which Castlelake and its relying adviser may manage asset-backed loans, aircraft and other

Read the rest of Item 4 (629 more words)

asset-based leases, finance leases, unsecured loans, as well as maintenance and disposition proceeds relating thereto (collectively, the Funds and Vehicles may be referenced here as the “Accounts”). Castlelake’s advisory services to the Accounts are detailed in the applicable private placement memorandum, confidential information memorandum or other offering memorandum and materials (each, a “Memorandum”), investment management agreements, servicing, facility management and similar type agreements, trust and similar agreements, limited partnership, limited liability company or other similar operating agreements (each, a “Partnership Agreement”) (each such Memorandum and Partnership Agreement collectively referred to herein as an “Offering Document”) and are further described below under “Methods of Analysis, Investment Strategies and Risk of Loss.” Castlelake or its related entities have also entered into side letter agreements (“Side Letters”) with certain investors in the Funds, establishing rights under, or supplementing or alternating the terms (including economic or other terms) of, the applicable Offering Documents with respect to such investors. Additionally, from time to time and as permitted by the relevant Offering Documents of each Fund, Castlelake expects to provide (or agrees to provide) co-investment opportunities (including the opportunity to participate in co-invest vehicles) to certain investors or other persons, including other sponsors, market participants, finders, Operating Partners (as defined below) and other service providers, Castlelake’s personnel and/or certain other persons associated with Castlelake and/or its affiliates. Such co-investments typically involve investment and disposal of interests in the applicable portfolio investment at the same time and on the same terms as the Fund making the investment. However, from time to time, for strategic and other reasons, a co-investor or co-invest vehicle have in the past purchased, and will in the future purchase, a portion of an investment from one or more Funds after such Funds have consummated their investment (also known as a post-closing sell-down or transfer or bridge). As well, for strategic or other reasons, disposal of interests may not be conducted at the same time or on a pro rata basis. Castlelake is managed by Rory O’Neill, Evan Carruthers, Rich Barnett, Christopher Buckley, Alex Curcio, Eduardo D’Alessandro, Brad Farrell, Alan Gearing, Yen-Wah Lam, Matt Little, John Lundquist, Joe McConnell, Daniel McNally, Armin Rothauser, and Isaiah Toback (collectively, the “Principals”). Detailed information about the Accounts is located in their respective Offering Documents. Castlelake invests called capital (and in certain of the Funds, recycled proceeds) in the Funds during their respective commitment periods, and as otherwise permitted in the Offering Documents, in portfolio investments.

All discussions of the Accounts in this Brochure, including but not limited to their investments, the strategies used in managing the Accounts, the services provided to the Accounts, the fees and other costs associated with an investment in the Accounts and other terms, are qualified in their entirety by reference to each Account’s respective Offering Documents. Investment advice is provided directly to the Accounts, subject to the discretion and control of the applicable Account’s general partner, managing member or entity serving a similar role (the “General Partner” or “General Partners”) and not individually to investors in the Accounts. Each Account’s General Partner is subject to the U.S. Investment Advisers Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Advisers Act”) pursuant to Castlelake’s registration in accordance with SEC guidance. This brochure describes the business practices of the General Partners, managing members and an adviser which operate as a single advisory business together with Castlelake. This brochure also describes the business practices of Castlelake RA, LLC which is a relying adviser to Castlelake (and its associated General Partners) (“relying adviser”). References herein to Castlelake should be read to include the General Partners, managing members and relying adviser as applicable. As of December 31, 2025, Castlelake manages approximately $35.3 billion in assets on a discretionary basis in its Accounts.

Item 5. Fees and compensation

- Fees and Compensation

Management Fees In general, Castlelake receives management fees (calculated and payable either monthly or quarterly) as well as certain servicing fee compensation, all of which are described in detail in the respective Offering Documents and for which additional information is provided later herein. While management fees of certain Funds are subject to an offset by all or the specified portion of the servicing fees and compensation and other similar consideration (all net of expenses) relating to the making, disposition or management of Fund investments received by Castlelake or its management company affiliates, management fees are not offset for servicing and other fees received in certain of the circumstances described in the following paragraph.

Read the rest of Item 5 (4,286 more words)

In certain circumstances, Castlelake management fees may be reduced for certain investors subject to agreed upon terms and conditions of a Fund’s Offering Documents and/or Side Letters. In addition, Castlelake expects that co-investors or other parties will negotiate the right to share a portion of certain fees from a particular investment, and the above-described offset will be applied after excluding any amounts paid to such persons. Servicing and Other Fees Castlelake or its affiliates, including Platform Servicing Companies, receive servicing fees, facility management fees, origination fees and/or other similar fees (collectively referred to as “servicing fees”) through the Accounts or similar securitization vehicles, warehouse facilities, term facilities, trust structures, joint ventures and other structured investments. Castlelake receives fees and compensation earned by, paid to, either directly or indirectly for structuring, arrangement, origination, placement, syndication and other similar services provided in respect of a portfolio investment or portion thereof (including, for the avoidance of doubt, (i) with respect to the Fund’s allocable portion of any portfolio investment, where another portion of such portfolio investment

(whether relating to different parts of the debt or capital structure or otherwise) is syndicated, placed or otherwise sold to, or arranged or structured (or re-structured) in respect of, another person following the Fund’s investment therein or (ii) where such services are with regard to financing facilities, loan structuring, securitizations, securitization like transactions and other financing or refinancing transactions related to the Fund’s allocable portion of portfolio investments). Castlelake also receives servicing fees through co-investments or other structures or loan offerings with respect to assets, investments or debt that are not owned by a Fund, or activities that are not on behalf of a Fund (including, without limitation, providing services to any persons other than a Fund participating in, or providing financing to, the same investment, or with respect to any other activities undertaken by such persons for the benefit of any third parties, or providing services with respect to assets owned by third parties). Certain of these fees could be asset-based fees, based on collections of premiums, rent, principal and interest or based on certain performance criteria (as described below) and such fees can be paid upfront, over time and/or upon monetization of an asset or investment. Castlelake’s ability to retain such amounts provides it with an incentive to increase the portion of each relevant investment held by non-Fund parties. See also “Conflicts of Interest” in Item 10. Carried Interest and Performance Fees Castlelake is entitled to receive carried interest or performance fees or allocations (collectively referred to herein as “Carried Interest”) with respect to certain of the Funds. Carried Interest is generally equal to a percentage of net profits, subject to a preferred return or hurdle return, as more fully described in an applicable Fund’s Offering Documents. Carried Interest is generally equal to a percentage of profits after application of preferred return threshold or above an agreed upon threshold, as more fully described in an applicable Fund’s Offering Documents. Certain Vehicles or similar securitization vehicles or other managed accounts, warehouse facilities, term facilities, trust structures and joint ventures may also pay Carried Interest to Castlelake. The timing of payment of Carried Interest varies by Vehicle and may be paid later in the life of the Vehicle or, less frequently, annually. Additionally, the Accounts are permitted to invest in loans or other debt instruments which have been sourced by a Platform Servicing Company and are, directly or indirectly, originated and serviced, on a temporary or permanent basis, by a Platform Servicing Company. The Accounts could pay origination, upfront, servicing, administration, compensation (including salary and/or bonuses), incentive based or other similar fees to, or enter into profit sharing or expense reimbursement arrangements with, a Platform Servicing Company (as defined herein later) and any of such will not offset the management fee. Any Insurance Servicing fee offsets will generally be pro-rated in proportion to the capital invested directly by the Accounts relative to the total principal amount of the applicable loans (or other financing) reinsured by an Account owned reinsurance vehicle in respect of which such Insurance Servicing Fees were generated, as further defined in the Fund’s Offering Documents, and there will generally be no offset for loans or other financings where the Fund does not participate in the reinsurance.

Other Information Castlelake is permitted to exempt investors in the Funds from payment of all or a portion of management fees and/or Carried Interest. For certain Funds this includes Castlelake, its General Partner entities and other affiliates and any other person designated by Castlelake, such as “friends and family” of Castlelake or its personnel, or other investors as determined by Castlelake based on commitment size, timing, or other strategic or relationship factors. For example, in instances where a Castlelake professional (or an affiliated entity thereof) invests in a Fund, such professional (or such affiliated entity) will generally be exempt from payment of the management fee and Carried Interest with respect to such Fund. Additionally, to the extent permitted by the relevant Offering Documents, certain General Partners or similar parties have the right to permit investors, affiliated with Castlelake or otherwise, to invest in the funds through the relevant General Partner or other vehicles that do not bear management fees or Carried Interest. Further, co-investors often pay lower or no management fees and/or Carried Interest or performance fees. The Funds generally invest on a long-term basis. Accordingly, management and other fees and expenses are expected to be paid, except as otherwise described in the Offering Documents, over the term, or through final liquidation in some cases, of the relevant Fund, and investors generally are not permitted to withdraw or redeem interests in the Funds. In general, the management fee, servicing fee and other offsets described above apply only with respect to the capital commitments of fee-paying investors and do not apply if a Fund ceases to pay management fees at the end of its term. Principals or other current or former employees of Castlelake generally receive salaries and other compensation derived from, and in certain cases including a portion of, management fees, Carried Interest or other compensation received by Castlelake or its affiliates. In addition to any management fees and organizational and startup expenses, the Accounts shall pay for (or shall reimburse Castlelake or its affiliates, as applicable, for its payment of) all costs, fees liabilities, obligations and expenses (referred to collectively as “costs”) relating to the Accounts that are not reimbursed, including, but not limited to, operations and annual, periodic or special meetings of the investors (or with any one subset or subsets of the investors) and any other conference, meeting or webcast or other video conference (and any subscription costs related thereto) with any investor(s) (in each case, including any costs associated with venue, set-up, room and board, dining, entertainment, gifts and mementos, honorarium, events or speakers and other meeting or conference-related costs), in each case to the extent incurred by the Account, Castlelake or any other affiliate of Castlelake; costs (including legal and accounting costs) incurred in connection with the tax and other structuring, as well as the, organizing, reorganizing (including an initial public offering or a merger or acquisition), dissolution, winding up or termination of a Fund, any parallel investment entities and alternative investment vehicles or their respective subsidiaries or any other special purpose vehicles and/or the General Partner (including the liquidation of such entities and their assets); costs directly related to the pursuing, originating, sourcing, discovering, conducting due diligence, investigating, developing, negotiating, structuring, making, leasing, re-leasing (e.g., conversion and reconfiguration), holding, managing, monitoring, maintaining (e.g., maintenance events and aircraft part purchases) dissolving, liquidating and disposing of investments (including potential investments that are not consummated, including any non-consummated investment that would have been allocated in part

to one or more co-investors irrespective of whether any such co-investor had been identified or selected, or had committed to participate in such investment, but excluding any portion of such costs attributable to any Castlelake Co-Investor (as defined in the Offering Documents) that committed, pursuant to a binding agreement, to participate in a co-investment alongside the Accounts), including, without limitation, meetings with respective counterparties, advisors and investors and entertainment, meals and travel costs in connection therewith (including, where appropriate, the cost of utilizing private aircraft at a cost not in excess of the cost of first class commercial airfare), transaction costs, interest and commitment fees on debit balances, borrowings, guarantees or other credit support or permitted hedging activity, clearing and settlement charges, compensation (including salary and/or bonuses), fees, profit sharing arrangements, retainer, costs and expenses of advisors, consultants, and experts (who may be affiliated with, or employed by, portfolio companies of other Accounts, Castlelake, Service Companies and/or their respective affiliates) (excluding any employees of Castlelake), including persons engaged in connection with a Fund considering, making, holding or disposing of, directly or indirectly, an investment; appraisal fees, investment banking costs, custody fees, third-party fees and profit-sharing arrangements that are not payable to Castlelake or any of its affiliates (provided such third- party fees and profit-sharing arrangements were not in connection with the day-to-day costs required to be borne by Castlelake in accordance with the Offering Documents and are entered into on an arm’s length basis), costs of service companies, custodians, depositaries (including any depositary appointed pursuant to the AIFMD or any similar law, rule or regulation as implemented in any relevant jurisdiction), any Swiss representative and paying agent (pursuant to the CISA), consultants, economists, tax preparers, outside counsel, accountants or other experts and professionals engaged by, Castlelake or the relevant Fund’s Advisory Committee (as defined below) and costs associated with activities with respect to the origination, identification and sourcing of investment opportunities for the Accounts, including attending and sponsoring industry conferences and events, meeting with consultants, finders, broker-dealers, investment banks and other sources of investments and developing and maintaining an investment pipeline; costs of certain personnel to perform jurisdiction-specific administrative functions at one or more registered or administrative offices in any jurisdiction in connection with one or more investments in such jurisdiction; registered office and registered agent costs; brokerage and commission charges for securities and commodity transactions and other trade-related costs such as stamp and transfer taxes on foreign securities, reasonable travel, meal and lodging costs of personnel of Castlelake relating to the Accounts (including, where appropriate, the cost of utilizing private aircraft at a cost not in excess of the cost of first class commercial airfare); all third-party costs for administrative, accounting, tax preparation, audit, legal and compliance services, including without limitation, costs of compliance which include any Accounts information (e.g., Form PF and filings required under the U.S. Securities Exchange Act of 1934, as amended, and the rules and regulations promulgated thereunder), costs for any third-party secondee (e.g., legal) of the Accounts, and/or Castlelake and technical consulting and/or other expert consulting and in-house legal and technical costs of the Accounts, and/or Castlelake; all costs associated with reporting and providing information to existing and prospective investors (including in respect of investmentrelated matters and any other Accounts-specific reporting, notification or other filing obligations), including through a third-party data portal and otherwise; data production and maintenance services and other third-party research costs, including specific costs incurred in obtaining systems, research and other information, including information service subscriptions, utilized for portfolio management, valuations (including third-party valuations, fairness opinions, appraisals

or pricing services), accounting or reporting purposes, including the costs of pricing services, service contracts for quotation equipment and related hardware and software, phone and internet charges as well as other costs for information and technology systems (including security); developing, licensing, implementing, maintaining or upgrading any web portal, website, extranet tools, software or other technology tools (including artificial intelligence and subscription-based services), including relating to accounting, investor tracking, investor reporting, customer relationship, management, administration, ledgers, due diligence, sourcing, research and other investment activity, investment monitoring, financial management and cybersecurity or other administrative or reporting tools (including subscription-based services) for the benefit of the Accounts or the investors; third-party fees and other costs (which shall be entered into on an arm’s length basis) related to the organization, operation, administration, accounting, reporting, legal, tax, monitoring, compliance, dissolution, technical consulting and/or other expert consulting and in-house legal and technical costs of any AIV or Funds or their respective subsidiaries, including any other vehicles through which Account’s investments are made; all costs associated with environment, social and governance, including establishing, implementing, monitoring, measuring, maintaining, reporting on and/or disclosure of the status or impact of Environmental, Social, and Governance (“ESG”) policies and programs with respect to the Accounts or its investments or prospective investments, including all costs incurred in connection with ESG tracking tools, greenhouse gas assessments and any other assessments, measurements, service providers (including suppliers, vendors, consultants, lenders, law firms (including Fund or transaction counsel), transaction service providers and their respective affiliates, personnel and related investment vehicles (together, “Service Providers”)), advisory services (including consulting, advisory and retainer fees, expense reimbursement and other compensation paid and benefits provided to advisors), or advice or reports prepared or conducted as part of establishing, implementing, monitoring, measuring, maintaining, reporting on and/or disclosure of the Accounts, or Castlelake’s ESG policies and programs (including, without limitation, greenhouse gas emissions targets and commitments) or otherwise designed to promote or evaluate the Accounts or its investments’ or prospective investments’ achievement of ESG objectives, including the UN’s Sustainable Development Goals; the cost of insurance, including directors and officers liability, fiduciary bonds, management liability, cybersecurity, errors and omissions liability, representation and warranty, crime coverage and Castlelake liability premiums and other insurance (including costs related to any retention or deductibles and broker costs and commissions) obtained on behalf of the Accounts, and/or Castlelake, and any consultants or other advisors utilized in the procurement, review, maintenance and analysis of insurance as well as regulatory costs; any withholding, taxes, fees, duties or other governmental charges levied against or otherwise borne by the Accounts and all costs incurred in connection with any tax audit, investigation, settlement or review of the Accounts (except to the extent that the Accounts are reimbursed therefor by an investor pursuant to the Offering Documents and any costs of or related to the representative of the Accounts); any governmental, regulatory, licensing, filing or registration costs incurred in compliance by the Accounts with the rules of any self-regulatory organization or any federal, state or local laws; ongoing compliance costs contemplated by, or related to, the AIFMD (including any filings, notifications, reports or other regulatory requirements contemplated by or arising under the AIFMD other than costs of the initial notifications, filings and compliance which fall within organizational expenses) or any similar non-U.S. law; costs relating to any governmental inquiry or public relations undertaking relating to the Accounts; reviewing and responding to any “Freedom of Information Act,” “open records”

or similar requests and any costs related to protecting the confidential or non-public nature of any information or data (including any costs incurred in connection with the Freedom of Information Act, 5 U.S.C. § 552 and any U.S. state or other jurisdiction’s laws similar in intent or effect); the costs of any litigation involving the Accounts and the amount of any judgments or settlements paid in connection therewith, relating to the business, activities and interests of the Accounts, including the costs of discovery related thereto, any indemnification costs payable in accordance with the Offering Documents and advancing costs incurred by any a person in defense or settlement of any claim that may be subject to a right of indemnification pursuant to the Accounts Agreement; costs associated with the preparation of the Accounts’ financial statements, tax returns and Schedules K-1 and/or Schedules K-3 (or equivalent reports); costs relating to any forms, schedules, reports, filings, information or other documents prepared with respect to the U.S. Foreign Account Tax Compliance Act and any comparable non-U.S. filings; to the extent provided in the Offering Document or otherwise approved by Castlelake in its sole discretion, activities or proceedings of the relevant limited partner advisory committee (the “Advisory Committee”) (including any reasonable out-of-pocket costs (including travel)) incurred by representatives of Castlelake, or any Advisory Committee, members, permitted observers and other persons in attending or otherwise participating in meetings of any Advisory Committee, board or similar committee of an Account including, for the avoidance of doubt, other than such meetings that take place in connection with a general meeting of the investors; costs of administering or complying with any “most favored nations” or similar process with respect to any Side Letters or similar agreements including any “most favored nations” provisions and elections; costs accrued in connection with the process of compiling and/or complying with Side Letter compendia; amendments to, and waivers, consents or approvals pursuant to, the constituent documents of the Accounts, Castlelake, the investors and related entities and any AIV, including any persons owned directly or indirectly by the Accounts (including investments), including the preparation, distribution and implementation thereof; costs of any third-party experts, including independent appraisers, advisors and/or investment banks, engaged by Castlelake in connection with the Accounts considering, making, holding or disposing of, directly or indirectly, an investment in the same person as one or more other investment vehicles or accounts sponsored by Castlelake and/or its affiliates; costs incurred in connection with termination, liquidation, winding-up or dissolution of the Accounts and any vehicles owned directly or indirectly by the Accounts (including portfolio companies) and related entities; costs relating to enforcing any defaults by investors in the payment of any capital contributions; unreimbursed costs incurred in connection with any transfer or proposed transfer or any investor’s name change, internal restructuring or change in trust, registered agent or custodian; costs relating to derivatives and similar transactions; other costs associated with the acquisition, holding and disposition of the Account’s investments, including extraordinary expenses; developing, structuring, operating and winding up administrative structures in Luxembourg, Ireland (excluding, for the avoidance of doubt, any costs related to Castlelake Aviation Holdings (Ireland) Limited), other European countries and elsewhere that are put in place to support, administer and help operate certain of the Accounts’ investment activities (including any travel and accommodation costs related to such structures, the salary and benefits of any personnel reasonably necessary for the maintenance of such structures, or other overhead costs and rent in connection therewith); fees, costs and expenses of investigating or pursuing a “GP-led secondary”, “continuation vehicle” or similar transaction (whether or not consummated), including obtaining any third-party valuations, fairness opinions and other items and any associated legal costs and expenses; costs related to complying with any law, rule, regulation, policy, directive or special

measure in relation to privacy, data protection (including the EU Data Protection Law (as defined in the Offering Documents), know-your-customer, anti-money laundering, sanctions or antiterrorism considerations, including related software costs; and any other costs approved by an Advisory Committee, board or similar body of an Account. The Accounts may retain unaffiliated Service Providers to provide certain administrative, accounting, reporting, tax support, monitoring and other services with respect to the Accounts and certain subsidiaries. These Service Providers will be paid fees by the Accounts for these services that may be based on the assets being serviced and/or otherwise. To the extent any of the costs are incurred on behalf of the Accounts and any other Accounts managed by Castlelake or its affiliates, the Accounts shall not bear more than its pro rata portion of such costs, as determined by Castlelake utilizing a fair and reasonable allocation methodology given the circumstances of such costs. Costs will be allocated among Parallel Investment Entities comprising the Accounts on a pro rata basis, unless Castlelake reasonably believes that another allocation methodology is more equitable. Expenses of the Accounts are expected to be substantial and may surpass their operating income. The amount of these expenses will reduce the actual returns realized by investors on their investment in the Accounts (and may, in certain circumstances, reduce the amount of capital available to be deployed by the Fund for investments). Expenses of the Accounts include recurring and regular items, as well as extraordinary expenses for which it may be hard to budget or forecast. As a result, the amount of the expenses of the Accounts could exceed expectations and some stakeholders are expected to bear an amount of fees or expenses disproportionate to the benefits they receive, or in some cases without receipt of any direct benefits. The inclusion of an expense category in a Fund’s Offering Documents will not impose on Castlelake an obligation to charge an expense (or the full amount of that expense) to that Fund; instead, permitted expenses will be allocated and charged in Castlelake’s discretion to the Fund(s) it deems appropriate. Investors in Accounts that elect to participate in certain investments through tax blocker corporations will also bear a pro rata portion of taxes, fees or governmental charges and such other costs associated with a blocker corporation as reasonably determined by Castlelake. The Accounts pay or reimburse Castlelake for certain expenses specified in their Offering Documents, which generally also include some or all of the expenses set forth in the preceding paragraph. Such expenses also include any fees, costs, expenses, taxes and indemnification amounts incurred on behalf of the issuer group member in the course of business activities permitted under the Accounts operative documents, including, without limitation, issuer expenses, ordinary course expenses, Service Provider fees relating to the assets, maintenance and modification expenses and asset trade payments with respect to the assets (not funded out of the maintenance support account, if applicable) and liquidity and hedging facility expenses. Castlelake expects to be subject to potential conflicts of interest where certain administrative and other functions would not be chargeable to the Funds under the Offering Documents if Castlelake were to elect to directly provide such services (which it is permitted but not required under the Offering Documents to do), but third parties performing the same services generally would be chargeable to the Funds thereunder, and outsourcing to third parties effectively enables Castlelake and its affiliates to reduce its personnel compensation costs.

Air travel expenses attributable to the activities of the Accounts and investments, including potential investments, are charged accordingly as either economy or business/first class travel as reasonably determined by Castlelake and consistent with Castlelake’s travel policies and procedures. In certain circumstances where non-commercial air transportation is elected, such noncommercial air transportation expenses charged to the Accounts are capped at commercial business/first class travel costs, as applicable and as determined in good faith by Castlelake; provided however where commercial air transportation is not available or where non-commercial air transportation is permitted by the operative documents, the actual costs of such non-commercial air transportation may be paid by the Accounts. In certain circumstances, one Fund may pay an expense common to multiple Funds (including without limitation legal expenses for a transaction in which all such Funds participate, or other fees or expenses in connection with services the benefit of which are received by other Funds over time) and be reimbursed by the other Funds by their share of such expense as determined by Castlelake on a fair and equitable basis, with or without interest. In certain circumstances, Castlelake advances amounts related to the foregoing and receives reimbursement from the Funds to which such expenses relate. Expenses charged at the level of a portfolio company or intermediate entity, or capitalized into the cost of a transaction, generally will not be reflected as Fund expenses in calculating the gross and net performance of the relevant Fund; conversely, expenses charged at the Fund level do not reduce portfolio company-level gross returns. Accordingly, Castlelake expects to be subject to potential conflicts of interest in determining whether certain expenses should be charged to the portfolio company or intermediate entity, capitalized into transaction costs, or charged to the relevant Fund. Valuation. Castlelake is responsible for valuing the securities, loans and other investments comprising the assets and liabilities of the Funds. Investments in liquid, marketable securities are typically “marked to market” by reference to the last generally available price quotation. Investments in illiquid or non- marketable securities and other assets for which reliable market quotations are not readily available are valued in a manner as Castlelake determines on a consistent basis, so long as such methodology is consistent with U.S. generally accepted accounting principles (“U.S. GAAP”). Castlelake will typically apply the valuation technique (for example, income approach, market approach and cost approach) that is appropriate in the circumstances and will obtain and may rely on information provided by any source or sources reasonably believed to be accurate in determining the value of the investments or assets. It is often appropriate to use a combination of any or all of the valuation techniques and related information. Determining how to measure the values when using multiple techniques may change over time based on changes in facts and circumstances. A conflict of interest arises due to the fact that a higher fair value assigned to such investment can result in greater management fees paid (where management fees are based on net asset values). In addition, conflicts of interest can also arise with respect to Accounts that permit redemptions and subscriptions from time to time, especially if redemptions or subscriptions are made by Castlelake and its related parties, as valuations will impact the value of such redemptions or subscriptions and Castlelake could be incentivized to assign higher or lower valuations depending on the circumstances. Valuations assigned to securities, loans and other investments are not necessarily equivalent to the value that can be realized by the Funds on the sale of those securities, loans and other investments. In addition, there is a risk that the valuations of an investment made pursuant to U.S. GAAP may differ from the price at which an investment is actually sold.

Item 6. Performance-based fees and side-by-side management

- Performance-Based Fees and Side-By-Side Management

The Accounts are subject to performance-based compensation payable to Castlelake or its affiliates. Castlelake affiliates will receive Carried Interest with respect to the Funds generally equal to a percentage of net profits, generally subject to a preferred return or hurdle return, as described more fully in the respective Offering Documents. In addition, the respective Funds may make cash distributions to Castlelake affiliates in amounts sufficient to pay individual income taxes on income allocated to such affiliates for tax purposes, which amounts are generally not required to be repaid in the event the applicable preferred return has not been met over the relevant period of life of the Account.

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Distribution of performance-based compensation generally commences after invested capital and the applicable preferred return have been distributed to investors. In addition, certain Funds include servicing fees and/or other similar fees that are used in calculating net management fees. The existence of Carried Interest or other performance-based compensation creates a conflict of interest because it is not proportionate to the capital contributions of Castlelake affiliates to a Fund and may create an incentive for Castlelake to make riskier or more speculative investments, or to dispose of an investment sooner or later than otherwise would be the cause, with the aim to attempt to increase performance compensation paid. The nature of any preferred return in a Fund’s Carried Interest arrangements provides incentives for the relevant General Partner to accelerate actions that would result in earlier gains, such as dispositions, dividends, distributions, recapitalizations, currency forward or other currency hedges. This conflict is mitigated through the Funds’ diversification and eligibility requirements, ongoing risk management and internal governance and the fact that Castlelake’s Principals invest in the Funds. In addition, Castlelake’s investment allocation process described in Item 10 of this brochure further mitigates the risk of investments being allocated for the primary purpose of attempting to increase performance compensation. With respect to aviation vehicles and other financing structures, for both aviation and nonaviation investments, the following types of performance-based compensation may be incurred and payable to Castlelake as servicer, facility manager or similar role: (1) incentive or similar fee is payable (A) based on the performance of the portfolio or (B) if the amount of rent or similar income received during certain periods of time, net of certain maintenance-related payments, is equal to or greater than an agreed upon percentage of the projected net amount for the related period of time; (2) sales fees are payable as incurred upon net sales proceeds arising from the sale of assets; (3) remarketing fees are payable in the case of entering into a new lease or extending the lease term, and (4) end of lease compensation fees are payable on a percentage basis to the extent amounts of end of lease compensation exceed transaction related maintenance expenses actually incurred as well as other compensation of similar nature. Castlelake manages multiple Funds at any given time, and to the extent that Castlelake personnel are assigned varying percentages of Carried Interest from the Funds, such personnel are subject to conflicts of interest to the extent they are involved in identifying investment or disposition opportunities as appropriate for the Funds from which they are entitled to receive a higher Carried Interest percentage and/or which are more likely to generate Carried Interest. This side-by-side management creates a conflict of interest in that Castlelake could provide more favorable investment or disposition opportunities to Funds with more favorable compensation

arrangements. Castlelake seeks to mitigate this conflict of interest with allocation policies and/or practices that provide those transactions and investments or disposition opportunities will be allocated to the Funds in accordance with each Funds’ investment guidelines and Offering Documents, as well as other factors that do not include the amount of Carried Interest or other performance-based compensation received by Castlelake or any personnel.

Item 7. Types of clients

- Types of Clients

Castlelake provides investment advice to the Accounts. Account investors generally consist of state, local and corporate pension and profit-sharing plans, trusts, estates, charitable organizations, endowments, corporations, insurance companies, business entities, private fund-of-funds, foreign sovereign wealth funds, family offices and/or high net worth individuals. Employees of Castlelake who qualify as “knowledgeable employees” under Rule 3c-5 of the Investment Company Act of 1940 are also permitted to invest (directly or indirectly) in the Funds.

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The Funds may include alternative investment vehicles established from time to time in order to permit one or more investors to participate in one or more particular investment opportunities in a manner desirable for tax, regulatory or other reasons. Alternative investment vehicle sponsors generally have limited discretion to invest the assets of these vehicles independent of limitations or other procedures set forth in the organizational documents of such vehicles and the related Fund. Generally, the Accounts impose minimum investment requirements upon investors that can be waived in certain circumstances, as set forth in the respective Offering Documents.

Item 8. Methods of analysis, investment strategies and risk of loss

- Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis

The methods of analysis are conducted at varying levels depending upon the markets and participants involved. Castlelake generally performs quantitative and qualitative fundamental research to determine the suitability of a particular investment and in the context of the relevant industry. Certain research, particularly quantitative, may be outsourced to operating partners or other Service Providers.

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Depending on the investment, investment professionals will employ a variety of analytical techniques that may include any combination of the following amongst other things: financial models to analyze comparable valuations in the public and private markets, a discounted cash flow analysis, a reorganization analysis and liquidation analysis, and/or an analysis of potential returns for the investment to name a few. Castlelake utilizes this analysis to determine the price range at which to pursue the investment opportunity. Investment Strategies More detailed information regarding Castlelake’s investment strategies and activities described below is set forth in the Offering Documents. Castlelake’s investment strategies seek to deliver asset-based exposure across five broad asset classes: (i) aviation leasing and lending; (ii) consumer finance; (iii) small to medium sized business finance; (iv) residential mortgages and (v) commercial mortgages. Consistent with Castlelake’s overall investment approach, there is an emphasis on lending secured by financial and real assets as well as asset ownership. Castlelake utilizes asset servicers as well as a series of joint-venture asset operating partnerships (including Platform Servicing Companies) in a variety of the investments, generally other than aviation, under

which the operating partners or servicers provide a focus on managing certain asset specific nuances and day-to-day details of the investments, such as payments and administration. Generally, and as applicable, Castlelake seeks to maintain control over, or is involved in, economic and strategic decisions, working either in collaboration with the specific operating partners, or within the governance structure of a portfolio company in which the Funds hold an equity interest. In certain lending transactions Castlelake maintains rights over its collateral through data sharing arrangements with the servicer of the portfolio of assets. Please note that not all Accounts invest in all of the same types of investments and certain types of investments have been de-emphasized or added over time. Aviation. Castlelake seeks to employ a hands-on approach in aircraft investing with a large, dedicated team that is capable of managing all aspects of the aviation investing lifecycle from origination, structuring and financing to asset/ loan/ lease servicing, technical management and trading. Castlelake invests in aircraft and aviation assets, and offers tailored financing, leasing and servicing solutions. Castlelake focuses on commercial aircraft and engines and aviation secured debt. Castlelake’s team includes technical experts, risk management professionals, transaction management and legal expert and dedicated financing specialists that operate as needed at every stage of an investment. Castlelake’s investments also involve secured loans and other financing packages to airlines or lessors that look to refinance or acquire aircraft or to otherwise finance their business operations. Depending on the strategy set forth in the Offering Documents, aviation investments may focus on new aircraft or younger mid-life aircraft, generally yielding stable lower returns or older aircraft and related assets generally with a higher risk and higher return profile. Castlelake’s aviation strategy also includes certain of the Vehicles collateralized by aircraft. Consumer Finance. Castlelake views the consumer finance sector as a broad and resilient opportunity set, supported by a wide range of asset types and origination channels. Within this strategy, Castlelake is focused on constructing portfolios of granular, diversified consumer assets, which we believe provide attractive risk-adjusted returns and allow for consistent performance across varying economic environments. Castlelake generally targets exposure to nonprime and near prime consumers, as Castlelake has observed that these borrower cohorts have historically demonstrated lower performance volatility and more stable loss outcomes during periods of macroeconomic stress compared to prime borrowers. Depending on a Fund’s Offering Documentation, Castlelake seeks to partner with originators that align with the Firm’s underwriting standards and risk management approach while capitalizing on dislocations and structural shifts across the consumer financing landscape. Within the broader consumer finance strategy, Castlelake focuses on, among other asset classes, credit cards, installment loans and autoloans as investable sub-strategies. Small and Medium-Sized Enterprises (“SME”). Castlelake believes financing within the SME space offers compelling investment opportunities that can intersect with a critical social and economic need, especially considering recent bank retrenchment. Castlelake’s believes SME loans are differentiated from the leveraged/syndicated loan category due to their relatively small size, varying collateral packages and the diversity of the underlying borrower types and situations. Castlelake has observed that the proceeds of these loans are typically used to either fund day-to-day business operations (i.e. working capital and support capital expenditure) or finance asset acquisitions. Subject to a Fund’s Offering Documentation, Castlelake’s SME lending strategies involve providing primary credit solutions to SME lenders. Castlelake typically funds

SME assets on a forward flow basis, allowing the Firm to construct portfolios of newly originated receivables and proactively monitor investment performance. Within the SME space, Castlelake focus includes merchant cash advances and equipment leasing opportunities. Residential Mortgages. Castlelake’s residential mortgage strategy is anchored in sourcing and investing in small balance, primarily shorter duration assets in an effort to invest in diversified highly granular pools of residential mortgages or related assets. Castlelake believes this focus provides enhanced transparency into underlying collateral, quicker portfolio turnover, and reduced exposure to idiosyncratic asset level risks. To access these opportunities, Castlelake partners with a network of what it believes are established and specialized originators. Through these longstanding relationships, the Castlelake seeks to leverage the operational expertise and market reach of its originating partners while maintaining disciplined oversight of portfolio composition. Castlelake works closely with each partner to define, refine, and enforce the credit box, in seeking to align the investable assets with the Castlelake’s underwriting standards and risk management framework. Castlelake believes this collaborative approach can enable it to scale exposure efficiently, maintain consistency in asset quality, and capitalize on dislocations or niche origination channels within the broader residential mortgage market. Castlelake, depending on a Fund’s Offering Documentation, may focus on residential mortgage servicing rights or nonqualified mortgages, among other assets in the broader residential mortgages strategy. Commercial Mortgages. Castlelake believes there is substantial opportunities for its Fund to invest in loans backed by small-balance transitional commercial mortgage assets. In this strategy and subject to a Fund’s Offering Documentation, Castlelake targets investment opportunities secured by what Castlelake views to be attractive collateral primarily focused on sectors with strong occupational tailwinds in markets in North America and in certain European markets that appear to be liquidity constrained. Castlelake believes these dynamics create an attractive opportunity to finance assets at an entry price that provides inherent downside protection. Similar to the residential mortgage strategy, Castlelake intends to access these opportunities through a network of established origination partners as opposed to trafficking in broadly marketed auction processes. In these structures, Castlelake believes it is able to reunderwrite each asset and build in structural downside protections. General Risks The transactions that Castlelake engages in involve substantial risks. Growing competition may limit the ability to take advantage of investment opportunities in rapidly changing markets or to access investment opportunities believed to be attractive. Investing involves risk of loss that an investor should be prepared to bear. Due to the nature of Castlelake’s trading and investment activities, results will potentially fluctuate from month to month and from period to period. Accordingly, investors should understand that the results of a particular period will not necessarily be indicative of results in future periods. Certain of the material risks presented by Castlelake’s strategies and investments are set forth below, provided that additional information and additional risks specific to the Accounts will be contained in the respective Offering Documents. Although Castlelake has attempted to tailor certain of the risks to specifically reference Funds or Vehicles, such risks may be applicable to Accounts generally, and as applicable, are intended to be provided with respect to

all Accounts. This brochure does not purport to contain a complete disclosure of all risks that may be relevant to an existing or prospective investor. Material Risks Concentration of Investments. In its multi-strategy Funds, Castlelake is generally not limited in the amount of the Funds’ capital that can be invested in one industry, though a Fund’s Offering Documentation typically contains constraints on sizes or concentrations of individual investments. Although Castlelake will follow a general policy of seeking to spread the Funds’ capital among a number of investments, issuers, industries and geographies, Castlelake may depart from such policy from time to time and the Funds may hold one or more investments that are relatively large in relation to a Fund’s capital or are concentrated in a single issuer or a group of related issuers or in a single industry or in a focused geographical area, all to the extent permitted by the Offering Documents. Although Castlelake’s aviation-focused funds will be heavily concentrated in aviation investments, Castlelake will also follow a general policy of seeking to spread such Funds’ capital among a number of investments, issuers and geographies. However, Castlelake may depart from such policy from time to time and the aviation-focused Funds may hold one or more investments that are relatively large in relation to a Fund’s capital or are or a group of related issuers, credit counterparties or borrowers or in a focused geographical area. The result of such concentration of investments is that a loss in any such position could materially reduce the relevant Fund’s investment returns and/or capital. Furthermore, to the extent that the capital commitments raised are less than the targeted amount or a Fund requires an extended period of time to raise such capital commitments, such Fund may not be able to implement its investment strategy or achieve its investment objectives in the intended manner or on the intended timeline. Such Fund will likely invest in fewer portfolio companies and/or decline certain investment opportunities if there is insufficient capital available, and thus be less diversified. Additionally, a Fund's organizational expenses could be higher if its fundraising period continues for an extended period. Availability of, and Competition for, Suitable Investments. The activity of identifying, completing and realizing attractive investments is usually highly competitive and involves a high degree of uncertainty. Castlelake competes for investments with many other investors, including, other investment partnerships and corporations, strategic or industry acquirers, sovereign wealth funds, pension plans, institutional investors, banks and other financial institutions and other financial investors, including hedge funds and private equity funds or investment firms (or consortium thereof) investing directly or through affiliates. Further, over the past several years, an ever-increasing number of private equity funds have been or are being formed (and many existing funds have grown in size). Additional funds with similar investment objectives may be formed in the future by other unrelated parties. Some of these competitors could have more relevant experience, greater financial resources, a greater willingness to take on risk, greater negotiating power, a lower cost of capital, beneficial regulatory structures and/or and more personnel than Castlelake and its affiliates, and could be more well-known than Castlelake. The Funds could also incur significant expenses identifying, investigating and/or attempting to make potential investments that are ultimately not consummated. Castlelake expects that competition for appropriate investment opportunities could increase, which could also require the Funds to participate in auctions, the outcome of which cannot be guaranteed, thus reducing the number of investment opportunities available to the Funds and/or adversely affecting the terms upon which

investments can be made. Participating in auctions will also increase the pressure on the Funds with respect to pricing of a transaction. In addition, Castlelake has found that competitors for investment opportunities are willing to offer seller-favorable terms in a transaction, such as providing a “reverse break-up fee” and fund-level guarantees. In the event a financing-related closing condition is not available to the Funds or if the Funds are required to provide a reverse break-up fee or guarantee in connection with a potential investment, the Funds could become obligated to consummate a transaction on less favorable terms or could be required to fund the reverse break-up or similar fee in connection with a potential investment that is not made. There can be no assurance that the Funds will be able to locate, complete and exit investments which satisfy the Funds’ rate of return objective or realize upon their values or that it will be able to fully invest its available capital. It is possible that the capital committed to or called by a Fund will never be fully invested if enough sufficiently attractive investments are not identified. An investor should be aware that it may lose all or part of its investment in the Funds. Inflation and Deflation. Inflation risk is the risk that the value of certain investments or income thereon will be worth less in the future as inflation decreases the value of money. As inflation increases, the real value of a Fund’s investments can decline. Deflation risk is the risk that prices decline over time – the opposite of inflation. Deflation may have an adverse effect on the creditworthiness of portfolio companies in which the Funds invests and may make defaults more likely, which may result in a decline in the value of the Fund’s investments. High rates of inflation and rapid increases in the rate of inflation generally have a negative impact on financial markets and the broader economy. In an attempt to stabilize inflation, governments may impose wage and price controls or otherwise intervene in a country’s economy. Governmental efforts to curb inflation, including by increasing interest rates or reducing fiscal or monetary stimuli, often have negative effects on the level of economic activity. Persistently high levels of inflation could have a material and adverse impact on the Fund’s investments and its aggregated returns. For example, if a portfolio company were unable to increase its revenue while the cost of relevant inputs was increasing, the portfolio company’s profitability would likely suffer. Likewise, to the extent a portfolio company has revenue streams that are slow or unable to adjust to changes in inflation, including by contractual arrangements or otherwise, the portfolio company could increase revenue by less than its expenses increase. Conversely, as inflation declines, a portfolio company may see its competitors’ costs stabilize sooner or more rapidly than its own. Additionally, because the preferred return is not linked to the rate of inflation, as the rate of inflation increases, the proportion of real returns (i.e., the nominal rate of return less the rate of inflation) treated as preferred return decreases and the proportion of real returns subject to performance-based compensation increases. There can be no assurance that high rates of inflation will not have a material adverse effect on the investments of the Fund. Increases in Assets under Management. Despite limitations on commitments on a Fundby-Fund basis, Castlelake has not limited the aggregate amount of assets it may manage. Subject to requirements in the Offering Documents, Castlelake will raise new funds, vehicles or other investment products, may pursue new investment strategies and will continue to seek new investment capital from suitable sources. There can be no assurance that appropriate investment opportunities will be available to accommodate future increases in assets under management, which may require Castlelake to modify its investment decisions for the Funds because it cannot deploy all the assets in the manner it desires.

Asset Managers and Service Companies. Castlelake may enter into arrangements with asset or industry specialized management or advisory teams (which may include joint venture partners) (“Asset Managers” or “Operating Partners”) to acquire, manage and dispose of certain assets, which can include expense, fixed payments and/or profit-sharing arrangements with such persons, thus impacting returns to the Funds. Such payments and profit-sharing arrangements are in addition to the expenses, management and other fees and performance-based compensation to Castlelake and its affiliates and are not subject to an offset if paid to a third-party. It is possible for certain Asset Managers to receive incentive compensation related to the value or performance of specific assets serviced by them even though a Fund, as a whole, does not have positive returns. The failure on the part of Castlelake to select or retain the right Asset Managers and/or to establish a governance and compensation structure that provides for the appropriate balance of economic incentives to the Asset Manager and oversight by Castlelake, or to provide servicing with respect to certain assets (including securitization-like vehicles) on its own, could adversely impact the Funds. If an Asset Manager breaches its governing agreement or otherwise fails to perform its responsibilities adequately, the Funds may be adversely affected. In addition, given the specialized nature of these Service Providers, they may be difficult to replace if needed and transfers of responsibilities may cause a disruption of servicing or performance of the related investment. Use of Affiliates for Servicing. Castlelake or its management company affiliates act as servicer and receive compensation from the Vehicles in which some Funds have an interest and also for other Fund investments or entities, provided that fees to affiliated servicers (excluding fees to Platform Servicing Companies and excluding Insurance Servicing Fees and Structuring and Syndication Fees) will typically be structured (via offset to management fees or otherwise) so that, in addition to the payment of management fees, a Fund does not effectively bear the fees with respect to its allocable portion of investment in the Vehicles, financing facility or other entity. This can be accomplished through special allocation of the relevant fees to investors other than the Funds, or if any Fund is subject to such fees payable to Castlelake or its affiliates, any such amounts (net of related expenses) are applied to offset the Fund’s management fees. In general, these management fee offsets apply only with respect to the capital commitments of fee-paying investors and do not apply if a Fund ceases to pay management fees at the end of its term or otherwise. In addition, if these fees exceed management fees, depending on the terms of the relevant Offering Documents, such additional fees will be retained by Castlelake or potentially shared in whole or part with the Funds. The provisions noted herein do not apply if one portfolio company is providing services to another portfolio company or Fund. To the extent that servicing with respect to certain assets is performed in-house by Castlelake employees, there can be no assurance that the Firm will in the future be able to attract, train, develop, integrate or retain, suitable employees with the skills required to provide such servicing. Qualified personnel, in particular technical aviation servicing professionals, are in great demand throughout the aviation industry. Competitors and other entities may attempt to recruit Castlelake’s employees. The loss of such personnel, the inability to identify, attract or retain qualified personnel in the future or delays in hiring qualified personnel, particularly technical aviation servicing professionals, may make it difficult for Castlelake to service such assets. Proprietary Information. Castlelake relies on trade secret and other similar laws and confidentiality agreements with employees and Service Providers to protect its confidential information, proprietary data and databases including related to aircraft and aviation assets,

intellectual property and portfolio modeling approach (“intellectual property rights”), all of which offer only limited protection. Castlelake’s intellectual property rights may be compromised, stolen, lost or invalidated, or competitors may develop similar intellectual property rights independently. Legal proceedings to enforce Castlelake’s intellectual property rights may be unsuccessful and could also be expensive and divert management’s attention. Co-Investment Risks. Castlelake will provide or commit to provide co-investment opportunities to one or more Fund investors and/or third parties (“Co-investor”) through partnerships, joint ventures or other entities or arrangements. These co-investment opportunities could close concurrently with the Funds, or the Funds are expected to invest with the expectation to subsequently arrange for co-investments. Conflicts of interest are expected to arise in the allocation of such co-investment opportunities, which can be made to one or more investors for any number of reasons, as determined by Castlelake in its sole discretion. The allocation of coinvestment opportunities could be made to one or more persons for any number of reasons, which would not necessarily be in the best interests of the Funds or any individual investor. There are risks in connection with such third- party involvement, including the possibility that a co-investor may at any time have economic or business interests or goals that are inconsistent with the Funds and may have at any time financial difficulties, resulting in a negative impact on such investment, may have economic or business interests or goals which are inconsistent with those of the Accounts, or may be in a position to take (or block) action in a manner contrary to the Fund’s investment objectives. In addition, the Fund may in certain circumstances be liable for the actions of, or be responsible for expenses not allocable to or recoverable from, its third-party co-investor or partner. Conflicts of interest may arise in the allocation of such co-investment opportunities. The allocation of co-investment opportunities, which may be made to one or more persons (including to Brookfield (as defined hereinafter) and/or its affiliates) for any number of reasons as determined by Castlelake in its discretion, may not be in the best interests of the Fund or any individual investor. In exercising its discretion in connection with such co-investment opportunities, Castlelake may consider some or all of a wide range of factors, in certain cases including factors which benefit Castlelake such as the likelihood that an investor may invest in a future fund sponsored by Castlelake or its affiliates. See also “Conflicts of Interest” in Item 10. Castlelake seeks to mitigate this conflict of interest with allocation policies and practices that provide that transactions and investment opportunities will be allocated to the Funds in accordance with each Funds’ investment guidelines and Offering Documents. Castlelake’s investment allocation process described in Item 10 of this brochure further mitigates the risk of investments being allocated inappropriately. Funds may also co-invest in investments with third parties (including to Brookfield (as defined hereinafter) and/or its affiliates) through partnerships, joint ventures or other entities or arrangements, which, among other things, may result in the Funds lacking control or having limited influence. Such investments may involve risks, including the possibility that a third-party coinvestor or partner may at any time have economic or business interests or goals that are inconsistent with those of the applicable Fund, or may be in a position to take action contrary to the investment objectives of such Fund. In addition, a Fund may in certain circumstances be liable for actions of its third-party co-investor or partner. There can be no assurance that such Fund’s return from a transaction would be equal to and not less than the return of another party that was

allocated a co-investment opportunity and that is participating in the same transaction. Further, expenses relating to potential co-investments that are not consummated may be borne by the Funds. Also, any co-investment by the Funds through a special purpose vehicle (“SPV”) may expose the Funds to additional risk given that the SPV may not have segregation of liabilities arising from different investments, and the Funds can have liability regardless of whether they participate in all investments made by such SPV or otherwise in excess of their participation percentage if any other SPV participant defaults on its obligations. When, and to the extent that employees and related persons (including, for the purposes hereof, to Brookfield (as defined hereinafter) and/or its affiliates) of Castlelake make capital investments in or alongside a Fund, Castlelake is subject to conflicting interests in connection with these investments. Castlelake’s allocation of co-investment opportunities among such persons may not, and often will not, result in proportional allocations among such persons, and such allocations may be more or less advantageous to some persons relative to others. Third-Party Involvement. The Funds are permitted to co-invest in investments with third parties (including in certain instances co investing with investors or entities formed for them) through partnerships, limited liability companies, joint ventures, or other entities. These investments involve risks not present if a third- party were not involved, including the possibility that the third-party can take action contrary to the investment objectives of the Fund, may be unable or unwilling to perform its duties or obligations under the relevant agreements, may have financial, legal or regulatory difficulties resulting in a negative impact on a joint venture, or may have economic or business interests or goals which are inconsistent with those of the Funds. In addition, a Fund may in certain circumstances be liable for actions, costs and/or expenses of its third-party co-investors. Castlelake’s ability to exercise control or significant influence in connection with the joint venture may be limited and will depend on the nature of the governing documentation. Execution Risks and Error. The execution of the trading and investment strategies employed by Castlelake can involve complex transactions, the use of negotiated terms with counterparties, and difficult to execute transactions. In each case, Castlelake seeks best execution and has trained execution and operations professionals devoted to executing, settling and clearing such investments. However, in light of the complexity and global diversity involved, some slippage, errors and miscommunications with brokers and counterparties are inevitable and could result in losses to the Funds and Vehicles. Castlelake will evaluate the merits of potential claims for damage against brokers and counterparties who are at fault, and to the extent practicable will seek to recover losses from those parties. Castlelake could choose to forego pursuing claims against brokers and counterparties on behalf of the Funds for any reason including, but not limited to, the cost of pursuing claims relative to the likely amount of any recovery and the maintenance of its business relationships with brokers and counterparties. In addition, Castlelake’s own execution and operations professionals could be solely or partly responsible for errors in placing, processing, and settling trades that result in losses to the Funds. To the greatest extent permitted under applicable law including the Advisers Act, Castlelake is not liable to the Funds for losses caused by brokers or counterparties, or by Castlelake’s own negligence or contributory negligence, and investors and the Funds waive potential claims for damages arising from the operation of the Funds, including damages resulting from Castlelake’s own negligence or contributory negligence, and expect some execution losses to the Funds.

Portfolio Company Management Teams. In the case of investments made by the Funds with respect to companies, each such company’s day-to-day operations will generally be the responsibility of that entity’s management team. There can be no assurance that the existing management team, or any successor management team, will be able to operate the company in accordance the plans or expectations of Castlelake. Some of the Funds’ investments will represent minority and/or non-voting positions in portfolio companies, and, although Funds in certain circumstances have representatives that serve on the boards of directors, such representatives may not have the power individually to exert significant control over a portfolio company’s boards of directors and management. The Funds will rely significantly on the existing management and boards of directors of such portfolio companies, which may include unseasoned directors, managers and representatives of other investors with whom the Funds are not affiliated and whose interests or views conflict with the interests of the Funds. To the extent that the management of a portfolio company performs poorly, or if a director or key manager of a portfolio company engages in misconduct, commits material errors in carrying out his or her duties, or terminates his or her employment or association with such company, the applicable Funds’ investment in such company will be adversely affected. Counterparty and Settlement Risks. Many of the markets in which Castlelake effects transactions are through private transactions. Some of the markets are “over-the-counter” or “interdealer.” The counterparties in such private transactions and participants in these types of markets are typically not subject to the same credit evaluation and regulatory oversight as are members of “exchange-based” markets. There is a risk that a counterparty will not settle a transaction because of a credit or liquidity problem, thus causing the Funds to suffer a loss. Such “counterparty risk” is accentuated for contracts with longer maturities where events could intervene to prevent settlement, or where the Funds have concentrated its transactions with a single or small group of counterparties. In addition, there may be practical, or timing problems associated with enforcing the Accounts rights to its assets in the case of an insolvency of any such party. Many non-U.S. countries have different clearance and settlement procedures from developed countries. There may be no central clearing mechanism of settling investments and no central depository or custodian for the safe keeping of securities. The registration, recordkeeping and transfer of instruments can be carried out manually, which could cause delays in the recording of ownership. Increased settlement risk could increase counter-party and other risk. Certain markets have experienced periods when settlement dates are extended, and during the interim, the market value of an instrument may change. Moreover, certain markets have experienced periods when settlements did not keep pace with the volume of transactions resulting in settlement difficulties. Because of the lack of standardized settlement procedures in some non-U.S. countries, settlement risk is more prominent. Tax Considerations. The Accounts may take positions with respect to certain tax issues that depend on legal and other conclusions not yet addressed by the courts or governing tax authorities. Should any such positions be successfully challenged by governing tax authorities, there could be a material adverse effect on the Funds. In January 2023, Castlelake entered into an agreement with a third-party tax and accounting firm to utilize a managed services platform to provide, for the benefit of Castlelake, and the Accounts certain tax compliance, structuring and related services. The agreement with the thirdparty firm includes, among other things, an agreed upon reduced fee rate for the services provided

which incentivizes Castlelake to outsource the services to such third-party but which Castlelake also believes will be a benefit to the Accounts. As part of the agreement, Castlelake agreed to utilize the third-party provider for the tax, structuring and related services for a period of at least five years, and the expenses will be allocated among Castlelake and the Accounts according to Castlelake’s expense allocation policy. There can be no guarantee that such allocation will be in a manner equitable to the Accounts. Certain Castlelake tax personnel were given the opportunity to join the third-party provider and certain of these individuals did elect to join the provider beginning in February 2023. These individuals assist the provider in providing the tax and related services to Castlelake and the Accounts and their costs and expenses will therefore be borne by Castlelake and/ or the Accounts as appropriate. There is no guarantee that, in the case of the tax services provider or in other circumstances, former employees will perform services exclusively for the benefit of Castlelake and the Accounts and in fact it is contemplated, in the case of the tax services provider, that such former employees will ultimately spend substantial time performing services for other clients of the third-party provider. When determining how costs will be allocated, Castlelake will utilize a fair and reasonable methodology given the circumstances unless Castlelake reasonably believes that another allocation methodology would be more equitable. Fund-Owned Administrative Entities. Certain of the Accounts hold a shared interest in one or both of the following entities, Castlelake Aviation Services Limited (“CASL”) and CL Lux Services S.a r.l (“CL Lux”) (together, the “Fund-Owned Administrative Entities”), which provide certain corporate secretarial, reporting, tax, administrative, lease management and accounting services, as well as certain other services that are not required to be provided by Castlelake or its affiliates under the Offering Documents, to certain investment Vehicles and structures of such Accounts, as well as to other Castlelake Vehicles and to future Funds and/or Vehicles managed by Castlelake. The Funds may have an interest in one or both of the Fund-Owned Administrative Entities and/or will pay such entities a fee, and/or reimburse certain expenses and operating costs, for the provision of services utilized by the Funds in making, monitoring and administrating investments through various investment structures. The foregoing amounts will be borne as Account expenses and will not offset the management fee. The ownership structure of CL Lux is constituted such that all Funds benefitting from CL Lux services in a material way would be shareholders of CL Lux. As Funds are liquidated or new Funds are created, such Funds would withdraw from or join, respectively, the ownership of CL Lux. Castlelake does not believe that, as a captive servicing company, CL Lux has enterprise value or material liabilities, so owners are generally expected to enter and exit without charge or payment. The cost sharing among Funds generally reflects a use-based charge for the CL Lux services, but which also provides for an allocation of costs to nonowners benefitting from CL Lux services. CASL is owned by all Funds using CASL’s services (other than in certain de minimis ways). As Funds are liquidated or new funds are created, such Funds would withdraw from or join, respectively, the ownership of CASL. Castlelake does not believe that, as a captive servicing company, CASL has enterprise value or material liabilities, so owners are generally expected to enter and exit without charge or payment. Each Fund or Vehicle using CASL services, other than in certain de minimis ways, pays CASL a fee and/or reimburses certain expenses and operating costs. These charges are designed to allocate CASL costs and expenses to the Funds and Vehicles on a reasonable pro rata basis. To the extent that CASL resources are used to support third-party

servicing (including by Castlelake when servicing assets not relating to Account investments), such third-party and/or Castlelake will be allocated and required to pay a reasonable pro rata portion of the CASL costs (and generally including a reasonable margin). With respect to CASL, as of December 31, 2022, certain former employees of Castlelake Aviation Holdings (Ireland) Limited, an affiliated entity of Castlelake, were given the opportunity to become, and generally did become, employees of CASL. CASL, staffed by these and other employees, provides the services described above to the Accounts. These individuals assist CASL in providing services to the Accounts and potentially to Castlelake. The costs of CASL, including these individuals, will therefore be borne by the Accounts, as well as Castlelake,, as noted above and as Castlelake reasonably deems appropriate. Castlelake Aviation Holdings (Ireland) Limited (“CAHIL”), a wholly owned subsidiary of Castlelake, and CASL share office space in Dublin, Ireland. The costs and expenses of this leased space, as well as certain shared facilities including cafe, conference rooms and other services and resources, are shared between CAHIL and CASL. In addition, the landlord required a guarantee from both Castlelake and CASL in respect of the lease, which guarantee is joint and several. CAHIL (including Castlelake) and CASL entered into a cost sharing agreement allocating obligations with respect to the guarantee and with respect to office costs and common area facilities. Engagement of Service Providers and Other Personnel. Over the life of the Accounts, Castlelake generally expects to exercise its discretion to recommend to a Fund or to a portfolio investment thereof that it contract for services with, or select on behalf of the Accounts various Service Providers, potentially including, among others: (i) Castlelake and/or an affiliate thereof, which could include other portfolio investments of the Account and at rates determined or substantively influenced by Castlelake (including as contemplated by the following paragraph); (ii) servicers that are portfolio investments of the Funds; (iii) an entity with which Castlelake or its affiliates or current or former members of their personnel has a relationship or from which such person derive a financial or other benefit (including one of the Accounts); (iii) an investor (or a limited partner of another fund) or its affiliates; or (iv) one or more portfolio companies. This subjects Castlelake to potential conflicts of interest, because although it intends to select Service Providers that it believes are aligned with its operational strategies and that will enhance portfolio investment performance, Castlelake may have an incentive to recommend the related or other person because of its financial or business interest. Additionally, Castlelake, because of such incentive or for other reasons (including whether the use of such persons could establish, recognize, strengthen or cultivate relationships that have the potential to provide longer-term benefits to Castlelake or the Accounts could favor such retention or continuation even if a better price and/or quality of Service Provider could be obtained from another person. Whether or not Castlelake has a relationship with, or receives financial or other benefit from recommending a particular Service Provider, there can be no assurance that no other Service Provider is more qualified to provide the applicable services or could provide such services at lesser cost. The Accounts’ portfolio investments could be counterparties to or participants in agreements (including with respect to services), transactions or other arrangements with portfolio investments or portfolio companies in which an Account may or may not have an investment, subject to any requirements of the relevant governing agreements, including arrangements that

may not have otherwise been entered into but for the relationship with Castlelake or an affiliate, which may involve fees, commissions, servicing payments, discounts, rebates and/or other benefits to another Account (or its portfolio companies or investments), which are not subject to the management fee offset provisions. For example, other Accounts may hold equity or other investments in companies or businesses that provide services to the Accounts investments for a fee (including affiliated Service Companies). The fees paid or borne by the Accounts in connection with such investments that accrue to other Accounts (or their portfolio companies or investments) will not offset the management fee or otherwise be shared with the investors. Castlelake or an affiliate will attempt to negotiate such arrangements on an arms-length basis, but will not always be able to do so, depending on, in part, the level of control that Castlelake may have in such investment. Castlelake will make determinations of competitive market rates based on its consideration of a number of factors, which could include, for example, input from management of the underlying company, benchmarking data and other methodologies determined by Castlelake to be appropriate under the circumstances. While Castlelake will generally seek to obtain benchmarking data regarding the rates charged or quoted by third parties for similar services, relevant comparisons will not always be available for a number of reasons, including, without limitation, as a result of a lack of a substantial market of providers or users of such services or the confidential or the unique nature or structure of the transaction and/or bespoke nature of such services. Benchmarking data generally includes information relating only to hourly or project-based rates, and so generally does not include the value of any profits, participation or equity interests (including co-investment opportunities) in or relating to portfolio companies with respect to which the relevant services are provided; as such, references to “market” or “armslength” (or similar formulations) rates or terms refer only to the contracted-for hourly or projectbased rates. Therefore, such market comparisons will not always result in meaningful market references for comparable services. Any fees, payments or expenses in respect of any such arrangements paid by the Accounts to (or received by) Castlelake, their affiliates or their respective portfolio investments or portfolio companies, as well as the expenses, charges and costs of any benchmarking, verification or other analysis related thereto, will be retained by such persons and will not offset the management fee payable by the Accounts, and will, in certain circumstances, result in incurrence of greater expenses by the Accounts and its portfolio investments than would be the case if such services were provided by third parties. Castlelake is also permitted to employ personnel with pre-existing ownership interests in or who were employed by portfolio investments owned by the Accounts; conversely, former personnel or executives of Castlelake may, and in certain cases are expected to, provide services to the Accounts’ portfolio investments and/or serve in significant management roles at portfolio investments or as Service Providers recommended by Castlelake. Similarly, Castlelake and/or its personnel maintain relationships with (or may invest in) financial institutions, Service Providers and other market participants, including managers of private funds, banks, brokers, advisors, consultants, finders (including executive finders and portfolio investment finders), executives, attorneys, accountants, institutional investors, family offices, lenders, current and former employees, and current and former portfolio investment executives, as well as certain family members or close contacts of these persons. Certain of these persons or entities will invest (or will be affiliated with an investor) in, engage in transactions with and/or provide services (including services at reduced rates) to, Castlelake and the Accounts. Castlelake is expected to have a conflict of interest with the Accounts in recommending the retention or continuation of a third-party

Service Provider to the Accounts or a portfolio investment owned by the Accounts if such recommendation, for example, is motivated by a belief that the Service Provider or its affiliate(s) will continue to invest in one or more funds Castlelake advises, will provide Castlelake information about markets and industries in which Castlelake operates (or is contemplating operations) or will provide other services that are beneficial to Castlelake. Castlelake is also expected to have a conflict of interest in making such recommendations in that Castlelake has an incentive to maintain goodwill between itself and the existing and prospective portfolio investments for the Accounts and other funds and investment vehicles that Castlelake advises, while the products or services recommended could not necessarily be the best available to the portfolio investments held by the Accounts. Pay-to-Play Laws, Regulations and Policies. A number of U.S. states, their subdivisions, and municipal pension plans have adopted stringent investment policies or so-called “pay-to-play” laws, regulations or policies which prohibit, restrict or require disclosure of payments to (and/or certain contacts with) certain politicians or state officials by individuals and entities seeking to do business with state entities, including those seeking investments by public retirement funds. The SEC has a rule that, among other things, prohibits an investment adviser from providing advisory services for compensation to a government client for two years after the adviser or certain of its executives or employees makes a contribution to certain elected officials or candidates. If Castlelake, the General Partners, any of their respective employees or affiliates or any service provider acting on their behalf, fails to comply with such laws, regulations or policies, such noncompliance could have an adverse effect on the Fund. Such investors could also negotiate for Side Letter provisions that could be more expansive in their requirements than such laws, rules, regulations or policies. In certain cases, violations of these laws, rules, regulations, policies or Side Letter provisions, whether as a result of the conduct of the General Partners or Castlelake, or because of an action taken by a portfolio investment or an investor or their personnel, could have an adverse effect on a Fund by, for example, providing the basis for such investor to cease funding its obligations to a Fund. Investors could also seek to pursue individual remedies, including withdrawal rights, which could be included in Side Letters or otherwise imposed by statute. Risk of Controlled Group Liability for Portfolio Company Pension Plans. A Fund, along with their affiliates (which could include any parallel or related funds), is permitted to obtain a controlling interest (e.g., 80% or more voting control or value for a corporation or capital or profits interest for a Fund or LLC) in certain portfolio investments which may impose risks of liability to the Fund under ERISA for a portfolio investment’s underfunded pension plans, including withdrawal liability under any Taft-Hartley/multiemployer plans in which such portfolio investment’s contribute. Such liabilities might arise if the Fund (or Castlelake, on behalf of the Fund) were deemed to be engaged in a “trade or business” under ERISA, and could have a material adverse effect on the operations of such Fund and the companies in which the Fund invests. The determination of whether an investment fund, like one of the Fund, is engaged in a trade or business under ERISA is uncertain and could depend upon which U.S. Federal Circuit has jurisdiction over the matter. In at least one circuit, a court found that, in certain circumstances, an investment fund could be treated as a “trade or business” for purposes of determining pension liability under ERISA. Activities which may indicate the possibility of a trade or business being conducted as opposed to passive investment, include, but, are not limited to, management of such portfolio investment’s operations, authority with respect to the hiring, termination and compensation of such portfolio investment’s employees and agents and receipt of fees or other compensation that offset

the management fee for services provided to such portfolio investment by the Fund or its affiliates, including Castlelake. If a Fund (along with its affiliates and any parallel or related funds) were treated as both engaged in a trade or business for purposes of ERISA and to be under common control with the portfolio investment, then the Fund (and certain affiliates of the Fund in the same ERISA controlled group (e.g., other controlled portfolio investments)) could be jointly and severally liable to satisfy the liabilities of a specific portfolio investment to an ERISA pension plan (i.e., the Fund might suffer a loss which is greater than its actual investment in the specific portfolio investment to the extent that such portfolio investment becomes insolvent and is unable to satisfy its own obligations). It should be noted that the test as to whether a Fund is engaged in a trade or business for purposes of ERISA may not necessarily be the same as the test that would be used for U.S. Federal income tax purposes. Litigation. Litigation can and does occur in the ordinary course of the management of the Accounts. The Accounts may be engaged, directly or indirectly through various subsidiaries, in litigation both as a plaintiff and as a defendant. Such litigation can arise as a result of credit disputes, defaults, bankruptcies or other reasons. The outcome of such proceedings may materially adversely affect the value of the Funds and may continue without resolution for long periods of time. Any litigation may consume substantial amounts of the time and attention of Castlelake and its affiliates, and that time and the devotion of these resources to litigation may, at times, be disproportionate to the amounts at stake in the litigation. Litigation entails expense and the possibility of counterclaims against the Funds including Castlelake and its affiliates and ultimately judgments may be rendered against a Fund for which such Fund does not carry insurance. Castlelake and others are indemnified by the Accounts in connection with such litigation, subject to certain conditions. The expense of defending against third-party claims made against the Accounts, their portfolio investments or persons indemnified by them and paying any amounts pursuant to settlements or judgments generally would be borne by the Funds or the Accounts and may be significant unless indemnification or other rights can be enforced, or insurance is available. Contingent Liabilities. The Funds may from time to time incur actual or potential contingent liabilities in connection with an investment and/or in connection with financing for such investments. The Funds may also enter into agreements pursuant to which they agree to assume responsibility for default risk presented by a third-party. In addition, the Funds may purchase investments that are subject to contingent liabilities. These arrangements may result in contingent liabilities which will be borne by such Funds. Limitations on Actions and Indemnification. The Offering Documents limit the circumstances under which Castlelake and respective General Partners, investment managers and similar entities can be held liable to the Funds or the Vehicles. As a result, the Funds or Vehicles may have a more limited right of action in certain cases than they would in the absence of such a limitation. In addition, the Funds and the Vehicles are required to indemnify Castlelake, its affiliated persons and entities (including employees, officers, directors, partners and members) and other parties set forth in the Offering Documents, including, without limitation, members of the Funds’ Advisory Committees and boards of directors of subsidiaries and portfolio companies for liabilities incurred in connection with the affairs of the Funds and/or the Vehicles, absent (among other things) bad faith, gross negligence or willful misconduct. The application of the foregoing standards can result in the Funds and the Vehicles bearing significant financial losses even where such losses were caused by the negligence (even if heightened) of the covered persons. Although

insurance may exist, such insurance may not be sufficient, may not be applicable or may not be elected for various reasons. The indemnification obligations of a Fund would be payable from the assets of that Fund, including the unfunded capital commitments to such Fund. If the assets of a Fund are insufficient to pay any such indemnification obligations, distributions already made by such Fund may be recalled in order to pay such obligations (subject to certain limitations set forth in the applicable Offering Document). As a result, there could be periods where a Fund is advancing expenses to an individual or entity with whom the applicable Fund is not aligned or is otherwise an adverse party in a dispute. Moreover, the relevant General Partner could, notwithstanding any actual or perceived conflict of interest, be the beneficiary of any decision by it to provide indemnification (including advancement of expenses) to certain persons or entities including itself. Such liabilities of a Fund could not be resolved prior to the date that a Fund will be terminated, either by expiration of a Fund’s term or otherwise, and could extend beyond an investor’s withdrawal from a Fund. Certain investors cannot, for regulatory or policy reasons, be permitted to fund indemnification obligations, or their ability to fund such obligations could be restricted. In those cases, a Fund could be required to satisfy any shortfall with respect to indemnification obligations even if such obligations are the direct result of a breach of representation, warranty or covenant by any such restricted investor. It should be noted that the General Partner could, but shall not be required to, cause a Fund to purchase insurance for such Fund, the General Partner, Castlelake and their employees, agents and representatives at the expense of a Fund. Although the Offering Documents generally contain broad exculpation and indemnification provisions, Castlelake will not interpret such provisions to constitute a waiver of any person’s non-waivable federal fiduciary duties to the relevant Fund under the Advisers Act. The relevant liability standards under insurance coverage procured by Castlelake are expected to vary by carrier, and such standards are expected to vary depending on, for example, coverage features or limitations then-available from the carrier at the time of insurance contract renewal. As a result, insurance coverages are expected to vary from relevant liability and/or indemnity standards in the Offering Documents. Investors generally will be responsible for insurance premiums, as set forth in the Offering Documents. regardless of whether the liability and/or indemnity standards in Castlelake’s insurance coverage are higher or lower than that set forth in the Offering Documents. Additionally, while co-investors and/or co-investment vehicles have the potential to benefit from the General Partner’s appointment of portfolio company directors, they typically will not bear the cost of liability insurance related to such appointment, to the extent liability insurance is purchased by the relevant Fund. Exit Risk. There is risk that Castlelake will be unable to realize investment objectives through the sale or disposition of investments at an attractive price, within any given period of time, or will otherwise be unable to complete any exit strategy. In particular, these risks could arise from the absence of an established market for investments, changes in the financial condition or prospects of prospective purchasers, lack of prospective purchasers at reasonable prices or at all, changes in national or international economic or political conditions and changes in laws, regulations or fiscal policies of jurisdictions in which investments are located. The foregoing will often make it unlikely that a Fund will be able to fully exit all investments within its stated term and the liquidation of such Fund may extend materially beyond such term.

Projections. No Assurance of Investment Return. The Funds will make investments relying upon projections developed by Castlelake, operating or joint venture partners or a portfolio company management team concerning future performance of the relevant assets and cash flow. In all cases, projections are only estimated future results that are based upon information developed by Castlelake and/or received from third parties and upon assumptions made at the time the projections are developed. Projections are inherently uncertain and subject to factors beyond the control of Castlelake and the portfolio investment in question. There can be no assurance that the results set forth in the projections will be attained, and actual results may be significantly different from the projections. The inaccuracy of certain assumptions, the failure to satisfy certain financial requirements and the occurrence of unforeseen events could materially impair the ability of Funds to realize projected values and/or cash flow. There is no assurance that the Funds will be able to invest their capital on attractive terms or generate returns for their investors. There can be no assurance that the Funds’ investments will increase in value or that the Funds or their investments will not incur significant losses. Unspecified Investments. The Funds generally have broadly permissive investment mandates with limited prohibitions on certain types of investments. Castlelake has significant discretion to pursue investments that it deems to be consistent with the investment objectives of a Fund. With limited exceptions, the Offering Documents of the Funds do not identify the specific investments that they will make or specify mandatory allocations among their respective strategies. Accordingly, investors must rely upon the ability of Castlelake to identify, structure and make investments consistent with the Funds’ investment objectives and policies. Although Castlelake believes that it has been successful in locating appropriate investments in the past, the Funds could be unable to find a sufficient number of attractive opportunities to invest the committed capital or meet their investment objectives. Need for Follow-On Investments. Following an initial investment, Funds are permitted to provide additional funds to an investment or may have the opportunity to increase or expand an investment. If a Fund is able to make a follow-on investment, this may result in capital being called after the investment or commitment period or even after the term of the Fund, subject to the terms and conditions of the Offering Documents. There is no assurance that Funds will make follow-on investments or will have sufficient funds to make all or any of such investments, or that any followon investment a Fund participates in will be successful. Any decision not to make follow-on investments or the inability to make such investments may have a substantial negative effect on an investment in need of such an investment or may result in a lost opportunity for the Funds to increase participation in a successful investment. Additionally, such failure to make such investments may result in the dilution of Funds’ ownership in an investment if a third-party or another Fund invests in such investment. In addition, many investments, particularly those in “platform” phase, could need additional capital to sustain their working capital needs. If the capital provided by Funds is not sufficient, or Funds are unable to provide additional capital, further capital may need to be raised for an investment at an unfavorable price. To the extent some or all of the existing Funds do not participate in additional financing rounds, those Funds’ interests in an investment may be diluted, potentially materially. Conversely, co-investors that participated in an initial investment could choose not to participate in a follow-on investment, which could increase a Fund’s exposure to such investment.

Investments Longer than Term. The Funds will make certain investments that have durations that are notionally longer than the expected term of the Funds and which the Funds, as part of the investment thesis, expect to be able to exit earlier than maturity of such investments. Castlelake may not be able to achieve these exits in a timely fashion. In addition, the Funds may make investments which may not be advantageously disposed of, or have liabilities that may not be resolved, prior to the expiration of a Fund’s term or otherwise. Although Castlelake expects that investments will be disposed of prior to winding up and termination or be suitable for in-kind distribution at the winding up and termination and Castlelake has a limited ability to extend the term of a Fund, a Fund may have to sell, distribute or otherwise dispose of investments or resolve litigation or other contingent liabilities at a disadvantageous time as a result of the winding up and termination. These investments may also suffer from a lack of capital if such investments need capital, but the Funds are at a stage such that no capital is available. In addition, there can be no assurances with respect to the time frame in which the winding up and the final distribution of proceeds from the Fund will occur and such will often extend beyond the stated term of a Fund, potentially materially so. Cybersecurity Breaches and Identity Theft. Cyber-attacks and other malicious Internetbased activity continue to increase in frequency and magnitude. Techniques used to sabotage or obtain unauthorized access to systems or networks change frequently and are not generally recognized until launched against a target. Neither Castlelake nor any third-party partners or Service Providers may be able to anticipate these techniques, react in a timely manner, or implement adequate preventive measures. Castlelake’s information and technology systems may be vulnerable to actual or perceived damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by its professionals or Service Providers, or other disruptive events including denial-of-service attacks, power outages, and catastrophic events such as fires, floods, tornadoes, hurricanes and earthquakes. Cyber-attacks may also take the form of socially engineered frauds, such as phishing. There have been reports of alleged Chinese and Russian hacking attempts on American corporate intellectual property and Castlelake and its portfolio investments could be at risk of cyber-attacks. Third parties, including activist, criminal, nationstate or terrorist actors, could also attempt to fraudulently induce Castlelake’s employees, customers, third-party Service Providers or other users of Castlelake’s systems to disclose sensitive information to gain access to Castlelake’s data or that of the Funds, the investors or the portfolio investments. Entities and Service Providers have also been subject to “ransomware” attacks. As further evidence of the increasing and potentially significant impact of cyber security breaches, in recent times the U.S. government and several multinational companies, including financial institutions and retailers, have reported cyber security breaches affecting their computer systems that resulted in the personal information of millions of citizens, customers and employees being compromised. To the extent that a portfolio investment, Fund, General Partner, Castlelake or one or more of their service providers or respective affiliates is subject to cyber-attack or other unauthorized access is gained to their system, substantial losses could occur in the form of stolen, lost or corrupted: (i) data or payment information; (ii) financial information; (ii) software, contact lists or other databases; (iv) proprietary information or trade secrets or (v) other items.

Although Castlelake has implemented various measures to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, Castlelake and/or the Accounts it manages or services may have to incur significant expenses to repair or replace them and seek to remedy the effects of such issues. The failure of these systems and/or business continuity or disaster recovery plans for any reason could cause significant operational interruption and result in a failure to maintain the security, confidentiality, integrity or availability of data and systems, including sensitive or proprietary information and/or personal information relating to investors (and the beneficial owners of investors). Such a failure could harm the reputations of Castlelake and/or the Funds’ and subject any such entities and their respective affiliates to legal claims, regulatory penalties or otherwise affect their business and financial performance. In addition, the insurance coverage of Castlelake or the Funds may be insufficient to compensate any such entities and its respective affiliates or counterparties for incurred liabilities. Castlelake’s, the Funds’, investors’ and portfolio investments’ information and technology systems could be vulnerable to actual or perceived damage or interruption from computer viruses, infiltration by unauthorized persons and security breaches, and other disruptive behavior including denial-of-service attacks. Such activities could also create liabilities in respect of Castlelake and/or its portfolio investments to third parties. Furthermore, Castlelake and its portfolio investments could be vulnerable to actual or perceived usage errors by their respective professionals, network failures, computer and telecommunication failures, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes, which may result in potential loss to the Funds, including, if applicable, indemnification obligations benefitting Castlelake. Data Privacy and Protection. Laws and regulations related to privacy, data protection and information security could increase costs for Castlelake and the Accounts, and a failure to comply could result in fines, sanctions or other penalties, which could materially and adversely affect the results of operations of the investments of the Accounts. Castlelake is subject to laws and regulations related to privacy, data protection and information security in the jurisdictions in which it does business. As privacy, data protection and information security laws are implemented, interpreted and applied, compliance costs to the Accounts may increase, particularly in the context of ensuring that adequate data protection and data transfer mechanisms are in place. The General Data Protection Regulation (EU 2016/679) (the “GDPR”) replaced the preexisting EU data protection legislation and seeks to harmonize national data protection laws and enforcement across the EU. The GDPR notably has a greater extra-territorial reach than the preexisting legislation and has a significant impact on data controllers and data processors: (i) with an establishment in the EU; (ii) that offer goods or services to EU data subjects; or (iii) that monitor EU data subjects’ behavior within the EU. The UK Data Protection Act 2018 (DPA) and the UK General Data Protection Regulation (UK GDPR) address personal data privacy law across the UK. The DPA and UK GDPR govern the processing, such as the use or holding of personal data. On 28 June 2021, the EU approved an adequacy decision for the UK GDPR. This means data can continue to flow as it did before, in the majority of circumstances. The decision is expected to last until 27 June 2025. The GDPR has been kept in UK law as the UK GDPR.

Additionally, as a result of recent case law and regulatory guidance in Europe, organizations with a nexus to the EU and/or the UK will likely need to dedicate compliance costs and resources to implement appropriate legitimizing mechanisms and safeguards (e.g., standard contractual clauses, pseudonymization techniques, encryption, impact assessments) in respect of transfers of personal data from the European Economic Area and the UK to third countries that have not been deemed by the European Commission or the Government of the UK (as applicable) to provide adequate protection for personal data. Other jurisdictions, including U.S. states, have either passed, proposed or are considering similar Privacy Laws to the CCPA, EU GDPR and UK GDPR (such as the Virginia Consumer Data Protection Act passed March 2, 2021, and the Colorado Privacy Act passed on July 8, 2021, both of which became effective in 2023), which could impose similarly significant costs, potential liabilities and operational and legal obligations. Such Privacy Laws and regulations are expected to vary from jurisdiction to jurisdiction, thus increasing costs, operational and legal burdens and the potential for significant liability on regulated entities. Compliance with current and future privacy, data protection and information security laws could significantly impact current and planned privacy and information security related practices, the collection, use, sharing, retention and safeguarding of personal data and some of Castlelake’s current and planned business activities. A failure to comply with such laws could result in fines, sanctions or other penalties, which could materially and adversely affect results of operations and overall business, as well as have an impact on reputation. Economic Sanctions Laws. Economic and trade sanctions laws in the United States and other jurisdictions, including the EU and the United Kingdom, could prohibit Castlelake, the General Partner, the Castlelake employees and the Funds from transacting with or in certain countries and with certain individuals and companies. In the United States, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State administer and enforce laws, Executive Orders and regulations establishing U.S. economic and trade sanctions. Such sanctions prohibit, among other things, transactions with, and the provision of services to, certain non-U.S. countries, territories, entities and individuals. These entities and individuals include specially designated nationals, specially designated narcotics traffickers and other parties subject to OFAC sanctions and embargo programs. The lists of OFAC prohibited countries, territories, persons and entities, including the List of Specially Designated Nationals and Blocked Persons, as such list may be amended from time to time, can be found on the OFAC website at https://www.treasury.gov/resource-center/sanctions/Pages/default.aspx. In addition, certain programs administered by OFAC prohibit dealing with individuals or entities in certain countries regardless of whether such individuals or entities appear on the lists maintained by OFAC. These types of sanctions could significantly restrict the Fund’s investment activities in certain countries and, in particular, certain emerging market countries. At the same time, Castlelake could be obligated to comply with certain anti-boycott laws and regulations, which prevent Castlelake and the Funds from engaging in certain discriminatory practices that could be allowed or required in certain jurisdictions. Castlelake’s failure to discriminate in this manner could make it more difficult for the Funds to pursue certain investments and engage in certain business activities.

Anti-Money Laundering Requirements. In response to increased regulatory concerns with respect to the sources of funds used in investments and other activities, including but not limited to the Uniting and Strengthening America by Providing Appropriate Tools Required to Interrupt and Obstruct Terrorism Act of 2001, the General Partners reserve the right to request investors to provide documentation verifying, among other things, such investors’ identity, the identity of their beneficial owners/controllers (where applicable) and source of funds used to purchase the Units and require the investors to make various representations and warranties to the General Partner and the Funds in this regard. The relevant General Partner is permitted to decline to accept a subscription on the basis of the information that is provided by a prospective investor in a Fund or if such information is not provided. Requests for documentation and additional information may be made at any time by third parties. Castlelake or its affiliates may be required to provide this information or report the failure to comply with such requests, to appropriate governmental authorities, in certain circumstances without notifying the investors in a Fund that the information has been provided. Castlelake takes such steps as it determines are necessary to comply with applicable law, regulations, orders, directives or special measures. Reliance on Corporate Management and Financial Reporting. In many cases, Castlelake will rely on the financial information made available by the borrowers or issuers in which the Fund invests. Castlelake will also rely on the financial information made available by the Fund’s asset managers and other services providers engaged to monitor, value and service the Fund’s portfolio investments. Castlelake generally will not have the ability to independently verify such financial information, and generally will be dependent upon the integrity of both the management of these borrowers, issuers, asset managers and other Service Providers and the financial reporting process in general. Material losses can occur as a result of corporate mismanagement, fraud and accounting irregularities. Financial Fraud. Instances of fraud and other deceptive practices committed by senior management of certain companies in which the Fund invests may undermine Castlelake’s due diligence efforts with respect to such companies. If such fraud occurs, it may negatively affect the valuation of the Fund’s investments. In addition, when discovered, financial fraud may contribute to overall market volatility which can negatively impact the Fund’s investment program. Counterparty and Settlement Risk. The Fund may affect a portion of its transactions in “over-the-counter” or “interdealer” markets or through private transactions. The participants in such markets and the counterparties in such private transactions are typically not subject to credit evaluation and regulatory oversight as are members of “exchange-based” markets. This may expose the Fund to the risk that a counterparty will not settle a transaction because of a credit or liquidity problem, thus causing the Fund to suffer a loss. Such “counterparty risk” is accentuated for contracts with longer maturities where events may intervene to prevent settlement, or where the Fund has concentrated its transactions with a single or small group of counterparties. In addition, there may be practical, or time problems associated with enforcing the Fund’s rights to its assets in the case of an insolvency of any such party. Many non-U.S. countries have different clearance and settlement procedures from developed countries. There may be no central clearing mechanism of settling trades and no central depository or custodian for the safekeeping of securities. The registration, record-keeping and transfer of instruments may be carried out manually, which may cause delays in the recording of

ownership. Increased settlement risk may increase counter-party and other risk. Certain markets have experienced periods when settlement dates are extended, and during the interim, the market value of an instrument may change. Moreover, certain markets have experienced periods when settlements did not keep pace with the volume of transactions resulting in settlement difficulties. Because of the lack of standardized settlement procedures, settlement risk is more prominent. Prime Broker and Custody. The Fund will rank as an unsecured creditor to its prime brokers in relation to assets that a prime broker borrows, lends or otherwise uses and, in the event of the insolvency of a prime broker, the Fund might not be able to recover equivalent assets in full. The recovery process may take a long time during which the Fund may not have any access to the assets held by such insolvent prime broker or lending counterparty, and if such assets represent a significant portion of the Fund’s portfolio, the Fund may be forced to suspend its operations and calculation of net asset value. In addition, if applicable law permits, cash or assets that a prime broker holds or receives on the Fund’s behalf may not be treated by a prime broker as “client assets,” may not be segregated from the prime broker’s own assets and may be used by a prime broker in the course of its investment business. In such event, the Fund will rank as one of a prime broker’s unsecured creditors. The Fund’s custodian may not be responsible for cash or assets that are held by sub-custodians in certain non-U.S. jurisdictions, nor for any losses suffered by the Fund as a result of the bankruptcy or insolvency of any such sub-custodian. Custody services in certain non-U.S. jurisdictions remain undeveloped and accordingly there is a transaction and custody risk of dealing in certain non-U.S. jurisdictions. Given the undeveloped state of regulations on custodial activities and bankruptcy in certain non-U.S. jurisdictions, the ability of the Fund to recover assets held by a subcustodian in the event of the sub-custodian’s bankruptcy would be in doubt. Market Conditions. Investments rely upon local market conditions, and in part, upon the continuation of existing market conditions (including, for example, supply and demand characteristics) or, in some circumstances, upon the assumption or projection of more favorable market conditions existing at an expected exit. No assurance can be given that Fund investments can be acquired or disposed of at favorable prices or that the market for such assets will either remain stable or, as applicable, recover or improve, since this will depend upon events and factors outside the control of Castlelake. This may result in loss to the Fund or poor investment returns and/or longer hold periods, including beyond the end of the term of a Fund. FCPA Considerations. Castlelake is subject to certain laws including with the U.S. Foreign Corrupt Practices Act (“FCPA”) and other anti-corruption, anti-bribery and anti-boycott laws and regulations, both under U.S. and non-U.S. law. The Funds may be adversely affected because of their intention not to participate in transactions that violate such laws or regulations. Such laws and regulations will make it difficult in certain circumstances for the Funds to act successfully on investment opportunities and for investments to obtain or retain business. Castlelake has developed and implemented policies and procedures designed for compliance with the FCPA and other applicable anti-bribery laws, but such policies and procedures may not be effective in all instances to prevent violations. In addition, in circumstances under which the Funds do not control an investment, activities that could result in violations of the FCPA or other applicable laws may occur. Any determination that Castlelake has violated the FCPA or other applicable anticorruption, anti-bribery or anti-boycott laws could subject Castlelake and/or the Funds to, among other things, civil and criminal penalties and fines, profit disgorgement, injunctions, litigation and

a general loss of investor confidence, any one of which could adversely affect the business prospects of Castlelake, as well as the Funds’ ability to achieve their investment objectives and/or conduct their operations and which could result in loss of capital. Regulations Relating to Climate Change, Noise Restrictions and Greenhouse Gas Emissions. Regulations relating to climate change, noise restrictions and greenhouse gas emissions may have a negative effect on the airline industry. Governmental regulations regarding aircraft and engine noise and emissions levels apply based on where the relevant aircraft is registered and operated. Even if a jurisdiction does not require any phase-out of aircraft that meet the older standards applicable to engines manufactured or certified prior to the effective date of the new regulations, there is no guarantee that there will not be any impositions of operating limitations on aircraft that is not consistent with these new standards set in the future. In addition, concerns over global warming could result in more stringent limitations on the operation of aircraft powered by older, noncompliant engines, as well as newer engines. In addition, noise, emission, and aircraft age regulations could limit the economic life of aircraft, reduce their value, limit the Funds’ ability to lease or sell the non-compliant aircraft or, if engine modifications are necessary, require the Funds to make significant additional investments in the aircraft to make them compliant. Compliance with current or future regulations, taxes or duties imposed to deal with environmental concerns could cause lessees to incur higher costs and to generate lower net revenues, resulting in an adverse impact on their financial conditions. Consequently, such compliance may affect lessees’ ability to make rental and other lease payments and reduce the value the Funds receive for the aircraft upon any disposition, which could negatively affect the Funds’ ability to make distributions to investors. To the extent applicable, if an Account invests in other assets or industries impacted by climate change, noise restrictions and greenhouse gas emissions related regulations, then such investments may be similarly impacted as noted above. Environmental, Social and Governance (“ESG”). Except as otherwise may be provided in the Offering Documents, Castlelake seeks to integrate certain material ESG factors into the Funds’ investment process in accordance with the ESG policy consistent with and subject to Castlelake’s fiduciary duty and any applicable legal, regulatory or contractual requirements. The process of electing and evaluating material ESG factors is subjective by nature, and Castlelake expect to be subject to competing demands from different investors and stakeholder groups with divergent views on ESG (including the role of ESG factors in the investment process). There is no guarantee that the criteria utilized by Castlelake or a third-party advisor, or any judgment exercised by Castlelake or a third-party advisor, will reflect the views, internal policies or preferred practices of any particular investor or other asset manager or reflect market trends. Although Castlelake views the integration of ESG factors to be an opportunity to potentially enhance or protect the performance of its investments over the long-term, Castlelake cannot guarantee that its ESG program will positively impact the performance of any individual investment or the Funds. The materiality of ESG factors depends on many factors, including the relevant industry, location, asset class, and investment strategy. ESG factors, issues, and considerations do not apply in every instance and will vary by fund and investment. In addition, in evaluating an investment, Castlelake frequently depends upon information and data provided by a number of sources,

including the relevant investments and/or various reporting sources which could be incomplete or inaccurate, and which could cause Castlelake to incorrectly identify, prioritize, assess or analyze an investment’s ESG practices and/or related risks and opportunities. Castlelake does not independently verify all ESG information reported by investments or third parties. Further, the ESG Policy, practices and procedures are expected to change over time. ESG integration and responsible investing practices as a whole are evolving rapidly and there are different principles, frameworks, methodologies, and tracking tools being implemented by asset managers. Castlelake’s adoption and adherence to various such principles, frameworks, methodologies and tools is expected to vary over time. There is also growing regulatory interest across jurisdictions in improving transparency regarding how asset managers identify and manage financially material ESG risks and adverse impacts, as well as how they define and measure ESG performance. Additionally, Castlelake and the Funds and their investments could become subject to disclosure laws and regulations related to a range of sustainability matters, or requiring due diligence processes and internal compliance systems in relation to human rights and environmental matters. At the same time, “anti-ESG” sentiment has gained momentum across the U.S., with several states and Congress having proposed or enacted “anti-ESG” policies, legislation, or initiatives or issued related legal opinions. This evolving landscape results in management burdens and costs and could subject Castlelake to enforcement or other legal or reputational risks. Castlelake cannot guarantee that its current approach to ESG, including its ESG Policy, will meet future regulatory requirements or align with market trends. Risks Associated with Publicly Traded Securities. The Funds are permitted to invest a portion of its total assets in publicly traded securities. Such investments could be subject the Fund to risks that differ in type or degree from those involved with privately held investments. Such risks include greater volatility in the valuation of such companies, increased obligations to disclose information regarding such companies, limitations on the ability of the Fund to dispose of such securities and debt at certain times, increased likelihood of shareholder litigation and insider trading allegations against such companies’ executives and board members and increased costs associated with each of the aforementioned risks. Moreover, the Fund’s investments in securities of publicly traded companies are expected to be sensitive to movements in the stock market and trends in the overall economy and the ability of these companies to refinance debt securities could depend on their ability to sell new securities in the public high yield debt market or otherwise. U.S. Presidential Election. Presidential administrations generally seek to enact changes to numerous areas of law and regulations currently in effect. Any such changes, whether enacted by the current administration or a future administration could materially impact the Accounts and their investments. These include changes to trade agreements, immigration policy, import and export regulations, tariffs and customs duties, energy regulations, income tax regulations and the federal tax code, public company reporting requirements, and antitrust enforcement. Changes in federal policy, including tax policies, and at regulatory agencies occur over time through policy and personnel changes following elections, which lead to changes involving the level of oversight and focus on the financial services industry or the tax rates paid by corporate entities.

The nature, timing and economic effects of potential changes to the current legal and regulatory framework affecting financial institutions remain highly uncertain, including the impact of the increase in use and amount of trade tariffs. None of Castlelake or its Accounts or their respective affiliates can predict the ultimate impact of the foregoing on an Account, its business and investments, or the private equity industry generally, and any prolonged uncertainty could have an adverse impact on such Account and its investment objectives. Future changes may adversely affect an Account’s operating environment and therefore the Account’s business, operating costs, financial condition and results of operations. Further, an extended federal government shutdown resulting from failing to pass budget appropriations, adopt continuing funding resolutions, or raise the debt ceiling, and other budgetary decisions limiting or delaying deferral government spending, may negatively impact U.S. or global economic conditions, including corporate and consumer spending, and liquidity of capital markets. In addition, any changes in U.S. social, political, regulatory, and economic conditions or in laws and policies governing the financial services industry, foreign trade, manufacturing, outsourcing, development and investment in the territories and countries or types of investments in which an Account may invest, and any negative sentiments towards the United States as a result of such changes, could adversely affect the performance of the Accounts’ investments. Moreover, media (including social media) has the potential to influence public sentiment and escalate tensions both within the U.S. and in international relations, which could cause social unrest and could negatively impact stock markets and economics around the globe and the Funds’ investments. Castlelake also cannot predict how other countries will respond to the current and future U.S. presidential administrations’ actions. For example, Castlelake is unable to predict whether legislation or regulations that would have adverse impacts on an Account or its investments may be passed in other jurisdictions in response or related to any measures that were imposed by the previous U.S. presidential administration or that may be imposed by the current and future U.S. presidential administration, including the imposition of tariffs on U.S. goods imported into such jurisdictions, increased inspections on U.S. companies, delays on approvals for mergers and acquisitions involving U.S. companies, preferential treatment of non-U.S. companies, media campaigns against U.S. companies and/or goods, and delays on license approvals in such jurisdictions. The outcome presidential and congressional elections and changes in the control of the U.S. federal legislative and executive branches during an Account’s term could result in material changes in laws, regulations and policies affecting the private equity industry, which could negatively impact the performance of such Account. The likelihood of occurrence and the effect of any such change is highly uncertain and could have an adverse impact on Castlelake’s Accounts. International Conflicts and Geopolitical Events. Wars and other international conflicts, such as the Israeli- Palestinian conflicts, the ongoing military conflict between Russia and Ukraine and the ongoing U.S.-Iran hostilities and Iran’s retaliatory actions throughout the Middle East, have caused disruption to global financial systems, trade and transport, among other things. In response, multiple other countries have, and may in the future, put in or expand place sanctions and other severe restrictions or prohibitions on certain of the countries involved, as well as related individuals and businesses.

These conflicts, as well as heightened tensions in other regions, have also contributed to increased geopolitical uncertainty and volatility in global financial markets. The situation remains highly fluid and volatile, with significant uncertainty as to how events will unfold. Such developments have affected, and may continue to affect, energy and commodity prices, international shipping routes, supply chains, insurance markets and cross-border capital flows. Escalation, expansion or spillover of existing conflicts, or the outbreak of new conflicts between regional or global powers or their aligned groups, could materially disrupt economic activity, increase market volatility, reduce investor confidence and adversely affect the availability or cost of financing. The duration, scope and potential consequences of such hostilities are inherently uncertain and may change rapidly, and any such developments could have a material adverse effect on Castlelake’s investments, operations, and performance. The ultimate impact of these conflicts (and other geopolitical events, including national referenda, elections, interest rates, political movements, humanitarian crises, national and international policy changes, actual or perceived trade wars, import or export controls, tariffs, executive orders, laws, legal systems and regulatory regimes) and their effect on global economic and commercial activity and conditions, and on the operations, financial condition and performance of Castlelake’s Accounts or any particular industry, business or investee country and the duration and severity of those effects, is impossible to predict. These matters may have a significant adverse impact and result in significant losses to an Account. This impact may include reductions in revenue and growth, unexpected operational losses and liabilities, supply chain disruptions and reductions in the availability of capital. It may also limit the ability of an Account to source, diligence and execute new investments and to manage, finance and exit investments in the future. Developing and further governmental actions (military or otherwise) may cause additional disruption and constrain or alter existing financial, legal and regulatory frameworks and systems in ways that are adverse to the investment strategy which an Account intends to pursue, all of which could adversely affect such Account’s ability to fulfill its investment objectives. Banking System Volatility. The Accounts are subject to the risk that one of the banks, brokers, hedging counterparties, lenders or other custodians (each, a “Financial Institution”) of some or all of a Fund’s (or any portfolio company’s) assets fails to timely perform its obligations or experiences insolvency, closure, receivership or other financial distress or difficulty (each, a “Distress Event”). Distress Events can be caused by factors including eroding market sentiment, significant withdrawals, fraud, malfeasance, poor performance or accounting irregularities. If a Financial Institution experiences a Distress Event, the General Partners, the Funds or one of their portfolio companies may not be able to access deposits, borrowing facilities or other services, either permanently or for an extended period of time. Although assets held by regulated Financial Institutions in the United States frequently are insured up to stated balance amounts by organizations such as the Federal Deposit Insurance Corporation, in the case of banks, and the Securities Investor Protection Corporation, in the case of certain broker-dealers, amounts in excess of the relevant insurance are subject to risk of total loss, and any non-U.S. Financial Institutions that are not subject to similar regimes pose increased risk of loss. While in recent years governmental intervention has often resulted in additional protections for depositors and counterparties during Distress Events, there can be no assurance that such intervention will occur

in a future Distress Event or that any such intervention undertaken will be successful or avoid the risks of loss, substantial delays or negative impact on banking or brokerage conditions or markets. Any Distress Event has a potentially adverse effect on the ability of Castlelake to manage its Accounts and their investments, and on the ability of Castlelake, the Accounts and any portfolio company to maintain operations, which in each case could result in significant losses and in unconsummated investment acquisitions and dispositions. Such losses could include: a loss of funds; an obligation to pay fees and expenses in the event an Account is not able to close a transaction (whether due to the inability to draw capital on a credit line provided by a Financial Institution experiencing a Distress Event, the inability of an Account to access capital contributions or otherwise); the inability of an Account to acquire or dispose of investments, or acquire or dispose of such investments at prices that the relevant General Partner believes reflect the fair value of such investments; and the inability of portfolio companies to make payroll, fulfill obligations or maintain operations. If a Distress Event leads to a loss of access to a Financial Institution’s services, it is also possible that an Account or a portfolio company will incur additional expenses or delays in putting in place alternative arrangements or that such alternative arrangements will be less favorable than those formerly in place (with respect to economic terms, service levels, access to capital, or otherwise). Although Castlelake expects to exercise contractual remedies under agreements with Financial Institutions in the event of a Distress Event, there can be no assurance that such remedies will be successful or avoid losses or delays. The Accounts and their investments are subject to similar risks if a Financial Institution utilized by investors in an Account or by Service Providers or other counterparties of an Account or its investment becomes subject to a Distress Event, which could have a material adverse effect on an Account. Many Financial Institutions require, as a condition to using their services (including lending services), that Castlelake and/or the Accounts maintain all or a set amount or percentage of their respective accounts or assets with the Financial Institution, which heightens the risks associated with a Distress Event with respect to such Financial Institutions. Although Castlelake seeks to do business with Financial Institutions that it believes are creditworthy and capable of fulfilling their respective obligations to the Accounts, Castlelake is under no obligation to use a minimum number of Financial Institutions with respect to any Account or to maintain account balances at or below the relevant insured amounts. Foreign Bank Accounts. The Accounts, as a result of Side Letters with certain investors, are subject to limitations on their ability to establish bank accounts in certain jurisdictions outside of the U.S. In the event that an Account is unable to establish a bank account in a jurisdiction in which a prospective investment is located, the Account may have difficulty completing otherwise profitable investments, or may have to utilize less efficient structures in order to complete such investments. Deterioration of Credit Markets May Affect Ability to Finance and Consummate Investments. General fluctuations in interest rates and the market prices of securities and other assets may adversely affect the value of a Fund’s investments. Instability and volatility in interest rates and the securities markets may also increase the risks inherent in a Fund’s investments. A deterioration of the global credit markets, any possible future failures of financial services institutions or a significant rise in market perception of counterparty default risk will likely significantly reduce investor demand and liquidity for investment-grade, high-yield and senior bank debt, which in turn is likely to lead some banks and other lenders to be unwilling or

significantly less willing to finance new investments or to only offer financing for investments on less favorable terms than had been prevailing in the past. A Fund’s ability to generate attractive investment returns may be adversely affected to the extent the Fund is unable to obtain favorable financing terms for its investments. In the event a Fund is unable to obtain debt financing for potential acquisitions or can only obtain debt at an increased interest rate or on unfavorable terms, the Fund may have difficulty completing otherwise profitable acquisitions or may generate profits that are lower than would otherwise be the case, either of which could lead to a decrease in the investment income earned. In addition, a deterioration of the credit markets may require a Fund to post margin or other collateral to support financing or its hedging positions. Economic, Social, Political and Market Conditions. Consumer, corporate and financial confidence may be adversely affected by current or future tensions around the world, fear of terrorist activity and/or military conflicts, localized or global financial crises or other sources of political, social or economic unrest. Such erosion of confidence may lead to or extend a localized or global economic downturn. A climate of uncertainty may reduce the availability of potential investment opportunities, and increases the difficulty of modeling market conditions, potentially reducing the accuracy of financial projections. In addition, limited availability of credit for consumers, homeowners and businesses, including credit used to acquire businesses, in an uncertain environment or economic downturn may have an adverse effect on the economy generally and on the ability of the Accounts to execute their respective strategies. This may slow the rate of future investments and transactions by the Accounts and result in longer holding periods for investments. Furthermore, such uncertainty or general economic downturn may have an adverse effect upon the investments of the Accounts. Similarly, legislative acts, rulemaking, adjudicatory or other activities of the United States Congress, the SEC, the Federal Reserve Board, the NYSE, FINRA or other governmental or quasi-governmental bodies, agencies and regulatory organizations may make investments less attractive. Impact of Potential Regulatory Developments. The financial services industry generally, and the activities of private investment funds and their managers, in particular, have been subject to intense regulatory oversight and enforcement actions, both in the U.S. and Europe. Such scrutiny may increase the exposure of the Accounts, Castlelake and their respective affiliates to potential liabilities and to legal, compliance and other related costs. Increased regulatory oversight may impose administrative burdens on Castlelake, including, without limitation, those arising from responding to examinations and investigations and implementing new policies and procedures. Such burdens may divert Castlelake’s time, attention and resources from investment activities. Government measures may also limit the products that private investment funds can offer, limit the ability to pursue opportunities in an efficient manner, require an increase in regulatory capital, affect the value of the assets that private investment funds hold, reduce revenues and generally adversely affect the business, financial condition and results of private investment funds, their managers, their counterparties and the companies in which they invest. The Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) was enacted in July 2010. The Dodd-Frank Act created a number of new regulatory, supervisory and advisory bodies and affects the regulation of virtually every aspect of United States financial markets. The Dodd-Frank Act also mandates the preparation of studies of a wide range of issues, which could lead to additional regulatory change. Both in the U.S. and in Europe, new legislation may be enacted into law or new interpretations, rulings or regulations could be

adopted, any of which could impact the Accounts, the General Partner, the Management Company and their affiliates and the limited partners, potentially with retroactive effect. While it is not possible to predict at this time whether any such change will benefit or adversely impact the Accounts, Castlelake or investors, there can be no assurance that any new developments (including enhanced scrutiny), whether in the U.S. or in Europe, will not have an adverse impact on any Account’s activities, including the ability of an Account to implement operating improvements or otherwise execute its investment strategy or achieve its investment objectives. The regulatory environment for private investment funds is evolving, and changes in the regulation of private investment funds may adversely affect the value of investments held by an Account and the ability of the Partnership to effectively employ its investment strategies. Increased scrutiny and potential legislation applicable to private investment funds and their sponsors may also impose significant administrative burdens on Castlelake and may divert time and attention from portfolio management activities. In addition to, and in particular in light of, the changing global regulatory climate, Castlelake or an Account may be required to register under certain foreign laws and regulations, and need to engage distributors or other agents in certain non-U.S. jurisdictions in order to market interests to potential investors. The effect of any future regulatory change(s) on the Accounts could be substantial and adverse. In addition, the securities and futures markets are subject to comprehensive statutes, regulations and margin requirements. The SEC, other regulators and self-regulatory organizations and exchanges are authorized to take extraordinary actions in the event of market emergencies. The regulation of derivatives transactions and funds that engage in such transactions is an evolving area of law and is subject to modification by government and judicial action. Additionally, the SEC has proposed, and is expected to continue to propose, rules that will impact the business of Castlelake and the Accounts. Such current and future rulemaking is expected to impact Castlelake and its affiliates, the Accounts and/or their investments and the Accounts have the potential to bear significant increased costs as a result of such rules. In response to renewed attention by governmental authorities on whistleblower rights and contractual language that could be interpreted to stifle such rights, Castlelake wishes to clarify the applicability of the confidentiality provisions in its Accounts’ partnership agreements and other governing documents in certain circumstances. Although such documents often include broad confidentiality-related provisions, Castlelake will not as a matter of policy interpret such provisions to: (i) prohibit any investor from reporting possible violations of applicable law or regulation to any governmental agency or entity, or making other disclosures that are protected under the whistleblower provisions of applicable law or regulation; or (ii) require any investor to provide notification that it has made such reports or disclosures. As private fund firms and other alternative asset managers become more influential participants in the U.S. and global financial markets and economy generally, the private fund industry has recently been subject to criticism by some politicians, regulators and market commentators. In Germany, for example, U.S. and U.K. private equity firms are perceived by some as being responsible for high levels of domestic unemployment. There have been similar concerns expressed in other European countries. Various federal, state and local agencies have been examining, and the SEC has enacted a rule restricting, the role of placement agents, finders and other similar private equity Service Providers in the context of investments by public pension plans

and other similar entities, including investigations and requests for information and limitations on making political contributions by certain persons associated with the sponsors of private funds. Furthermore, elements of organized labor and other representatives of labor unions have embarked on a campaign targeting private equity firms on a variety of matters of interest to organized labor, including with respect to affording favorable treatment or significant deference to organized labor and labor unions in dealings with portfolio companies. There can be no assurance that the foregoing will not have an adverse impact on Castlelake or any Account or otherwise impede any Account’s activities. Public Health Emergencies; COVID-19. Pandemics and other widespread public health emergencies, including outbreaks of infectious diseases such as SARS, H1N1/09 flu, avian flu, Ebola and COVID-19, have resulted in historic market disruptions, and future such emergencies have the potential to materially and adversely impact economic production and activity in ways that are impossible to predict, all of which may result in significant losses to the Funds. The ultimate impact of any such health emergency — and any resulting decline in economic and commercial activity — on global economic conditions, and on the operations, financial condition and performance of any particular industry or business, is impossible to predict, but could have a significant adverse impact and result in significant losses to the Funds. The extent of the impact on the Funds’ and their portfolio companies’ operational and financial performance will depend on many factors, all of which are highly uncertain and cannot be predicted, and this impact may include significant reductions in revenue and growth, unexpected operational losses and liabilities, impairments to credit quality and reductions in the availability of capital. These same factors may limit the ability of the Funds to source, diligence and execute new investments and to manage, finance and exit investments in the future, and governmental mitigation actions may constrain or alter existing financial, legal and regulatory frameworks in ways that are adverse to the investment strategy the Funds intend to pursue, all of which could adversely affect the Funds’ ability to fulfill their investment objectives. They may also impair the ability of portfolio companies or their counterparties to perform their respective obligations under debt instruments and other commercial agreements (including their ability to pay obligations as they become due), potentially leading to defaults with uncertain consequences. In addition, the operations of the Funds, their portfolio companies, the General Partners and Castlelake may be significantly impacted, or even temporarily or permanently halted, as a result of any such health emergencies, or any measures, restrictions, remote-working requirements and other factors related thereto, including its potential adverse impact on the health of any such entity’s personnel. These measures may also hinder such entities’ ability to conduct their affairs and activities as they normally would, including by impairing usual communication channels and methods, hampering the performance of administrative functions such as processing payments and invoices, and diminishing their ability to make accurate and timely projections of financial performance United Kingdom Exit from the EU. On March 29, 2017, the United Kingdom formally withdrew from the European Council on January 31, 2020 (“Brexit”). After this, the United Kingdom (“UK”) entered in a transition period during which the majority of the existing EU rules applied in the United Kingdom. Following the end of the transition period on December 31, 2020, the EU rules ceased to apply in the UK.

Although the terms of the UK’s future relationship with the EU were agreed in a trade and cooperation agreement, signed on December 30, 2020, the terms of the trade and cooperation agreement are silent on financial services and there is still uncertainty as to the extent to which UK businesses will have access to the EU single market, and the extent to which EU business have access to the UK market. There is also a risk of significant disruption to trade between the UK and the EU, particularly in the initial period following the end of the transitional period and the implementation of the new trade arrangements. Alternative arrangements and structures may allow for the provision of cross-border marketing and services between the EU and UK, but these are subject to legal uncertainty and the risk that further legislative and regulatory restrictions could be imposed in the future. As a result of the onshoring of EU legislation in the UK, UK firms are currently subject to many of the same rules and regulations as prior to Brexit. However, the UK Government has begun the process of revising certain portions of onshored EU legislation as part of UK financial services legislation and regulation, which could result in substantive changes to regulatory requirements in the UK. It remains to be seen to what extent the UK may elect to diverge from the current EUinfluenced regime over time, either by actively legislating to replace onshored EU rules or by passively not implementing or mirroring EU legislative changes. It is possible that the EU may respond to UK initiatives by restricting third-country access to EU markets. If the regulatory regimes for EU and UK financial services change or diverge further, this could have an adverse impact on any Fund and its investments, including the ability of a Fund to achieve its investment objectives in whole or in part (for example, owing to increased costs and complexity and/or new restrictions in relation to cross-border access between the EU and non-EU jurisdictions) The legal, political and economic uncertainty and disruption generally resulting from Brexit may adversely affect both EU- and UK-based businesses, including Castlelake and Fund portfolio companies, as applicable. Brexit has already led to disruptions in trade as businesses attempt to adapt cross-border procedures and rules applicable in the UK and in the EU to their activities, products, customers, and suppliers. Continuing uncertainty and the prospect of further disruption may also result in an economic slowdown and/or a deteriorating business environment in the UK and in one or more EU Member States. Alternative Investment Fund Managers Directive. The EU Alternative Investment Fund Managers Directive (the “AIFMD”), as implemented in each member state of the European Economic Area (“EEA”) and as implemented and retained by the United Kingdom following its departure from the EU, regulates the activities of certain private fund managers undertaking fund management activities or marketing fund interests to investors within the EEA, and the United Kingdom respectively. To the extent that a Fund is actively marketed to investors domiciled or having their registered office in the EEA or the United Kingdom: (i) the Fund and Castlelake will be subject to certain reporting, disclosure and other compliance obligations under the AIFMD, which will result in the Fund incurring additional costs and expenses; (ii) the Fund and Castlelake may become subject to additional regulatory or compliance obligations arising under national law in certain EEA jurisdictions or the United Kingdom, which would result in the Fund incurring additional costs and expenses or may otherwise affect the management and operation of the Fund; (iii) Castlelake will be required to make detailed information relating to the Fund and its investments

available to regulators and third parties; and (iv) the AIFMD will also restrict certain activities of the Fund and Castlelake in relation to EEA or United Kingdom portfolio companies, including, in some circumstances, the Fund’s ability to recapitalize, refinance or potentially restructure an EEA portfolio company within the first two years of ownership, which may in turn affect operations of the Fund generally. In addition, it is possible that some EEA jurisdictions will elect to restrict or prohibit the marketing of non-EEA funds to investors based in those jurisdictions, which may make it more difficult for a Fund to raise its targeted amount of investor capital commitments. EEA Risks. In addition to specific national concerns, the EEA is continuing to be subject to instability in the aftermath of a collective debt crisis. Ongoing concerns regarding the sovereign debt of various EEA countries, including the potential for investors to incur substantial writedowns, reductions in the face value of sovereign debt and/or sovereign defaults, as well as the possibility that additional countries may leave the EU or the EEA create risks that could materially and adversely affect a Fund’s investments. The consequences of any sovereign default would likely be severe and wide-reaching, including significant exchange rate volatility or even an abolition of the Euro. This could have a severe negative impact on the financial and other markets, not only within Europe but globally and could result in a Fund’s inability to successfully carry out its investment program, especially with respect to European investments. The EEA is also subject to severe geopolitical pressures in light of the ongoing refugee resettlement crisis. Investor confidence in other EU member states has been severely impacted, threatening capital markets throughout the EEA. Artificial Intelligence and Machine Learning. Recent technological advances in artificial intelligence and machine learning technologies (collectively, “AI Technologies”), as well as the rapid growth and widespread use thereof, have the potential to pose risks to Castlelake, the Funds and the portfolio companies. AI Technologies have the potential to result in significant and disruptive changes in companies, sectors or industries, including those in which the Funds invest, and any such changes could render Castlelake’s underwriting models obsolete or create new and unpredictable operational, legal and/or regulatory risks. To the extent competitors of Castlelake the Funds and the portfolio companies make more efficient or extensive use of AI Technologies, there is a possibility that such competitors will gain a competitive advantage. Many jurisdictions have passed or are considering laws and regulations concerning AI Technologies, which could adversely affect Castlelake, the Funds, the portfolio companies and their operations. Additionally, Castlelake, the Funds and the portfolio companies could be further exposed to the risks of AI Technologies if Service Providers or any counterparties, whether or not known to Castlelake, use AI Technologies in their business activities. Castlelake will not be able to control the use of AI Technologies in third-party products or services, including those provided by Castlelake’s and its affiliates’ Service Providers. Additionally, Castlelake and its personnel reserve the right to use AI Technologies in connection with Castlelake’s business activities, including to support Castlelake’s due diligence and investment activities. AI Technologies are generally highly reliant on the collecting and analysis of large amounts of data, and it is not possible or practicable to incorporate all relevant data into the model that AI Technologies use to operate. Certain data in AI Technologies potentially will contain a degree of inaccuracy and error and could otherwise be inadequate or flawed, which would be likely to degrade the effectiveness of such AI Technologies. Even where AI Technologies are utilizing accurate data, they may, nonetheless, output results that contain, in whole or in part, inaccurate information, which may be difficult or impossible to

identify, and it may be difficult or impossible to modify such AI Technologies to eliminate these occurrences. Additionally, the ongoing development, maintenance and operation of AI Technologies is expensive and complex, and may involve unforeseen difficulties including material performance problems and undetected defects or errors. Any such inaccuracies or errors could have adverse impacts on the operations and/or performance of Castlelake, the Funds and/or the portfolio companies. In addition, use of AI Technologies poses various risks related to confidentiality, privacy and cybersecurity. Castlelake personnel also could utilize AI Technologies in contravention of any policies, confidentiality agreements or applicable law. Any of such risks or misuse could have an adverse effect on Castlelake, the Funds and/or the portfolio companies. AI Technologies and their applications, including in the financial sector, continue to develop rapidly, and it is impossible to predict the future risks that have the potential to arise from such developments. Any of the foregoing factors could have a material and adverse effect on Castlelake, the Funds and the portfolio companies. CFIUS and National Security Clearance Considerations. Certain investments by a Fund that involve the acquisition of, or investment in, a U.S. business (including a U.S. subsidiary of a portfolio company domiciled outside of the United States) or U.S. assets could be subject to review and approval by the U.S. Committee on Foreign Investment in the United States (“CFIUS”) depending on, among other factors, the structure, beneficial ownership and control of interests in the Fund and the nature of the U.S. business. CFIUS reform legislation (the Foreign Investment Risk Review Modernization Act) and related regulations empower CFIUS to scrutinize more closely investments in U.S. “sensitive personal data,” “critical infrastructure” and “critical technology” companies, including investments involving non-U.S. limited partners or co-investors that may be deemed “non-passive.” Certain transactions involving non-U.S. persons and U.S. “critical technology” companies, as well as sovereign investments in “critical technology,” infrastructure or data businesses, can be subject to mandatory pre-closing notification requirements, and monetary penalties may attach to a party’s failure to file such a notification. In addition, non-U.S. countries are increasingly taking action to strengthen their own foreign investment clearance (“FIC”) regimes, and as a result, certain investments by a Fund could likewise be subject to review by non-U.S. FIC regimes if the investments are perceived to implicate national security policy priorities. CFIUS and other FIC regulatory practices are evolving rapidly, and CFIUS and other FIC regulators have substantial discretion in deciding how to interpret, apply and enforce the relevant regulations. Any review and approval of a Fund investment by CFIUS or another FIC regulator could have outsized impacts on transaction certainty, timing, feasibility and cost, among other things. In the event that CFIUS or another FIC regulator reviews one or more of the Fund’s proposed or existing investments, it may seek to impose limitations on or prohibit such investments, and there can be no assurances that the Fund will be able to proceed with, or maintain, such investments on terms acceptable to the Fund. Such limitations or restrictions could adversely affect a Fund’s performance with respect to such investments (if consummated) and thus the Fund’s performance as a whole. Failure to submit required CFIUS filings could result in significant financial penalties for each transaction party, as well as reputational damage and potential legal restrictions on future investments. In addition, CFIUS is actively pursuing transactions that were not notified to it and may ask questions regarding, or impose restrictions or mitigation on, transactions post-closing.

Certain Fund investors are expected to be non-U.S. investors, and in the aggregate, could comprise a substantial portion of the Fund’s commitments, which increases the risk that Fund investments could be subject to review by CFIUS. To the extent that restrictions are reasonably likely to be imposed on an investment by the Fund due to the non-U.S. status of a limited partner or group of limited partners or other related CFIUS or FIC considerations, the General Partner is permitted to restrict such limited partner’s or group’s ability to participate in any investment and further, if applicable, restrict such limited partner’s or group’s rights to participate in or vote on certain decisions of the relevant advisory committee with respect to such investment. However, there can be no assurance that any such restrictions will allow the Fund to maintain, or proceed with, any investment on terms acceptable to the Fund. Additionally, a Fund is permitted to invest in portfolio companies that have previously taken capital from, or may in the future take capital from, third-party investors that are considered “foreign persons” for CFIUS purposes. In certain cases, notifications to CFIUS in connections with such third-party investments may be mandatory, and failure to make a notification could result in the imposition of fines or penalties on the investor and/or the portfolio company. In the event that CFIUS reviews such investors’ investments in portfolio companies, CFIUS may impose limitations or restrictions on the investors or the companies, which could adversely impact such companies’ performance and thus the performance of the Fund as a whole. In addition, heightened scrutiny of foreign investment in companies by CFIUS and similar non-U.S. FIC regulators could potentially constrain the universe of suitable buyers for an investment, thereby making it more difficult for a Fund to recognize value from exits and/or making exit transactions more difficult. Outbound Investment Regulation. In August 2023, the President of the United States issued an executive order setting forth a framework to implement outbound investment controls regulating U.S. investment in certain countries and companies deemed to be adverse to U.S. national security and foreign policy interests. In October 2024, the U.S. Department of the Treasury issued a final rule to implement the executive order and establish an outbound investment security program (“OISP”), which became effective on January 2, 2025. OISP imposes notification requirements for, and certain prohibitions relating to, investments by “U.S. persons” as well as their “controlled foreign entities” into certain entities that have both a nexus to China and that involve semiconductors and microelectronics, quantum information technologies or artificial intelligence. On February 21, 2025, the President of the United States signed a National Security Presidential Memorandum entitled “America First Investment Policy,” which indicates that the OISP restrictions may be expanded to cover biotechnology, hypersonics, aerospace, advanced manufacturing and directed energy, among other sectors, and it is likely that the number of targeted sectors will expand over the life of a Fund. The OISP restrictions could limit the universe of prospective investments available to a Fund, making it more difficult to deploy capital and/or identify buyers for investments on exit. Any failure to comply with OISP could result in significant legal and monetary penalties and/or adverse reputational and other consequences. Limited Access to Information; Confidentiality. Limited partners’ rights to information regarding a Fund, the relevant General Partner or Castlelake generally will be specified, and in many cases strictly limited, by the Offering Documents. In particular, it is anticipated that the General Partner and its affiliates will obtain certain types of material information from or relating

to a Fund’s investments that will not be disclosed to limited partners because such disclosure is prohibited, including as a result of contractual, legal or similar obligations outside of Castlelake’s control. Decisions by Castlelake or its affiliates to withhold information may have adverse consequences for limited partners in a variety of circumstances. For example, a limited partner that seeks to transfer its interest in a Fund may have difficulty in determining an appropriate price for such interest. Decisions to withhold information may also make it difficult for a limited partner to monitor Castlelake and its performance. Additionally, it is anticipated that limited partners that designate representatives to participate on a Fund’s advisory committee generally will, by virtue of such participation, have more or earlier information about a Fund and its investments in certain circumstances than other limited partners. Limited partners generally will bear the expenses of responding to disclosure requests, including in connection with state public records, similar freedom of information and other laws, whether or not the relevant Fund succeeds in asserting confidentiality for requested documents and other materials, and Castlelake reserves the right to withhold certain information from investors subject to such laws for reasons relating to Castlelake’s public reputation, business strategy or other reasons. Notwithstanding the foregoing, or the provision of any Fund’s Offering Documents, Castlelake will not as a matter of policy interpret any Fund’s confidentiality or information rights provisions to: (i) prohibit any limited partner from reporting possible violations of applicable law or regulation to any governmental agency or entity, or making other disclosures that are protected under the whistleblower provisions of applicable law or regulation; or (ii) require any limited partner to provide notification that it has made such reports or disclosures. Investment Risks Broad Investment Mandate. A purchaser of interests must rely upon the ability of the Accounts and Castlelake to identify, structure and implement investments consistent with the Accounts overall investment objectives and policies at such times as they determine. Except as set forth in the Accounts’ Offering Documents, there are no material limitations on the instruments, markets or countries in which the Accounts may invest or the specific investment strategies that may be employed on behalf of the Accounts. The Accounts may make investments throughout the capital structure such as mezzanine securities, senior secured debt, bank debt, unsecured debt, convertible bonds and preferred and common stock and across asset classes such as real estate, public equity, structured equity, minority private equity, commodities and credit. The Fund may make equity, credit and/or debt investments that do not involve control or influence over the underlying entity in which the Fund invests. Additionally, the Fund will be permitted to invest (and may actually invest) in any number of companies and assets operating in a wide range of industries, geographies or activities. Castlelake may pursue additional investment strategies and may modify or depart from its initial investment strategy, investment process and investment techniques as it determines appropriate. Castlelake may pursue investments outside of the industries and sectors in which it has previously made investments or has internal operational experience. Aircraft and Aircraft Operating Leases. Certain of the Accounts acquire direct or indirect ownership interests in aircraft and related engines which are leased to airlines, leasing companies or other operators or owners, and in some circumstances are not currently leased. The aircraft leasing market is affected by various cyclical and other factors that are not within the control of Castlelake such as: (i) interest rates; (ii) the availability of credit; (iii) fuel costs and general

economic conditions affecting lessee operations; (iv) manufacturer production level; (v) passenger demand; (vi) retirement and obsolescence of aircraft models; (vii) manufacturers merging or exiting the industry or ceasing to produce aircraft types; (viii) re-introduction into service of aircraft previously in storage; (ix) governmental regulation; (x) air traffic control infrastructure constraints (xi) the particular maintenance and operating history of aircraft and engines; (xii) the number of operators using a type of aircraft; (xiii) import restrictions; and (xiv) existing supply of parked or grounded aircraft. The availability of commercial aircraft for lease or sale has periodically experienced cycles of oversupply and undersupply, producing sharp decreases and increases in aircraft values and lease rates. Aircraft leasing is subject to lessee credit risk, default and market related events or other occurrences that could increase or decrease the demand for certain models of aircraft and related engines. In addition to general industry factors that may affect aircraft values and lease rates, the value of specific aircraft will depend on a number of other factors that are not within the control of Castlelake, such as the particular maintenance and operating history of the aircraft, the number of operators using the type of aircraft and the supply of such type of aircraft, whether the aircraft is subject to a lease and any regulatory and legal requirements that must be satisfied before the aircraft can be sold. Values of aircraft may be adversely affected by changes in the competitive and financial position of the relevant commercial aircraft manufacturer, by the withdrawal of such manufacturer from that market or by unexpected manufacturing defects that may surface subsequently. Ultimately, the profitability of aviation assets will depend on the condition in which the aviation asset is returned to the owner or lessor (e.g., the Fund). The Fund may enter into lease agreements that specify re-delivery conditions with respect to major components including the airframe, engines, landing gear, and auxiliary power unit. Accordingly, the compliance of operators and airlines with re-delivery conditions will determine the value and marketability of the aircraft. If a lessee fails to deliver complete and accurate records of leased aviation assets upon redelivery of such aviation assets, the Fund may be unable to release such aviation assets to operators and airlines because airworthiness requirements could prohibit the use of aircraft containing such aviation assets that do not have complete documentation. In some cases, the lessee will pay a security deposit that is refundable upon the expiration of the lease; provided that all re-delivery conditions are met, and that the lessee has not defaulted under the lease. Also, certain lessees may be required to make periodic maintenance reserve payments to the lessor based on the number of hours or cycles the aircraft or engine has accrued. Subject to a lessee paying monthly maintenance reserves to the lessor, after maintenance is performed on the leased assets and the lessee has paid the maintenance performer for the maintenance performed, a lessee may request a maintenance payment from the lessor to cover part or all of the cost of scheduled maintenance. Upon the expiration of the lease, an amount equal to any remaining maintenance reserves are typically retained by the lessor. In any event, there is the risk that these reserves will not be sufficient to cover maintenance costs and expenses incurred by the Fund once the asset is returned by the lessee.

Aircraft Lease Receivables (“ALRs”). Fund investments in airline/aircraft assets may include ALRs. ALRs are asset-backed securities that are generally structured as pass-through trusts. The aircraft is sold to the trust which leases it to the airline lessee. Unlike receivables backed by loans or interest rates, however, ALRs may entail a higher risk because of the nature of the underlying assets, which are expensive to maintain and operate and are difficult to sell. In addition, aircraft are subject to many laws in different jurisdictions, and the repossession of aircraft from defaulting lessees may be difficult and costly. Enhanced Equipment Trust Certificates (“EETCs”). Although any entity may issue EETCs, to date, U.S. airlines are the primary issuers. An airline EETC is an obligation secured directly by aircraft or aircraft engines as collateral. EETCs tend to be less liquid than bonds. Other asset-backed securities may be collateralized by the fees earned by Service Providers. The value of asset-backed securities may be substantially dependent on the servicing of the underlying asset pools and therefore is subject to risks associated with the negligence of, or defalcation by, their servicers. In certain circumstances, the mishandling of related documentation also may affect the rights of the security holders in and to the underlying collateral. The insolvency of entities that generate receivables or that utilize the assets may result in added cost and delays in addition to losses associated with a decline in the value of the underlying asset. Pre-Delivery Payments (“PDPs”). The Fund may finance PDPs, which are progress payments made by aircraft purchasers to manufacturers while new aircraft are being built. Because PDP payments are often used by aircraft manufacturers as working capital for completion of the aircraft, financing PDPs pose the risk that the underlying aircraft is not ultimately manufactured, that a project is delayed or that the purchaser does not take delivery. Further, such transactions can give rise to certain conflicts of interest, as described in Item 10 of this brochure. Controls on Investment; Repatriation Limitation. In the course of sale of the aircraft of the Fund or a restructuring of the aircraft portfolio, it is typically necessary to transfer the aircraft or change the registration of aircraft or transfer substantial amounts of capital from one jurisdiction to another in the context of such events. In some jurisdictions, such transfer, or the transfer or repatriation of capital or the repossession of the aircraft may be or may become legally impaired or may be subject to approval by local authorities. Effects of Natural Disasters. Air travel can be disrupted, sometimes severely, by the occurrence of natural disasters and other natural phenomena. For example, the spread of volcanic ash in Europe in early 2010, the tsunami in Japan and flooding in Thailand in 2011 and the damage caused by Hurricanes Florence and Michael, primarily in the United States and Central America, in 2018 caused the closure of airports and flight cancellations throughout the affected areas. The airline industry incurred substantial losses from these disruptions and any such disruptions could negatively affect the Fund’s ability to make distributions to investors. Aircraft Mortgage Debt. The Funds may invest in various forms of aviation related debt, including ALRs, EETCs, aircraft asset-backed securities, direct or structured loans and private placements or bank loans secured by aircraft or other aviation assets (together referred to as “aircraft mortgage debt”). Investing in aircraft mortgage debt entails many of the same risks as investing in aircraft directly. However, there are several additional risks, including the complicated structures involved in aircraft mortgage debt and the fact that in general, unlike if the Funds were

to own an aircraft, the Fund generally will not have a controlling position with respect to the aircraft when it invests in aircraft mortgage debt. Aircraft mortgage debt tends to be less liquid than many other types of debts, such as bonds, and such debt is generally not actively traded on any exchange. Therefore, should the Funds seek to sell any investment in aircraft mortgage debt, the Funds may not be able to achieve, in a timely manner or at all, a price that represents what Castlelake believes is the value of the investment. Aviation Debt. Certain of the Funds’ investments may consist of providing financing to airlines, leasing companies and other industry participants, including through loans, securities and/or other instruments, or interests in pools of securities and/or other instruments that are subordinated or may be subordinated in right of payment and ranked junior to senior securities and/or instruments issued by, or loans made to, airlines. Such investments in a borrower may be at levels of the capital structure that reflect a greater possibility that adverse changes in the financial condition of the borrower or in general economic conditions (including, for example, a substantial period of rising interest rates or declining earnings in the aviation industry), or both, may impair the ability of the borrower to make payment of principal and interest. Some borrowers may be highly leveraged, and their relatively high debt-to-equity ratios create increased risks that their operations might not generate sufficient cash flow to service their debt obligations. Although subordinated debt is senior to common stock and other equity securities in the capital structure, it may be subordinated to large amounts of senior debt and is often unsecured. Furthermore, financings may be made to borrowers that are airlines or other similar participants in the aviation finance or leasing markets where the underlying collateral securing the debt is not an aviation asset. Although in such cases Castlelake would generally seek a parent guarantee or similar credit support from a participant in the aviation finance or leasing markets, there can be no assurance that such guarantee or similar credit support will be obtained. The ability of subordinated debt holders to influence a borrower’s affairs, especially during periods of financial distress or following an insolvency, is likely to be substantially less than that of senior creditors. For example, under the terms of typical subordination agreements, senior creditors are able to block the acceleration of the debt or other exercises by the subordinated creditors of their rights. Accordingly, the Funds may not be able to take the steps necessary to protect its investments in a timely manner, or at all. Further, the unsecured debt in which the Funds may invest may not be protected by financial covenants or limitations upon additional indebtedness, could have limited liquidity and may not be rated by a credit rating agency. Under certain circumstances, the Fund may be offered an opportunity to make an investment in an airline that is expected to lease or purchase aircraft from one or more of the other funds, or in an airline that has already leased or purchased, or concurrently will lease or purchase, aircraft from one or more of the other funds or has borrowed money from one or more of the other funds in the same or other parts of the capital structure. As a result, Castlelake, the Fund and/or the other funds may have conflicting interests, including in negotiating the terms of such financing and lease or purchase agreements. In negotiating the price of the financing, the rate of interest or stated dividend yield of such securities, the nature of the covenants and other terms and conditions of such securities, the other funds may have interests that conflict with those of the Fund. In that regard and otherwise, actions may be taken by the other funds and/or Castlelake that are adverse

to the Fund. Such conflicts may also exist in the negotiations of amendments or waivers or in a workout or bankruptcy. It is possible that in a bankruptcy proceeding, the Fund’s interests may be adversely affected by virtue of the other funds’ involvement. It may not be feasible for Castlelake to reconcile the conflicting interests of the Fund and the other funds in a way that protects the Fund’s interests. Furthermore, as further described in “Servicing and Other Fees,” “CLOs,” “Securitization Vehicles,” “Structuring CLOs,” and “Leveraged Nature of CLO Securities,” (i) the Fund may, alongside one or more other funds, gain exposure to underlying assets through originating loans, lending to, or acquiring debt and/or equity interests in, any platform, warehouse and/or securitization-like vehicle or facility, including by contributing, or committing to contribute, assets, investments and/or cash consideration to such facilities or vehicles in exchange for interests therein, and (ii) the Fund and other funds may indirectly participate in certain investments through one or more warehouse facilities and collateralized loan obligations (a “CLO”) (to the extent that a CLO is issued with respect to such investments). Aviation Mezzanine Debt. Certain of the Fund’s investments may consist of providing mezzanine financing to airlines, including through loans, securities and/or other instruments, or interests in pools of securities and/or other instruments that are subordinated or may be subordinated in right of payment and ranked junior to senior securities and/or instruments issued by, or loans made to, airlines. Mezzanine investments in an airline often reflect a greater possibility that adverse changes in the financial condition of the airline or in general economic conditions (including, for example, a substantial period of rising interest rates or declining earnings in the aviation industry), or both, may impair the ability of the airline to make payment of principal and interest. Some airlines may be highly leveraged, and their relatively high debt-to-equity ratios create increased risks that their operations might not generate sufficient cash flow to service their debt obligations. Although subordinated debt is senior to common stock and other equity securities in the capital structure, it may be subordinated to large amounts of senior debt and is often unsecured. The ability of subordinated debt holders (such as the Fund) to influence an airline’s affairs, especially during periods of financial distress or following an insolvency, is likely to be substantially less than that of senior creditors. For example, under terms of subordination agreements, senior creditors are typically able to block the acceleration of the mezzanine debt or other exercises by the subordinated creditors of their rights. Accordingly, the Fund may not be able to take the steps necessary to protect its investments in a timely manner or at all. Further, the unsecured debt in which the Fund may invest may not be protected by financial covenants or limitations upon additional indebtedness, could have limited liquidity and may not be rated by a credit rating agency. Under certain circumstances, the Fund may be offered an opportunity to make a mezzanine investment in an airline that is expected to lease or purchase aircraft from one or more of the other funds, or in an airline that has already leased or purchased, or concurrently will lease or purchase, aircraft from one or more of the other funds or has borrowed money from one or more of the other funds in the same or other parts of the capital structure. As a result, Castlelake, the Fund and/or the other funds may have conflicting interests including in negotiating the terms of such mezzanine and/or other financing and lease or purchase agreements. In negotiating the price of the mezzanine

and/or other financing, the rate of interest or stated dividend yield of such securities, the nature of the covenants and other terms and conditions of such securities, the other funds may have interests that conflict with those of the Fund. In that regard and otherwise, actions may be taken by the other funds and/or Castlelake that are adverse to the Fund. Such conflicts may also exist in the negotiations of amendments or waivers or in a workout or bankruptcy. It is possible that in a bankruptcy proceeding, the Fund’s interests may be adversely affected by virtue of the other funds’ involvement. It may not be feasible for Castlelake to reconcile the conflicting interests of the Fund and the other funds in a way that protects the Fund’s interests. Aviation Credit Risk. Lending and acquiring debt have significant credit risk with respect to the ability of the borrower to make interest and principal payments on the loan or security as they become due. Given that the Fund may consider opportunities to gain additional exposure to underlying aircraft assets through lending to or acquiring debt from or issued by leasing companies or airlines, in such cases, if the borrower fails to pay interest, the Fund’s income might be reduced. If the borrower fails to repay principal, the value of that investment and the value of the Fund might be reduced. The Fund’s interests in loans or in the debt of a leasing company or airline are subject to risks of default. The Fund may be exposed to losses resulting from default. In any reorganization or liquidation proceeding relating to a leasing company or airline in which the Fund has made loans to, the Fund may lose all or part of the amounts advanced to such leasing company or airline. The Fund cannot guarantee the adequacy of the protection of the Fund’s interests, including the validity or enforceability of the loan. Furthermore, the Fund cannot assure that other claims may not be asserted that might interfere with enforcement of the Fund’s rights. In the event of a default, the Fund or an affiliate of the Fund may assume direct ownership of the underlying assets of the leasing company or airline. The liquidation proceeds upon sale of such asset may not satisfy the entire outstanding balance of principal and interest on the loan, resulting in a loss to the Fund. Any costs or delays involved in a default, or a liquidation of the underlying asset will further reduce the proceeds and thus increase the loss. Lending and acquiring debt also have significant liquidity risks and market value risks since they are generally not publicly traded in organized exchange markets but are traded by banks and other institutional investors engaged in loan syndications. Because loans are privately syndicated and loan agreements are generally privately and heavily negotiated and customized and subject to offering restrictions, loans are not purchased or sold as easily as other investments. Due to their illiquid nature, the Fund may not be able to dispose of its interest in a loan to or in the debt of a leasing company or airline in a timely manner and/or at a fair price. The inability to dispose of a loan could result in losses to the Fund, including the loss of its entire investment. If the leasing company or airline is in default or its debt is highly leveraged, such debt may be less liquid than other debt. If the Fund voluntarily or involuntarily sold its interests in those types of debt instruments, it might not receive the full value it expected. In particular, these risks could arise from changes in the financial condition or prospects of the leasing companies or airlines whose borrowings underlie the Fund’s investments, changes in national or international economic or political conditions (including acts of war, terrorism or other calamity or crisis), adverse conditions in national or global financial or capital markets, or changes in laws or regulations affecting the aviation industry, fiscal policies or political conditions of countries in which investments are made.

Aviation Regulation. The aviation industry is highly regulated in the United States and internationally and subject to regulatory change. While the Funds intend to make investments that comply with relevant laws and regulations, certain aspects of the Funds’ operations may not have been subject to judicial or regulatory interpretation. An adverse review or determination by any one of such authorities, or an adverse change in the regulatory requirements, could have a material adverse effect on the Funds’ investments. Various regulators in the US and globally may introduce legislative proposals that would effect major changes in the aviation industry. The aviation industry is often subject to significant regulatory changes. It is not clear at this time what changes, if any, will occur and what effect any proposals would have on the aviation industry. International and EU Regulatory and Market Initiatives on Emissions from Aviation. Castlelake acknowledges the sustainability risks involved in investing in the aviation sector, including the regulatory obligations and financial burdens imposed by EU regulation surrounding carbon emissions specific to the aviation sector. These currently include Directive 2008/101/EC which sought to include aviation activities in the system for greenhouse gas emission allowance trading (“EU ETS”), which imposes both an annual ‘cap’ on emissions and an obligation on market participants to monitor, report and verify emissions in respect of flights within the EEA. Castlelake acknowledges these obligations and the impact such obligations may have on the performance of the fund when making investments in that sector, particularly in light of the rising price of carbon credits and offsets in recent years. Pursuant to the EU Green Deal, there is potential for increased EU regulation to be implemented impacting the aviation sector. Proposals currently include a revision to the Energy Taxation Directive (Directive 2003/96/EC), which proposes to end the tax exemption for aviation fuel, and the ReFuelEU Aviation Initiative, which could mandate the percentage of sustainable aviation fuel on a per flight basis. In addition, proposed changes to the EU ETS include a decrease in the free allocation of carbon allowances and an expansion of the scope of the EU ETS to be potentially applicable to flights into and from the EEA. Separately, the global market-based mechanism (GMBM) known as the Carbon Offsetting and Reduction Scheme for Internal Aviation aims to stabilize CO2 emissions in 2019 and 2020 levels by requiring airlines to offset the growth of emissions above 2020 levels by (i) monitoring emissions on all international routes and (ii) purchasing eligible emission units generated by projects that reduce emissions such as those for the generation of renewable energy. Castlelake continues to monitor the complex and developing international and European regulatory and market initiatives governing the management of emissions from aviation. Effect of Airworthiness Directives and Operating Restrictions. The maintenance and operation of aircraft and engines are strictly regulated in the United States by the FAA in the U.S. and similar governmental authorities in foreign jurisdictions. These rules and regulations govern such matters as certification, registration, inspection, operation and maintenance procedures, personnel certification and record keeping. Periodically, the FAA issues airworthiness directives requiring changes to aircraft or engine maintenance programs and procedures. Future regulatory changes may also increase the cost of operating and/or maintaining aircraft and engines, which may adversely affect their residual value and the profitability of the Fund’s investments, as can the

failure of a lessee to comply with the maintenance provisions as set forth in the lease. The cost of compliance with such requirements may be significant. Requirement for Certain Licenses and Approvals. Some lease or sale transactions may require that the Fund and/or the lessee obtain licenses, consents or approvals from governmental or other regulatory authorities with respect to the importing, exporting and deregistration of aircraft. Subsequent changes in applicable law or administrative practice may increase such requirements. In addition, a governmental consent, once given, might be withdrawn or expire without renewal. The Fund may have difficulty acquiring the licenses, consents or approvals needed in connection with aircraft leasing or sale. Any of these events could adversely affect the Fund’s ability to lease or sell aircraft and could negatively affect the Fund’s ability to make distributions to investors. Registration of Aircraft. Appropriate registration of aircraft is a material obligation of the lessee and/or the holder of title of an aircraft (as applicable, dependent on local regulations) and an indispensable precondition for operating the aircraft. If an aircraft were to be operated without valid registration, the lessee operator or, in some cases, the owner or lessor (such as the Fund) might be subject to penalties, which could constitute or result in a lien being placed on such aircraft. Lack of registration could also restrict the ability of the owner or lessee to operate the aircraft, negatively affect insurance premiums or cause the loss of insurance. The foregoing adverse effects could cause lessees to incur higher costs and to generate lower net revenues, resulting in an adverse impact on their financial conditions, affecting lessees’ ability to make rental and other lease payments to the Fund. Regulations Relating to Climate Change, Noise Restrictions, and Greenhouse Gas Emissions. Regulations relating to climate change, noise restrictions and greenhouse gas emissions may have a negative effect on the airline industry and, in turn, the Fund. Governmental regulations regarding aircraft and engine noise and emissions levels apply based on where the relevant aircraft is registered and operated. United States and certain other jurisdictions regulate emissions of certain greenhouse gases, such as nitrogen oxide, as well as noise levels which applies to engines manufactured or certified on or after a certain date. There is no guarantee that there will not be any impositions of operating limitations on any aircraft that is not consistent with new regulatory standards set in the future. In addition, concerns over climate change could result in more stringent limitations on the operation of aircraft. European countries generally have relatively strict environmental regulations that can restrict operational flexibility and decrease aircraft productivity. Such regulation could possibly distort the air transport market, leading to higher ticket prices and ultimately a reduction in demand for air travel. In addition, noise, emission and aircraft age regulations could limit the economic life of aircraft, reduce its value, limit the Fund’s ability to lease or sell the non-compliant aircraft or, if engine modifications are necessary, require the Fund to make significant additional investments in the aircraft to make it compliant. Compliance with current or future regulations, taxes or duties imposed to deal with environmental concerns could cause lessees to incur higher costs and to generate lower net revenues, resulting in an adverse impact on their financial conditions. Consequently, such compliance may affect lessees’ ability to make rental and other lease payments and reduce the value the Fund receives for the aircraft upon any disposition, which could negatively affect the Fund’s ability to make distributions to investors.

Effects of the Aviation Security Act. The U.S. Aviation and Transportation Security Act (the “Aviation Security Act”), among other things, subjects substantially all aspects of U.S. civil aviation security to federal oversight and mandates enhanced security measures, including: (i) improved flight deck security; (ii) deployment of federal air marshals on flights; (iii) improved security of airport perimeter access; (iv) airline crew security training; (v) augmented security screening of passengers, baggage, cargo, mail, employees and vendors; (vi) improved training and qualifications of security screening personnel; (vii) additional provision of passenger data to U.S. Customs and Border Protection; and (viii) more detailed background checks on passengers and airline and airport personnel. The implementation of the requirement that all checked baggage be screened by explosives detection systems has resulted, and may continue to result, in significant equipment acquisitions by the government and changes to baggage processing facilities and procedures. The changes mandated by the Aviation Security Act have increased costs for airlines providing service in the U.S. have resulted in delays and disruptions to air travel, which have adversely affected, and may to continue to adversely affect, the aviation industry in general. It is expected that the Aviation Security Act will continue to impose additional costs on the airlines and may adversely impact the performance of the Fund. Effect of War or Armed Hostilities and Terrorist Attacks. War or armed hostilities, or the fear of such events, could reasonably be expected to exacerbate many of the economic problems experienced by the airline industry. In addition, terrorist attacks and attempts have negatively affected the airline industry and fears about future terrorist attacks or other substantial events could continue to negatively affect the airline industry in a variety of ways, including, without limitation: (i) higher costs to the airlines due to the increased security measures and other compliance with new regulatory enactments; (ii) losses in passenger revenue due to terrorism concerns and the inconvenience of additional security measures; (iii) significantly higher costs of insurance coverage for future claims caused by acts of war, terrorism, sabotage, hijacking and other similar perils, and uncertainty as to the extent to which such insurance will continue to be available; and (iv) possible lost revenue stemming from aircraft grounded as a result of terrorists attacks, the economic slowdown, forced shutdowns due to government actions and airline reorganizations. Additional potential problems include increased security restrictions on air travel within the U.S. and elsewhere, increased airline costs for and restricted availability of aircraft insurance and fuel, enhanced security measures, a decline in passenger demand for air travel, increased difficulties in acquiring war risk and other insurance at reasonable costs, and additional lessee restructurings. Should these risks come to pass, there can be no guarantee that the government of the U.S. or any other country will take action to assist the aviation industry. General Airline Industry Risks. The airline business is dependent on several factors. For example, the airline industry can be highly impacted by conflicts and wars (including those discussed in “International Conflicts and Geopolitical Events” above) which can in turn have substantial impacts on investments made by the Funds. Additionally, the business depends on the price and availability of aircraft fuel. Continued periods of high fuel costs, significant disruptions in the supply of aircraft fuel or significant further increases in fuel costs could have a significant negative impact on air carriers’ operating results. Union disputes, employee strikes, increased employee costs, employee absences and other labor- related disruptions may adversely affect airlines’ operations. The travel industry may be materially adversely affected by the risk of terrorist attacks and continues to face on-going security concerns and cost burdens associated with security. Increases in insurance costs or reductions in insurance coverage may adversely impact airlines

operations and financial results. Changes in government regulation could increase airlines operating costs and limit their ability to conduct their business. The airline industry is intensely competitive. It is subject to risk of losses and adverse publicity stemming from any accident involving any of the aircraft and is subject to weather factors and seasonal variations in airline travel, which cause financial results to fluctuate. Any of these factors can affect the value of the Funds’ investments. Aircraft Accidents. An aircraft crash, or other serious safety incidents, could expose the Fund to significant liability and reduce the demand for certain of the Fund’s aircraft. In addition, airline operators and/or aviation authorities may ground aircraft due to safety concerns. As a result, the Fund may be forced to bear substantial losses stemming from an accident. For example, airline operators and aviation authorities in the United States, Europe, China, Canada and other countries previously suspended the use of Boeing’s 737 MAX 8 aircraft over concerns about its safety, after an Ethiopian Airlines flight of the same model crashed in March 2019 (shortly after another crash of the same model). The Boeing 737 MAX 9, which has nearly identical design features as the Boeing 737 MAX 8, was also grounded across the globe. Any crash or serious accident involving aircraft that the Fund is expected to acquire could adversely impact the Fund’s business, results of operations and financial condition or create an adverse public perception, which could result in air travelers being reluctant to fly on such aircraft. Accidents involving aircraft types which Castlelake is not expected to target, may also result in increased competition for the Fund’s target aircraft, which in turn may limit supply and increase costs for the Fund. Asset Backed Debt Vehicles. The Funds may structure partial exit transactions through establishing asset backed debt vehicles to which some or all certain types of assets will be transferred. The Funds are expected to be issued the most junior tranches of securities in such asset backed debt vehicles, which are typically treated as equity certificates for U.S. federal income tax purposes and are generally unrated or rated below investment grade. Such securities are subordinated to payments of interest and principal on higher-rated securities of the asset backed debt vehicle and will be directly affected by any losses or delays in payment on the related collateral. Interests in asset backed debt vehicles can be considered a levered investment in the underlying collateral of the vehicle because the amount of the investment is significantly below the principal value of the vehicle’s equity and below investment grade debt’s pro rata portion of the underlying collateral. However, an asset backed debt vehicle’s equity and below investment grade debt tranches, due to their subordinated nature, are the first and second tranche, respectively, to absorb trading losses and defaults in the underlying collateral. Therefore, while the levered nature of an asset backed debt vehicle’s equity and below investment grade debt tranches increases the cash flow that may be available for distribution, it also increases the exposure to trading losses and defaults, and accordingly, causes returns to be more volatile. Payments on asset backed debt vehicle equity and below investment grade debt tranches may be deferred or eliminated depending on the amount of cash flow generated by the collateral. Castlelake and/or its affiliates will act as collateral manager, servicer, facility manager or similar role with respect to any such vehicles. The fees payable to Castlelake and/or its affiliates with respect to any asset backed debt vehicles will generally be structured so that the Funds do not bear such amounts with respect to their ownership in such vehicles (including through credits

and/or offset of the management fees payable by the Fund to Castlelake by any such amounts), subject in all cases to the terms of the Offering Documents. Multiple Funds may be issued interests in the same asset backed debt vehicles and Funds may purchase interests in such vehicles or other asset backed debt vehicles in the secondary markets, with such interests being of the same or different classes held by other Funds. Restricted Nature of Investment Positions. Generally, there will be no readily available market for a significant portion of the Funds’ investments, and hence, most of the Funds’ investments will be difficult to value. The Funds also invest in some assets that are experiencing or are expected to experience severe financial difficulties which may never be overcome. Since the Funds are permitted to make a limited number of investments, and many of the Funds’ investments are expected to involve a high degree of risk, poor performance by a few of the investments can have a significant negative impact on the Funds’ performance. The Funds’ strategies are based, in part, upon the premise that investments will be available for purchase by the Funds at prices which Castlelake considers favorable. Further, the Funds’ strategies rely, in part, upon local market conditions, and in part, upon the continuation of existing market conditions (including, for example, supply and demand characteristics) or, in some circumstances, upon the assumption or predictions of more favorable market conditions existing at the expected exit. As a result, the Fund may not liquidate an investment at favorable values, or at all, prior to the end of the term of the Funds. No assurance can be given that Funds’ investments can be acquired or disposed of at favorable prices or that the market for such assets will either remain stable or, as applicable, recover or improve, since this will depend upon events and factors outside the control of Castlelake. Investments in Undervalued and Distressed Assets. The Funds often attempt to invest in undervalued and distressed assets, including financial assets such as mortgage servicing rights, transportation assets such as those in aviation, shipping, railroads and rail networks, consumer debt, residential and commercial real estate as well as assets in other industries. The identification of investment opportunities in such assets is a difficult task, and there is no assurance that such opportunities will be successfully recognized or acquired. While investments in undervalued or distressed assets offer the opportunity for above-average capital appreciation, these investments involve a high degree of financial risk and can result in significant losses. Returns generated from undervalued investments of Funds may not adequately compensate investors for the business and financial risks assumed. The Funds may incur substantial losses if the assets which Castlelake believes are undervalued are not in fact undervalued and may be forced to sell such assets at a substantial loss. Such assets may be required to be held for a substantial period of time before realizing their anticipated value. Once purchased, these assets will often require additional ongoing maintenance capital. During this period, a portion of capital of Funds would be committed to the assets purchased, thus possibly preventing the Funds from investing in other opportunities. There can be no assurances that workouts, reorganizations or exits with respect to any distressed or undervalued assets would be successful. Indebtedness may be incurred in connection with such asset acquisitions, which debt would typically be secured by the assets so acquired and typically nonrecourse to the Accounts. The industries in which the Funds invest may be subject to extensive rules and regulations limiting rights or otherwise impacting the risk profile. Castlelake in some instances enters into arrangements with industry specialized management, servicing teams or entities to acquire, manage and dispose of these assets, which typically include fixed payments and/or profit-sharing arrangements with such teams or entities. The failure on the part of Castlelake

to select the right management/advisory team for an investment and/or to establish a governance and compensation structure that provides for the appropriate balance of economic incentives to the team and oversight by Castlelake would have a material adverse effect on the investment in such asset class. The failure of Castlelake to provide or secure appropriate servicing of certain investments could also have a material adverse effect on the Fund. Lessee Defaults and Other Credit Problems. The ability of each lessee to perform its obligations under its lease will depend primarily on the lessee’s financial condition, which may be affected by factors beyond the Fund’s control, including competition, fare levels, air cargo rates, passenger and air cargo demand, operating costs (including the price and availability of jet fuel and labor costs), labor difficulties, economic conditions in the countries in which the lessee operates and governmental regulation of or affecting the air transportation business. Airlines with weaker capital structures, in general, are more likely than well- capitalized airlines to seek operating leases, and, at any point in time, a varying number of lessees may experience payment difficulties. In addition, many lessees are exposed to currency risk due to the fact that they earn revenues in their local currencies and certain of their liabilities and expenses are denominated in U.S. dollars, including lease payments to the Fund. As a result of their poor financial condition, a large portion of lessees over time may consistently be significantly in arrears in their rental payments or maintenance payments. The Fund can give no assurances that lessees will be able to perform their financial and other obligations under future lease agreements. A lessee may also experience periodic difficulties that are not financial in nature, which could impair its performance of its maintenance obligations under a lease agreement. These difficulties may include deferring the performance of scheduled aircraft maintenance. The Fund cannot assure that, in the event a lessee defaults under a lease, the security deposit paid, or the letter of credit provided by the lessee, if any, will be sufficient to cover the outstanding or unpaid obligations accrued under the applicable lease agreement or other lessee obligations such as navigational charges and landing and/or airport fees which may give rise to lien rights in favor of applicable creditors. If such amounts are insufficient, the Fund’s ability to make distributions to investors will be adversely impacted. Lessee Credit Risk. Castlelake will evaluate the credit risk associated with each of the prospective operators/lessees, and their respective ability to properly maintain the aircraft and comply with the lease. In addition to Castlelake’s independent assessment of the lessee’s credit standing using public information, data provided by the operator, financial institutions, industry periodicals, trade references, and/or regulatory authorities, Castlelake will utilize, when it deems appropriate and practicable, credit and rating agency reports and/or research reports published by investment banks to get a better understanding of the operator’s financial condition and viability. On the basis of such review, Castlelake will assess the credit rating of the operator and weigh that credit evaluation against the asset risk, the lease rate, and the lease structure, in determining whether the operator meets the Fund’s investment criteria. Nonetheless, many factors can dramatically and quickly impact an individual airline’s viability. These include fuel prices, pandemics, labor disruptions, air crashes, and new or intensified competition. Should a lessee file for a re-organization under bankruptcy statutes, there is the added risk that the lessor/owner may be at least temporarily prohibited from foreclosing on or repossessing its aircraft. Most developed countries, like the U.S. (which affords lessors and other secured parties certain protections and certain rights pursuant to Section 1110 of the Bankruptcy Code), have specific laws that determine how and when a secured party or a lessor in a bankruptcy can repossess an aircraft. Although the process is improving due to the approval of, and certain countries joining, the Cape Town

Convention on International Interests in Mobile Equipment and the Protocol to the Convention on International Interests in Mobile Equipment on Matters Specific to Aircraft Equipment, the process can be slow, expensive, and in some instances may result in lost revenue and thus negatively impact the proceeds that would otherwise be received by the Fund. Higher Costs Resulting from Lease or Consignment Default. Repossession of an aircraft after a lessee or consignee default may result in the Fund incurring costs in excess of those incurred with respect to an aircraft returned at the end of the lease or consignment. Those costs include legal and other expenses of court or governmental proceedings (particularly if the lessee or consignee is contesting the proceedings or is in bankruptcy to obtain possession and/or reregistration of the aircraft and flight and export permissions. Delays resulting from any of these proceedings would also increase the period of time during which the relevant aircraft is not generating revenue pursuant to a lease agreement. In addition, the Fund may incur substantial maintenance or repair costs (that a defaulting lessee has failed to pay) and may need to pay off liens, taxes and governmental charges in order to obtain unencumbered possession and to re-lease the aircraft effectively. The Fund may incur costs in connection with the physical repossession of the aircraft. Any of these costs or delays will adversely impact the returns of the Fund. The rights of the Fund upon a lessee default may be subject to limitations of applicable law, including the need to obtain a court order for repossession of aircraft and/or consents for deregistration or reexport of aircraft. When a defaulting lessee or consignee is in bankruptcy, protective administration, insolvency or similar proceedings, additional limitations may apply. Certain jurisdictions will give rights to the trustee in bankruptcy or a similar officer to assume or reject the lease or consignment or to assign it to a third-party, or will entitle the lessee or consignee, as the case may be, or another third-party to retain possession of the aircraft (without performing all or some of the obligations under the relevant lease or consignment, as the case may be). Accordingly, the Fund may be delayed in or prevented from, or may incur additional costs including legal costs, enforcing certain of the Fund’s rights under a lease agreement or consignment and in selling the affected aircraft. Such delays and costs may adversely impact the returns of the Fund. Restructuring of Leases. Under certain circumstances, including when a lessee is late in making payments or fails to make one or more payments in full as required under the applicable lease or is subject to an insolvency or reorganization proceeding, the relevant Fund(s) may be requested to restructure a lease. Restructuring may involve anything from a rescheduling of payments, a reduction and/ or waiver of rental or other payments, or an easing of return conditions upon the termination of a lease and return of the aircraft, in each case without receiving all or any portion of the past due amounts. If any leases are restructured, the Fund expects that any reduced or deferred rental payments would be payable over all or some part of the remaining term of the lease. The Fund may have no reasonable alternative but to agree to such rental reductions in the event no viable substitute lessee is available. The Fund may be unable to agree upon acceptable terms for some or all of the requested restructurings and as a result may exercise its remedies under those leases. If the Fund, in the exercise of its remedies, repossesses the aircraft, the Fund cannot ensure that it will be able to re-lease the aircraft promptly, at favorable rates, or at all. Restructurings with some lessees might occur in the future. The terms and conditions of any such lease restructurings may result in significant reductions of rental payments and adversely impact the returns of the Fund. In addition, conflicts of interest may arise among Funds which have invested in different structures involving the same lessees. Further, in certain restructurings which are approved by the applicable bankruptcy court, a Fund may either receive a benefit or a detriment

depending on the terms of that court approved restructuring, pursuant to which it is possible a Fund has a minority interest and control is decided by other non-affiliate lessors and creditors. Lastly, conflicts of interest may arise as a result of financing structures the Fund may be a part of which has a pool of aircraft leased to different lessees. In this situation, it is possible that the financing structure may be in a position to restructure leases with certain lessees and not others. Lessees in Developing and Emerging Markets. The Fund may lease the aviation assets to operators and airlines located in countries that have poorly developed economies and legal systems that are more vulnerable to economic and political problems, such as civil disturbances, government instability, nationalization and expropriation of private assets, the imposition of taxes or other charges by governments and significant fluctuations in gross domestic product, interest rates and currency exchange rates. The resulting instability may adversely affect the ability of operators and airlines which operate in these markets to meet their lease obligations, and these operators and airlines may be more likely to default than operators and airlines that operate in developed economies. Further, lessors may have difficulty enforcing their rights under leases in these jurisdictions. These factors may adversely affect the Fund’s investments in these jurisdictions and negatively impact the Fund’s ability to make distributions to investors. Failure to Appropriately Discharge Aircraft Liens. In the normal course of business, liens that secure the payment of airport fees and taxes, custom duties, fuel liens, air navigation charges (including charges imposed by Eurocontrol), landing charges, crew wages, maintenance charges, salvage or other liens (“Aircraft Liens”) are likely, depending on the jurisdiction, to attach to the aircraft. Aircraft Liens may secure substantial sums that may, in certain jurisdictions or for limited types of Aircraft Liens (particularly fleet liens), exceed the value of the particular aircraft to which the Aircraft Liens have attached. In some jurisdictions, Aircraft Liens may give the holder thereof the right to detain or, in limited cases, sell or cause the forfeiture of the aircraft. In some cases, it may be difficult to obtain “clear title” to the assets acquired (including all aircraft documentation) unless an expensive title search is undertaken prior to acquisition. Such Aircraft Liens or clouded title could, until discharged, impair the Fund’s ability to repossess or sell aircraft. Although the financial obligations relating to these Aircraft Liens are the responsibilities of the lessees, if lessees fail to fulfill their obligations, Aircraft Liens may attach to the Fund’s aircraft and ultimately become the Fund’s responsibility. In some jurisdictions, Aircraft Liens may give the holder thereof the right to detain or, in limited cases, sell or cause the forfeiture of the aircraft. In such cases, the Fund may find it necessary to pay the claims secured by such liens in order to repossess the aircraft or to obtain the aircraft or engines from a party holding a lien in respect thereof. Maintenance of Aircraft During Lease Term; Funding of Maintenance; Maintenance Reserves. Under most leases, the relevant lessee is primarily responsible for maintaining the aircraft and complying with all governmental requirements applicable to the lessee and the aircraft including operational, maintenance, and registration requirements and airworthiness directives. Failure of a lessee to perform required maintenance with respect to an aircraft during the term of a lease could result in a diminution in value of such aircraft’s parts upon termination of such lease. The Fund will not be in possession of any aircraft while such aircraft are subject to leases. A continuous failure by a lessee to meet its maintenance obligations under the relevant lease (i) could result in a grounding of the aircraft; (ii) in the event of a releasing of the aircraft, could cause the Fund to incur integration and other costs, which may be substantial, in restoring the aircraft to an acceptable maintenance condition; (iii) could result in a lower rental rate or shorter term under any

new lease which the Fund might enter into following repossession of the aircraft; and (iv) would be likely to adversely affect the value of the aircraft. There can be no assurance that the Fund’s operational cash flow and available liquidity reserves will be sufficient to fund maintenance requirements, particularly as aircraft age. Actual rental and maintenance payments by lessees and other cash that the Fund receives may be significantly less than projected as a result of numerous factors, including defaults by lessees and the Fund’s possible inability to obtain satisfactory maintenance provisions in lease agreements. In some cases, a lessee may be entitled to substitute a letter of credit for maintenance reserve payments. Some leases do not provide for any maintenance reserve payments or letters of credit to be made or pledged, as the case may be, by lessees as security for their maintenance obligations, and there can be no assurance that future lease agreements will contain such requirements. Maintenance reserves may be insufficient to cover the scheduled maintenance expenses they are intended to fund. In addition, maintenance reserves typically cover only certain scheduled maintenance requirements and do not cover all required maintenance and all scheduled maintenance. Also, there can be no assurance that lessees will meet their obligations to pay maintenance reserves or perform required scheduled maintenance. If lessees fail to meet their obligation to fund reserves or perform required scheduled maintenance, the Fund may be required to make such payments which may adversely affect investment in the Fund. Amortization Risk. The revenue that will be earned from certain leases may not be sufficient to fully amortize the investment and financing costs related to the underlying aircraft. A wide array of economic factors and regulations may affect the price at which the Fund can dispose of its aviation assets, which, in turn, may reduce the overall rate of return generated by the Fund’s investments. Liabilities, Loss and Insurance. Lessees are required under most leases to indemnify the related lessor for, and insure against, liabilities arising out of use and operation of the aircraft, including third-party claims for death or injury to persons and damage to property for which the Fund may be deemed liable. Lessees are also required to maintain public liability, property damage and aircraft hull insurance on the aircraft at agreed levels. They are not, however, required to maintain political risk insurance and there are other types of events that may or may not be insurable by an operator or airlines (e.g., direct and/or indirect consequences resulting from seizure of an aviation asset by a government official or regulatory body in connection with alleged or actual illegal activity in respect of such aviation asset in the possession of a lessee irrespective of such lessee’s or the lessor’s liability therefor). The lessees may have fleet-wide deductibles for liability insurance. Any hull insurance in respect of such claims will generally be paid to the lessee (in some circumstances up to a cap with the balance going to the lessor), in the event of a partial loss of or damage to the aircraft, to effect repairs, unless there is a total loss with respect to the aircraft in which case insurance proceeds are paid to the lessor or, in the case of liability insurance, to each of the insured parties for indemnification of third-party liabilities. In the event of a total loss, the lessor will usually be entitled to receive insurance proceeds equal to an amount agreed to at the commencement of the lease, and subject to the terms of the applicable lease, the balance of any hull insurance proceeds after deduction for all amounts due and payable by the lessee under such lease, may remain with the lessee. There can be no assurance that insurance of operators and airlines, including any available governmental supplemental coverage, will cover all types of claims that may be asserted against the Fund. Any inadequate insurance coverage, default by an insurer or default by operators and airlines in fulfilling their indemnification or insurance

obligations or the lack of political risk insurance will affect the proceeds that would be received by the Fund upon an event of loss under the relevant lease agreement or upon a claim under the relevant liability insurance policy. Liability Risk as Lessor. Section 44112 of Title 49 of the United States Code (“Section 44112”) provides that lessors of aircraft or engines generally will not be liable for any personal injury or death, or damage to or loss of property (collectively, “Loss” or “Losses”); provided, that such lessor is not in actual possession or control of the equipment at the time of such Loss. Under common law, the owner of an aircraft or engine may be held liable for injuries or damage to passengers or property, and such damage awards can be substantial. Because certain case law interpreting Section 44112 provides that lessors of aircraft or engines may be liable for Losses, there can be no assurance that the provisions of Section 44112 would fully protect the lessor and the Fund from all liabilities in connection with any Losses that may be caused by any aircraft or engine it owns. Therefore, each lessee typically will be required to indemnify the lessor and/or the Fund for, or insure the lessor or the Fund against, such claims by third parties. Nonetheless, if Section 44112 does not apply in a particular action, there is the possibility that the lessee might not have the financial resources or insurance to fulfill its indemnity obligations. It should be noted, however, that this description is limited to U.S. law, and to the extent that the law in foreign jurisdictions is applicable (e.g., in a jurisdiction where an accident occurs), different rules may apply. For example, certain foreign jurisdictions may impose strict liability upon an owner of an aircraft or an engine. Such liability may apply with respect to claims of passengers, employees or third parties for death, injury and/or damages to public or private property (including consequences of terrorist attacks) or environmental damages. As described above, operators and airlines may be unable or unwilling to indemnify the Fund, resulting in losses to the Fund. The scope and amount of insurance coverage available to airlines for liability to third persons may decrease while the premiums for such third-party risk insurance may simultaneously or otherwise increase. This situation may result in the operators, airlines and/or the Fund not obtaining sufficient insurance coverage to cover all types of claims that may be asserted against the operators and airlines or the Fund. Such insufficient insurance coverage amounts or defaults by operators and airlines in fulfilling their indemnification or insurance obligations or the lack of third-party liability insurance may increase the loss amounts for which the operators and airlines or the Fund are ultimately liable. Castlelake will typically seek to require lessees to maintain those types of insurance customary and appropriate in the air transportation industry, including liability insurance and aircraft hull insurance. There can be no assurance that lessees’ insurance will cover all types of claims that may be asserted against the Fund. Any inadequate insurance coverage, default by an insurer or default by lessees in fulfilling their indemnification or insurance obligations will negatively affect the proceeds that would be received by the Fund, and ultimately, the Partners, upon an event of loss under the respective leases or upon a claim under the relevant liability insurance. Effects of Industry Economic Losses and Airline Reorganizations. The aviation industry as a whole suffered significant losses as a result of deteriorating international economic conditions during the global financial crisis and may again do so in the future. Certain airlines have announced reductions in capacity, services and employee workforce in response to reductions in passenger demands and yields in certain regions. Airlines involved in reorganizations typically undertake

substantial fare discounting to maintain cash flows and to encourage continued customer loyalty. Such fare discounting has led to lower yields. In certain regions, bankruptcies, reductions in capacity, labor strikes and slowdowns and reduced demand generally have led to the grounding of significant numbers of aircraft and the negotiated reduction of aircraft lease rental rates which has had the effect of depressing aircraft market values. The permanent or near permanent grounding of aircraft, if concentrated among one or a few aircraft models, may also depress the market values of individual parts since the decreased use of aircraft results in fewer maintenance events (including piece-part replacement) thereby increasing the supply of aircraft parts while simultaneously decreasing the demand for such parts. Reorganizations or liquidations by airlines often lead to the rejection of aircraft leases or the abandonment of aircraft by airlines which would then exacerbate the already depressed aircraft values. Effects of Fuel Costs. Fuel costs represent a major expense to airline operators. Fuel prices fluctuate widely depending primarily on international market conditions, geopolitical and environmental events and currency/exchange rates. Although having declined from historical peaks, fuel prices tend to fluctuate. Significant fuel price increases would materially affect the operating results and profitability of the airlines. Long or short-term fluctuations may (i) affect the ability of operators and airlines to make rental and other lease payments; (ii) result in lease restructurings and aircraft repossessions; (iii) impair the Fund’s ability to re-market or otherwise dispose of the aircraft on a timely basis and/or at favorable terms; and (iv) reduce the value received for the aircraft upon any disposition. Illiquidity of Investments in Assets. The Funds invest in assets, loans or securities for which no (or only a limited) liquid market exists or that are subject to legal or other restrictions or transfer. The market prices, if any, for such investments may in fact be volatile, and may fluctuate due to a variety of factors that are inherently difficult to predict, including, but not limited to, changes in interest rates, prevailing credit spreads, general economic conditions, financial market conditions, domestic or international economic or political events, developments or trends in any particular industry, and the financing condition of the obligors on the assets. Castlelake may not be able to sell investments when it desires to do so or to realize what it perceives to be their fair value in the event of a sale. A portion of the investments may consist of securities that are subject to restrictions on resale because they were acquired in a “private placement” transaction or for other reasons including Castlelake’s access to material non-public information. In addition, the Funds may hold investments subject to contractual restrictions on transfer. The sale of illiquid assets and restricted securities often requires more time and results in higher brokerage charges and other selling expenses than does the sale of securities eligible for trading on national securities exchanges or in the over-the-counter markets. Investments in Real Estate. Castlelake may, from time to time, invest in a variety of real estate and related transactions, either as a direct investment or through investment in other entities, including affiliates. Investing in real estate entails certain risks including: the burdens of ownership of real property; local, national and international economic conditions; the supply and demand for properties; the financial condition of tenants, buyers and sellers of properties; changes in interest rates and the availability of mortgage funds which may render the sale or refinancing of properties difficult or impracticable; changes in environmental laws and regulations, planning laws and other

governmental rules and fiscal and monetary policies; environmental claims arising in respect of properties acquired with undisclosed or unknown environmental problems or as to which inadequate reserves have been established; changes in real property tax rates; changes in energy prices; negative developments in the economy; uninsured casualties; force majeure acts, weather events, terrorist events, under-insured or uninsurable losses; and other factors which are beyond the reasonable control of Castlelake. In addition, real estate assets are subject to long-term cyclical trends that give rise to significant volatility in values. Many of these factors could cause fluctuations in occupancy rates, rent schedules or operating expenses, causing the value of the Fund’s investments to decline and negatively affect the Fund’s returns. The value of the Fund’s investments may fluctuate significantly due to these factors and may be significantly diminished in the event of a sudden downward market for real estate and real estate related assets. The returns available from investments depend on the amount of income earned and capital appreciation generated by the relevant underlying properties, as well as expenses incurred in connection therewith. If properties do not generate income sufficient to meet operating expenses, including amounts owed under any third-party borrowings and capital expenditures, the Fund’s returns will be adversely affected. In addition, the cost of complying with governmental laws and regulations and the cost and availability of third-party borrowings may also affect the market value of and returns from the investments. The Fund’s returns would be adversely affected if a significant number of tenants were unable to pay rent or if properties could not be rented on favorable terms. Certain significant fixed expenditures associated with purchasing properties (such as third-party borrowings, taxes and maintenance costs) may stay the same or increase even when circumstances cause a reduction in returns from properties. Real estate-related investments can entail the following risks: •

Redeveloping and Repositioning Risks. The Fund may seek to redevelop or reposition certain real estate properties. Such redevelopment or repositioning carries a number of attendant risks, including the possibility that costs incurred in connection with the initial development may not be recovered. In addition, suitable tenants may not be found for repositioned properties, which could lead to the Fund owning vacant properties producing insufficient income to meet expenses or provide a suitable return to the Fund. Another risk associated with redevelopment or repositioning include the risk that delays in the construction timetable result in a property not reaching a stage where it is reasonably fit for occupancy. Similarly, there may be planning risks arising from difficulties in obtaining planning consents and licenses, which delay the construction timetable of a redevelopment or repositioning timetable.

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Risks of Acquiring Real Estate Loans and Participation. Real estate loans acquired by the Fund can be at the time of their acquisition, or may become after acquisition, nonperforming for a wide variety of reasons. Such nonperforming real estate loans will require a substantial amount of workout negotiations and/or restructuring, which may entail, among other things, a substantial reduction in the interest rate and a substantial write down of the principal of such loan. However, even if a restructuring were successfully accomplished, a risk exists that, upon maturity of such real estate loan, replacement “takeout” financing will not be available. Purchases of participations in real estate loans may involve many of the same risks as investments in real estate loans and also carry risks of illiquidity and lack of control. It is possible that Castlelake may find it necessary or

desirable to foreclose on collateral securing one or more real estate loans purchased by or on behalf of the Fund. The foreclosure process can be lengthy and expensive. Borrowers often resist foreclosure actions by asserting several claims, counterclaims and defenses against the holder of a real estate loan, including, without limitation, lender liability claims and defenses, even when such assertions have no basis in fact, in an effort to prolong the foreclosure action. In some jurisdictions, foreclosure actions can take up to several years to conclude. At any time during the foreclosure proceedings, the borrower may file for protection under bankruptcy or other similar law, which would have the effect of staying the foreclosure action and further delaying the foreclosure process. Foreclosure litigation may also create a negative public image of the collateral property and may disrupt ongoing leasing and management of the property. •

Investments in New Developments. Acquisition of direct or indirect interests in, or loans to owners or developers of, undeveloped land or underdeveloped real property, which are often non-income producing, are subject to the risks normally associated with such assets and development activities. Such risks include, without limitation, risks relating to the availability and timely receipt of zoning and other regulatory approvals and entitlements, the cost and timely completion of construction (including risks beyond the control of Castlelake, such as weather or labor conditions or material shortages), supply chain disruptions, increased costs of supply and labor, the availability of both construction and permanent financing on favorable terms, political or local opposition, environmental issues, labor disputes (such as work stoppages), counterparty nonperformance, project feasibility assessment and dealings with and reliance on third-party consultants. In addition, these investments will also be subject to the risks relating to the developer’s or construction manager’s ability to control construction costs or to build in conformity with plans and specifications, as well as to meet applicable timetables. Investments in new developments may also be affected or delayed by conditions beyond the developer’s or construction manager’s control. Additional risks may be incurred with periodic progress payments or other advances to a developer or construction manager prior to completion of construction or renovation. Properties under development or properties acquired to be developed may receive little or no cash flow from the date of acquisition through the date of completion of development and may experience operating deficits after the date of completion. The Funds generally rely upon projections of rental income and expenses and estimates of the fair market value of property upon completion of construction or renovation when agreeing upon a price to be paid for the property. These risks could result in substantial unanticipated delays, increased costs and expenses and, under certain circumstances, could prevent completion of development activities once undertaken, any of which could have an adverse effect on the Funds.

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Availability of Insurance Against Certain Catastrophic Losses. Certain losses of a catastrophic nature, such as wars, earthquakes, floods, environmental contamination, terrorist attacks or other similar events, may be either uninsurable or insurable at such high rates that to maintain such coverage would cause an adverse impact on the related investments. In general, losses related to terrorism are becoming more difficult and more expensive to insure against. Some insurers are excluding terrorism coverage from their allrisk policies. In some cases, the insurers are offering significantly limited coverage against terrorist acts for additional premiums, which can greatly increase the total costs of casualty

insurance for a property. As a result, not all investments may be insured against terrorism. If a major uninsured loss occurs, the Fund could lose both invested capital in and anticipated profits from the affected investments. •

Environmental Liabilities. The Funds may be exposed to substantial risk of loss from environmental claims arising in respect of direct investments made in real estate with undisclosed or unknown environmental problems or as to which inadequate reserves had been established, including being liable for the costs of removal or remediation of certain hazardous or toxic substances on or in such property. Environmental claims with respect to a specific investment may exceed the value of such investment, and under certain circumstances, subject the other assets of the Funds to such liabilities. The presence of such hazardous or toxic substances, or the failure to properly remediate contamination from such substances, may adversely affect the owner’s ability to sell the real estate or to borrow using such property as collateral and may have a significant adverse effect on the value and returns from such property. Under various laws, ordinances and regulations, an owner of property may be liable for the costs of removal or remediation of certain hazardous or toxic substances on or in such property. Such laws, ordinances and regulations may impose joint and several liability, which can result in a party being obligated to pay for greater than its share, or even all, of the liability involved. Such liability may also be imposed without regard to whether the owner knew of, or caused, the presence of such hazardous or toxic substances. The cost of any required remediation and the owner’s liability therefore as to any property are generally not limited under such laws and regulations and could exceed the value of the property and/or the aggregate assets of the owner. The presence of such substances, or the failure to properly remediate contamination from such substances, may adversely affect the owner’s ability to sell, lease, or otherwise realize income from the real estate or to borrow funds using such property as collateral, which could have an adverse effect on the Fund’s return from such investment.

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Harmful Mold and Other Air Quality Issues. When excessive moisture accumulates in buildings or on building materials, mold may grow, particularly if the moisture problem remains undiscovered or is not addressed over a period of time. Some molds may produce airborne toxins or irritants. Indoor air quality issues can also stem from inadequate ventilation, chemical contamination from indoor or outdoor sources and other biological contaminants such as pollen, viruses and bacteria. Indoor exposure to airborne toxins or irritants above certain levels can be alleged to cause a variety of adverse health effects and symptoms, including allergic or other reactions. As a result, the presence of significant mold or other airborne contaminants at any of the Fund’s properties could require the Fund to undertake a costly remediation program to contain or remove the mold or other airborne contaminants from the affected property or increase indoor ventilation. In addition, the presence of significant mold or other airborne contaminants could expose the Fund to liability from its tenants, employees of its tenants and others if property damage or health concerns arise.

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Americans with Disabilities Act. Certain U.S. properties of the type to be acquired by the Fund must comply with Title III of the Americans with Disabilities Act (the “ADA”) to the extent that such properties are “public accommodations” or “commercial facilities” as defined by the ADA. The ADA may require removal of structural barriers to access by

persons with disabilities in certain public areas of the properties where such removal is readily achievable. However, noncompliance with the ADA could result in substantial capital expenditures to remove structural barriers, as well as the imposition of fines or an award of damages to private litigants which might adversely affect the Fund’s ability to make distributions to investors. Similar protective legislation can apply with respect to real estate holdings in Europe and can affect the Fund’s investment returns. •

Other Regulatory Risks. Real estate properties are subject to various forms of regulation in addition to the ADA, including building codes, regulations pertaining to fire safety and handicapped access, and other regulations, which may from time to time be enacted. The Fund may be required to incur significant costs to comply with any future changes in such regulations. However, noncompliance with existing or future regulations to which the properties are subject could result in substantial capital expenditures to bring the properties into compliance, as well as the imposition of fines or an award of damages to private litigants, which might adversely affect the Fund’s ability to make expected distributions to investors.

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Business Risks. The Fund may invest in a full array of assets and instruments across aircraft and aviation finance markets and instruments globally. Such investments involve a high degree of business and financial risk that can result in substantial losses.

Investment in Loans. Castlelake may invest in loans in multiple types of industries, which may entail the following risks (among others): •

General Credit Risks. Credit risk relates to the ability of the borrower to make interest and principal payments on the loan or security as they become due. If the borrower fails to pay interest, the Fund’s income might be reduced. If the borrower fails to repay principal, the value of that investment and the value of the Fund might be reduced. The Fund’s interests in debt instruments are subject to risks of default. The Fund may be exposed to losses resulting from default and foreclosure. The value of the underlying collateral, if any, the creditworthiness of the borrower and the priority of the lien are each of great importance (although the Fund may invest in subordinate or second priority liens). There is no assurance that the Fund will correctly evaluate the value of the assets collateralizing the loans or the prospects for a successful reorganization or similar action. In any reorganization or liquidation proceeding relating to a company in which the Fund has an interest, the Fund may lose all or part of the amounts advanced to the borrower. The Fund cannot guarantee the adequacy of the protection of the Fund’s interests, including the validity or enforceability of the loan and the maintenance of the anticipated priority and perfection of the applicable security interests. Furthermore, the Fund cannot assure that claims may not be asserted that might interfere with enforcement of the Fund’s rights. In the event of a foreclosure, the Fund or an affiliate of the Fund may assume direct ownership of the underlying asset. The liquidation proceeds upon sale of such asset may not satisfy the entire outstanding balance of principal and interest on the loan, resulting in a loss to the Fund. Any costs or delays involved in the effectuation of a foreclosure of the loan, or a liquidation of the underlying property will further reduce the proceeds and thus increase the loss.

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Lower Credit Quality Loans. There are no restrictions on the credit quality of loans in which the Fund can invest. Loans purchased by the Fund are expected to have substantial vulnerability to default in payment of interest and/or principal. Certain loans which the Fund may possess have large uncertainties or major risk exposures to adverse conditions and may be considered to be predominantly speculative. Generally, such loans offer a higher return potential than better quality loans but involve greater volatility of price and greater risk of loss of income and principal. The market values of certain of these loans are also generally considered to be subject to greater risk than obligations with higher ratings in the case of deterioration of general economic conditions, and the yields and prices of such obligations may be more volatile than those for higher-rated securities.

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Equitable Subordination. Loans to companies operating in workout modes or under Chapter 11 of the Bankruptcy Code are, in certain circumstances, subject to certain potential liabilities which may exceed the amount of the Fund’s loan. For example, under certain circumstances, lenders who have inappropriately exercised control of the management and policies of a debtor may have their claims subordinated or disallowed or may be found liable for damages suffered by parties as a result of such actions.

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Usury Considerations. Interest charged on loans owned by Funds may be subject to state usury laws imposing maximum interest rates and penalties for violation, including restitution of excess interest, unenforceability of debt, rescission rights or other borrower remedies. Although the Funds do not intend to engage in conduct expected to be in violation of any applicable usury laws, the potential exists for a borrower to assert that the usury laws of particular jurisdiction apply to a loan transaction.

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Lack of Liquidity. Loans and interests in loans have significant liquidity risks and market value risks since they are generally not publicly traded in organized exchange markets but are traded by banks and other institutional investors engaged in loan syndications. Because loans are privately syndicated and loan agreements are generally privately and heavily negotiated and customized and subject to offering restrictions, loans are not purchased or sold as easily as publicly traded securities. Due to their illiquid nature, the Fund may not be able to dispose of its interest in a debt security in a timely manner and/or at a fair price. There is no assurance that the Fund will be able to dispose of an investment in a particular debt instrument prior to its redemption at maturity. The inability to dispose of a loan position could result in losses to the Fund, including the loss of its entire investment. The debt of highly leveraged companies or companies in default also may be less liquid than other debt. If the Fund voluntarily or involuntarily sold its interests in those types of debt instruments, it might not receive the full value it expected. In particular, these risks could arise from changes in the financial condition or prospects of the companies whose borrowings underlie the Fund’s investments, changes in national or international economic or political conditions (including acts of war, terrorism or other calamity or crisis), adverse conditions in national or global financial or capital markets, or changes in laws, regulations, fiscal policies or political conditions of countries in which investments are made.

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Special Risks. Special risks associated with investments in bank loans and participations include (i) the possible invalidation of an investment transaction as a fraudulent conveyance under relevant creditors’ rights laws, (ii) so called lender liability claims by the issuer of the obligations, (iii) environmental and other liabilities that may arise with respect to collateral securing the obligations, and (iv) limitations on the ability of the Fund to directly enforce its rights with respect to participations. Successful claims by third parties arising from these and other risks, absent bad faith, will be borne by the Fund.

Loans and Origination Activities. The Fund may engage in the origination of debt financing and/or purchase loans. If the Fund engages in such activities, it will be subject to applicable laws in each jurisdiction in which such activities take place. Such laws are frequently highly complex and may include licensing or registration requirements. The licensing processes can be lengthy and can be expected to subject a loan originator to increased regulatory oversight. In addition, the Fund may make certain investments in industries, companies or assets that are subject to licensing and other regulatory requirements that may impact the Fund’s ability to fully implement its investment strategy without obtaining the requisite license or regulatory approval. The Fund may incur significant costs, expenses and delays (including missed investment opportunities) in connection with such license or registration requirements. Non-compliance with such laws or regulations could have an adverse effect on the Fund. In some instances, the process for obtaining a required license may require disclosure to regulators or to the public of information about the Fund, its direct or indirect investors, its loans, its business activities, its management or controlling persons or other matters. Such disclosures may provide competitors with information that allows them to benefit at the expense of the Fund, which could have a material adverse effect on the Fund. Failure, even if unintentional, to comply fully with applicable laws may result in sanctions, fines, or limitations on the ability of the Fund, Castlelake or their respective affiliates of the foregoing to do business in the relevant jurisdiction or to procure required licenses in other jurisdictions, all of which could have a material adverse effect on the Fund. Non-Performing Loans (“NPLs”). The Fund’s investments are expected to include investments in NPLs and sub-performing loans which may involve a substantial amount of workout negotiations and restructuring, which may entail, among other things, the possibility of foreclosure and/or a substantial reduction in the interest rate and a substantial write-down of the principal invested in such loans. These processes can be lengthy and expensive. The Fund’s investments in NPLs will likely involve entities or issuers that are experiencing or are expected to experience financial difficulties which may never be overcome, including companies involved in bankruptcy or other reorganization and liquidation proceedings. As a result, the Fund’s investments may be subject to additional bankruptcy-related risks and returns on such investments may not be realized for a considerable period of time. Such investments could, in certain circumstances, subject the Fund to certain additional potential liabilities, which may exceed the value of the Fund’s original investment therein. The Fund may also be subject to lengthy and expensive processes in relation to realizing value in such investments. There can be no assurance as to the amount and timing of payments with respect to NPLs. Further, while certain NPLs may be secured, some NPLs may not be secured. While investments in such NPLs may offer the opportunity for significant gains if all or a part of the

principal on the loans is recovered, these investments involve a high degree of financial risk and can result in substantial or complete losses to the Fund. There can be no assurance that the Fund’s investments in NPLs will prove profitable or that the Fund will not incur significant losses. There are varying sources of statistical default and recovery rate data for loans and other debt securities and numerous methods for measuring default and recovery rates. However, historical performance of financial assets is not necessarily indicative of their future performance. NPL Underwriting. The underwriting guidelines for NPLs are different from and, in certain respects, less stringent than the other general underwriting standards employed by originators. For example, these loans may have been originated to borrowers that have poor credit or that provide limited or no documentation in connection with the underwriting of the mortgage loan. Such loans present increased risk standards of delinquency, foreclosure, bankruptcy and loss than prime mortgage loans. An originator generally originates mortgage loans in accordance with underwriting guidelines it has established and, in certain cases, based on exceptions to those guidelines. These guidelines may not identify or appropriately assess the risk that the interest and principal payments due on a mortgage loan will be repaid when due, or at all, or whether the value of the mortgaged property will be sufficient to otherwise provide for recovery of such amounts. To the extent exceptions were made to an originator’s underwriting guidelines in originating an NPL, those exceptions may increase the risk that principal and interest amounts may not be received or recovered and compensating factors, if any, which may have been the premise for making an exception to the underwriting guidelines may not in fact compensate for any additional risk. NPLs may be secured by investor or commercial properties and/or assets or a borrower’s primary residence or second home. NPL Modifications. Part of the Fund’s strategy in acquiring NPLs may involve making NPL modifications to reduce delinquencies and the risk of borrower default and, ultimately, to maximize the value of the NPL. Modifications may include permanently or temporarily reducing or otherwise changing the mortgage interest rate, forgiving payments of principal or interest, extending the final maturity date, capitalizing or deferring delinquent interest and other amounts owed under the mortgage loans, deferring principal payments with or without interest, or any combination of these or other modifications. These modifications may reduce the value of the NPL. The Fund’s ability to modify NPLs may be limited due to the difficulty in contacting at-risk borrowers or creating modifications acceptable to affected borrowers. NPL Refinancing. The Fund may seek to refinance an NPL to realize the greater value from such loan. However, there may be impediments to executing a refinancing strategy for NPLs. For example, many mortgage lenders have adjusted their loan programs and underwriting standards to be more conservative, which has reduced the availability of mortgage credit to prospective borrowers. This has resulted in reduced availability of financing alternatives for borrowers seeking to refinance their mortgage loans. A decline in housing prices may also result in higher loan-tovalue ratios and leave borrowers with insufficient equity in their homes to permit them to refinance. To the extent prevailing mortgage interest rates continue to rise from their current levels, these risks would be exacerbated. The effect of the above would likely serve to make refinancing NPLs potentially more difficult and less profitable for the Fund.

Residential Mortgage NPLs. The Funds may acquire residential mortgage NPLs where the borrowers have failed to make timely payments of principal and/or interest currently or in the past. As part of the residential mortgage NPL portfolios the Funds may purchase, the Funds also may acquire performing loans that subsequently become non-performing. Many of these loans may have current loan-to-value ratios in excess of 100%, meaning the amount owed on the loan exceeds the value of the underlying real estate. If actual results are different from Castlelake’s assumptions in determining the prices for such loans, particularly if the market value of the underlying property decreases significantly, the Funds may incur significant losses. General Risks Associated with Mortgage Loan Investments. The Funds may invest in or purchase mortgage loans. A Fund’s acquisition of mortgage loans is subject to certain risks, such as the “as is” basis, with limited or no representations or warranties on which a loan is usually acquired, fraud in connection with the origination of the loan, uninsured title defects and casualty losses to the underlying real estate improvements, missing or incomplete loan files due to the seasoned nature of the loans, and foreclosure or other collection counterclaims, offsets or other defenses asserted by borrowers and guarantors in the event of a default and the initiation of foreclosure proceedings, or by a borrower’s bankruptcy and other civil or criminal proceedings. A Fund may conduct limited due diligence with respect to the mortgage loans it acquires, and no assurance can be given with respect to the truth or accuracy of the representations and warranties made with respect to a mortgage loan acquired by the Funds. Collection or foreclosure proceedings could also be prevented or delayed due to missing or deficient documents, such as promissory notes, mortgages, guarantees, assignments, title work, surveys, appraisals, environmental and other reports, and closing documents. The Funds, and their mortgage loan servicers, are expected to be restricted in their foreclosure and debt collection practices by various laws that regulate debt collection and unfair credit collection practices. Any changes in such regulations could adversely affect the Funds’ results of operations or its ability to generate returns. The Funds also exposed to the risk of increases in interest rates that would diminish the value of fixed-interest-rate loans acquired by the Funds. Any diminution in the value of those loans would adversely affect the Funds’ operating results. The underlying real estate and other assets securing mortgage loans will be subject to several risks, including those described herein with respect to real estate generally; and impairment in the value of such real estate or other assets as a result of the materialization of such risks materializing can adversely affect the value of the Funds’ investments in such mortgage loans or such real estate or other assets. The ability of a borrower to repay a loan secured by residential property typically is dependent upon the existence of independent income or assets of the borrower. Exercise of foreclosure and other remedies may involve lengthy delays and additional legal and other related expenses on top of potentially declining property values. In certain circumstances, the creditors may also become liable upon taking title to an asset for environmental or structural damage existing at the property. Furthermore, a Fund is permitted to, at any time during its terms, securitize and sell pools of mortgage loans.

Risks Associated with Commercial Mortgage Loans. The Funds may invest in commercial mortgage loans. The value of a Fund’s commercial mortgage loans will be influenced by the historical rate of delinquencies, defaults experienced on the commercial mortgage loans and the severity of loss incurred as a result of such defaults, as well as market conditions. The factors affecting delinquencies, defaults and loss severity include (a) industry sector and economic and real estate market conditions (e.g., multi-family, retail, office), (b) the terms and structure of the mortgage loans, and (c) any specific limits to legal and financial recourse upon a default under the terms of the mortgage loan. Commercial loans generally expose a lender to a greater risk of loss through delinquency and foreclosure since the ability of the borrower to repay a loan secured by income-producing property typically is dependent primarily upon the successful operation and operating income of such property, rather than upon the existence of independent income or assets of the borrower. Most commercial mortgage loans provide recourse only to specific assets, such as the property, and not against the borrower’s other assets or personal guarantees. Commercial mortgage loans generally do not fully amortize, which can necessitate a sale of the property or refinancing of the remaining debt amount at or prior to maturity of the mortgage loan. Accordingly, investors in commercial mortgage loans bear the risk that the borrower will be unable to refinance or otherwise repay the mortgage at maturity, thereby increasing the likelihood of a default on the borrower’s obligations. Exercise of foreclosure and other remedies may involve lengthy delays and additional legal and other related expenses on top of potentially declining property values. In certain circumstances, a Fund could become liable upon taking title to an asset for environmental or structural damage existing at the property. Lender Liability Considerations and Equitable Subordination. In recent years, a number of judicial decisions in the United States have upheld the right of borrowers to sue lending institutions on the basis of various evolving legal theories (collectively termed “lender liability”). Generally, lender liability is founded upon the premise that an institutional lender has violated a duty (whether implied or contractual) of good faith and fair dealing owed to the borrower or has assumed a degree of control over the borrower resulting in a creation of a fiduciary duty owed to the borrower or its other creditors or shareholders. While believed to be unlikely, because of the nature of certain of the Fund investments, the Fund could be subject to allegations of lender liability. In addition, under common law principles that in some cases form the basis for lender liability claims, if a lending institution (i) intentionally takes an action that results in the undercapitalization of a borrower to the detriment of other creditors of such borrower, (ii) engages in other inequitable conduct to the detriment of such other creditors, (iii) engages in fraud with respect to, or makes misrepresentations to, such other creditors, or (iv) uses its or its affiliates’ influence as a stockholder to dominate or control a borrower to the detriment of other creditors of such borrower, a court may elect to subordinate the claim of the offending lending institution to the claims of the disadvantaged creditor or creditors, a remedy called “equitable subordination.” Because of the nature of certain of the Fund’s investments, the Fund could be subject to claims from creditors of an obligor that Fund’s investments issued by such obligor that are held by the Fund should be equitably subordinated, which could potentially reduce the cash flows and/or market value of the investment. The Fund may make investments in which it would not be the lead creditor. Accordingly, it is possible that lender liability or equitable subordination claims affecting the Fund investments could arise without the direct involvement of the Fund.

Nature of Investment in First Lien Senior Loans. The assets of the Fund’s portfolio are permitted to include first lien senior secured debt, including term loans and revolving loans and could pay interest at a fixed or floating rate. The Fund may acquire interests in first lien loans by way of purchase or assignment in the primary and secondary markets. The purchaser of an assignment typically succeeds to all the rights and obligations of the assigning institution and becomes a contracting party under the legal documentation with respect to the debt obligation; however, its rights can be more restricted than those of the assigning institution. In addition, if the Fund acquires loans pursuant to an assignment, it is possible that the Fund’s claims may be subject to attack (i.e., equitable subordination (as more fully discussed below) or disallowance) on account of the conduct of the transferee. Some of the senior secured loans acquired by the Fund may be rated below investment grade or may not be rated by a credit rating agency. In terms of liquidity with respect to such investments, there can be no assurance that levels of supply and demand in senior secured loan trading will provide an adequate degree of liquidity for the investments therein. The factors affecting an issuer’s first lien loans, and its overall capital structure, are complex. Some first lien loans may not necessarily have priority over all other debt of an issuer. For example, some first lien loans may permit other secured obligations (such as overdrafts, swaps or other derivatives made available by members of the syndicate to the company) or involve first liens only on specified assets of an issuer (e.g., excluding real estate). Issuers of first lien loans may have two tranches of first lien debt outstanding, each with first liens on separate collateral. Furthermore, any secured debt is secured only to the extent of its lien and only to the extent of underlying assets or incremental proceeds on already secured assets. In the event of a chapter 11 filing by an issuer, title 11 of the United States Code (11 U.S.C. §§ 101 - 1532) (the “Bankruptcy Code”) authorizes the issuer to use a creditor’s collateral and to obtain additional credit by grant of a priority lien on the issuer’s property, senior even to liens that were first in priority prior to the bankruptcy filing, as long as the issuer provides what the presiding bankruptcy judge considers to be “adequate protection,” which may, but need not always, consist of the grant of replacement or additional liens or the making of cash payments to the affected secured creditor. The imposition of prior liens on the Fund’s collateral would adversely affect the priority of the liens and claims held by the Fund and could adversely affect the Fund’s recovery on its investments. Moreover, underlying assets are subject to credit, liquidity, and interest rate risk. Although the amount and characteristics of the underlying assets considered as collateral may allow the Fund to withstand certain assumed deficiencies in payments occasioned by the company’s default, if any deficiencies exceed such assumed levels or if underlying assets are sold it is possible that the proceeds of such sale or disposition will not be equal to the amount of principal and interest owing to the Fund in respect to its investment. Further, loans may become non-performing for a variety of reasons. Upon a bankruptcy filing by an issuer of debt, the Bankruptcy Code imposes an automatic stay on payments of its prepetition debt. Non-performing debt obligations may require substantial workout negotiations, restructuring or bankruptcy filings that may entail a substantial reduction in the interest rate, deferral of payments and/or a substantial write-down of the principal of a loan or conversion of some or all of the debt to equity. If an issuer were to seek relief under chapter 11 of the Bankruptcy Code, the Bankruptcy Code authorizes the issuer to restructure the terms of repayment of a class

of debt even if the class fails to accept the restructuring as long as the restructured terms are “fair and equitable” to the class and certain other conditions are met. First lien credit facilities are often syndicated to a number of different financial market participants. The documentation governing the facilities typically require either a majority consent or, in certain cases, unanimous approval for certain actions in respect of the loan, such as waivers, amendments, or the exercise of remedies. In addition, voting to accept or reject the terms of a restructuring of a credit pursuant to a chapter 11 plan of reorganization is usually done on a class basis. As a result of these voting regimes, the Fund may not have the ability to control any decision in respect of any amendment, waiver, exercise of remedies, restructuring or reorganization of an investment. First lien loans are also subject to other risks and can cause unsecured creditors to seek remedies in order to limit the Fund’s potential recovery of such investments, including (i) the possible invalidation of a debt or lien as a “fraudulent conveyance,” (ii) the recovery as a “preference” of liens perfected or payments made on account of a debt in the 90 days before a bankruptcy filing, (iii) equitable subordination claims by other creditors, (iv) so-called “lender liability” claims by the issuer of the obligations, (v) environmental liabilities that may arise with respect to collateral securing the obligations, (vi) recharacterization claims in which certain creditors may seek to have the Fund’s debt positions recharacterized as equity and therefore subordinate the Fund’s claims to such creditors’ claims and (vii) designating the vote (i.e., ignoring the customary class vote system) under a chapter 11 plan of reorganization in which lenders are entitled to vote as a class. It is possible that a secondary loan market participant can be denied a recovery from the debtor in a bankruptcy if a prior holder of the loans either received and does not return a preference or fraudulent conveyance or engaged in conduct that would qualify for equitable subordination. The Fund’s investments may be subject to early redemption features, refinancing options, prepayment options or similar provisions that, in each case, could result in the issuer repaying the principal on an obligation held by the Fund earlier than expected. It is common for first lien debt to be repaid prior to its maturity; thus, the actual duration of such investments is typically shorter than their stated final maturity calculated solely on the basis of the stated life and repayment schedule. Generally voluntary prepayments are permitted, and the timing of prepayments cannot be predicted with any accuracy. The degree to which issuers prepay senior debt, whether as a contractual requirement or at their election, may be affected by general business conditions, market interest rates, the issuer’s financial condition and competitive market conditions among lenders. Nature of Investment in Second Lien Senior Loans. The assets of a Fund’s portfolio can include second lien senior secured debt, including term loans and revolving loans and could pay interest at a fixed or floating rate. Investments in second lien senior loans may be unsecured and will rank behind the issuer’s secured indebtedness, including first lien senior loans. Second lien loans are subject to the same risks associated with loans in general described above under “Nature of Investment in First Lien Senior Loans.” However, second lien senior loans are subordinate in right of payment to one or more senior secured loans of the related borrower and therefore are subject to additional risk that the cash flow of the related borrower and the property securing the loan may be insufficient to repay the scheduled payments to the Fund after

giving effect to any senior secured obligations of the related borrower. Second lien senior loans are also expected to be a more illiquid investment than senior secured loans for such reason. There also is less likelihood that the Fund will be able to sell participations in second lien loans that it originates or acquires, which would expose the Fund to increased risk. Nature of Investment in Subordinated Debt Instruments. Certain of the Fund’s investments are permitted to consist of loans or securities, or interests in pools of securities, that are subordinated or may be subordinated in right of payment and ranked junior to other securities issued by, or loans made to obligors. While such subordinated debt investments may benefit from the same or similar financial and other covenants as those enjoyed by the indebtedness ranking ahead of such investments and may benefit from cross-default provisions, some or all of such terms may not be part of particular investments. For example, under typical subordination terms, secured creditors are able to block the acceleration of the debt or the exercise by debt holders of other rights or remedies they may have as creditors for a period of time. In addition, the unsecured debt in which the Fund may invest may not be protected by financial covenants or limitations upon additional indebtedness, could have limited liquidity and may not be rated by a credit rating agency. Further, upon any distribution to an issuer’s creditors in a bankruptcy, liquidation or reorganization or similar proceeding, the holders of such issuer’s senior and/or secured indebtedness (to the extent of the collateral securing such obligation) will be entitled to be paid in full before any payment may be made with respect to the Fund’s subordinated debt investments. In the event of a bankruptcy, liquidation or reorganization or similar proceeding relating to an issuer, the Fund will participate with all other holders of such issuer’s indebtedness in the assets remaining after the issuer has paid all of its senior and/or secured indebtedness (to the extent of the collateral securing such obligation). An issuer may not have sufficient funds to pay all of its creditors and the Fund may receive nothing, or less, ratably, than the holders of senior and/or secured indebtedness of such issuer or the holders of indebtedness that is not subordinated. Mezzanine Loans. The Funds are permitted to invest in mezzanine loans that also have indebtedness which is more senior than the mezzanine loans, all or a portion of which may be secured. The Funds may also provide financing to companies or other entities and subsequently create senior debt held by a third-party and mezzanine debt held by the Funds, or some other combination thereof. Mezzanine loans or facilities may, but often will not, benefit from the same or similar financial terms and other covenants as those provided to more senior indebtedness. The ability of the Funds to influence a borrower’s affairs, particularly during periods of financial distress or following insolvency, is likely to be substantially less than those holding more senior obligations. Direct Loans. On occasion, Funds is permitted to provide financing to borrowers that have difficulty obtaining financing from other sources. Deterioration in a borrower’s financial condition and prospects may be accompanied by a decrease in the value of any collateral and a reduced likelihood of the borrower’s repayment and of Castlelake capitalizing on any guarantees it may have obtained from the borrower’s management or other parties. Some direct loans may be subordinated to a senior lender and interest in any collateral would, accordingly, likely be subordinate to another lender’s security interest.

Structuring CLOs. Castlelake has, and is expected to continue to, source certain loans into one or more warehouse facilities (each, the “Warehouse Facility”) and Castlelake has, and expects to continue to securitize Castlelake’s direct or indirect investments (including, for the avoidance of doubt, loans that or are not are a part of a Warehouse Facility), including through the formation of one or more CLOs, while generally retaining some exposure to the performance of these loans. This could involve contributing a pool of assets to a special purpose entity and selling debt interests in such entity on a non-recourse or limited-recourse basis to purchasers. There can be no assurances or guarantees Castlelake will securitize all or any of these assets (including assets that are a part of, or held outside of, a Warehouse Facility) through the formation of one or more CLOs, which may reduce a Fund’s overall exit options and returns and/or have an adverse effect on the ability of a Fund to effectively achieve its investment objective. In the event of a CLO, a Fund will depend on distributions from the CLO’s assets to enable it to make distributions to investors, and the aggregate return on CLO equity securities will depend in part upon the ability of Castlelake to actively manage the related portfolio of the assets of such issuers of one or more CLOs. Furthermore, the ability of a CLO to make distributions will be subject to various limitations, including the terms and covenants of the debt it issues. For example, tests (based on interest coverage or other financial ratios or other criteria) may restrict a Fund’s ability, as holder of a CLO’s equity interests, to receive cash flow from these investments. There is no assurance any such performance tests will be satisfied. Also, a CLO may take actions that delay distributions in order to preserve ratings and to keep the cost of present and future financings lower, or a CLO may be obligated to retain cash or other assets to satisfy overcollateralization requirements commonly provided for holders of such CLO’s debt. As a result, there may be a lag, which could be significant, between the repayment or other realization on a loan or other assets in, and the distribution of cash out of, a CLO, or cash flow may be completely restricted for the life of a CLO. In addition, a decline in the credit quality of any assets in a CLO, declines in the value of any collateral or increases in defaults, among other things, may force a CLO to sell certain assets at a loss, reducing its earnings and, in turn, cash potentially available for distribution to the Funds for distribution. To the extent that any losses are incurred by a CLO in respect of any collateral, such losses will be borne first by the holder of equity interests therein (a portion of the equity of which the Funds are anticipated to hold for at least some period of time). Any equity interests that are in a CLO will not be secured by the assets of such CLO and an equity holder will rank behind all creditors of such CLO. Any such CLO would, in some cases, at least initially, be managed by an affiliate of Castlelake (a “Collateral Manager,” and any CLO managed by the Collateral Manager, an “Affiliated CLO”). A Collateral Manager will receive CLO level compensation for managing the Affiliated CLO. Where a Collateral Manager, the manager, or another Castlelake affiliate receives such compensation, the Funds would not receive any such compensation other than through full or partial offset of the management fee in accordance with the terms of the Offering Documents. There can be no assurances or guarantees that all of the Fund’s assets will be suitable for inclusion in a CLO and such assets may achieve returns less than if such assets were suitable and included in a CLO. Leveraged Nature of CLO Securities. The Funds have made and will indirectly seek to continue to make all or certain investments or divestments in CLOs through the Warehouse Facility or otherwise. The subordination of securities issued by CLOs (and, in particular, of equity (“CLO Equity”) or subordinated debt securities issued by CLOs, which is typically highly leveraged) makes such debt securities issued by CLO issuers (“CLO Debt” and collectively with CLO Equity, “CLO Securities”) a leveraged investment in the assets of the CLO issuer that issued

it. Therefore, changes in the value of such CLO Security would be anticipated to be greater than changes in the value or payment performance of the debt obligations (including without limitation interests in bank loans or bonds acquired by way of a participation or assignment) (each, an “Underlying Asset”) owned by the CLO issuer, which themselves are subject to credit, liquidity, market and interest rate risk. Utilization of leverage is a speculative investment technique and involves certain risks to investors. The indebtedness of a CLO issuer under any notes issued by it will result in interest expense and other costs incurred in connection with such indebtedness that may not fully be covered by proceeds received from the Underlying Assets. Although the use of leverage generally magnifies opportunities for gain by holders of CLO Equity, it also magnifies risk of loss. Returns to the Funds on any holding of a CLO Security will be highly dependent on the amount of such leverage and upon changes in interest rates, delinquencies and losses on the Underlying Assets. As a result, the Funds may receive payments in respect of any investment in a CLO Security that are, in the aggregate, less than the original amount of its investment in such CLO Security. The CLO Securities issued by a CLO issuer may be subordinate to other CLO Securities issued by such CLO issuer and to other creditors of such CLO issuer, whether secured or unsecured and whether known or unknown, including, without limitation, any hedge counterparties. Ability to Purchase Loans on Advantageous Terms, Competition and Supply. A Fund’s success will depend, in part, on the ability of such Fund or its affiliates to source and purchase loans on advantageous terms. In sourcing and purchasing loans, a Fund or its affiliates compete with a broad spectrum of lenders, many of which have substantially greater financial resources and are more well-known than a Fund. Increased competition for, or a diminishment in the available supply of, qualifying loans could result in lower yields on such loans, which could reduce returns to investors. Purchases of Debt on a Secondary Basis. The Funds are permitted to invest in loans acquired on a secondary basis. The Funds are unlikely to be able to negotiate the terms of such debt as part of its acquisition and, as a result, these loans may not include some of the covenants and protections the Funds may generally seek. Even if such covenants and protections are included in the investments held by the Funds, the terms of the loans may provide issuers substantial flexibility in determining compliance with such covenants. In addition, the terms on which loans are traded on the secondary market may represent a combination of the general state of the market for such investments and either favorable or unfavorable assessments of particular investments by the sellers thereof. Loan Participations and Assignments. The Funds are permitted to invest in fixed- and floating-rate loans, which investments generally will be in the form of loan participations and/ or assignments of portions of such loans. Participations and assignments involve special types of risk, including credit risk, interest rate risk, liquidity risk, and the risks of being a lender. Participations in commercial loans may be secured or unsecured. Loan participations typically represent direct participation in a loan to a corporate borrower, and generally are offered by banks, other financial institutions or lending syndicates. When purchasing loan participations, the Funds assume the credit risk associated with the corporate borrower and may assume the credit risk associated with an interposed bank or other financial intermediary and may only be able to enforce its rights through the lender and may assume the credit risk of the lender in addition to the borrower. The

participation interests in which the Funds invest may not be rated by any nationally recognized rating service. Investments in loans through a direct assignment of a financial institution’s interests with respect to the loan may involve additional risks to the Funds. For example, if a loan is foreclosed, the Funds could become part owner of any collateral and would bear the costs and liabilities associated with owning and disposing of the collateral. In addition, it is conceivable that, under legal theories of lender liability, the Funds could be held liable as a co-lender. It is unclear whether loans and other forms of direct indebtedness offer securities laws protections against fraud and misrepresentation. In the absence of definitive regulatory guidance, the Funds rely on Castlelake’s research in an attempt to avoid situations where fraud or misrepresentation could adversely affect the Funds. Structured Finance Transactions and Obligations. The value of certain structured finance and other transactions in which Funds can invest may be particularly sensitive to changes in prevailing interest rates, and the ability of Funds to successfully utilize these instruments may depend in part on Castlelake’s ability to forecast interest rates and other economic data correctly. Structured finance obligations are subject to a number of risks, including but not limited to prepayment risk, credit risk, liquidity risk, market risk, structural risk, legal risk and interest rate risk (which may depend upon any associated hedge agreement providing for the exchange of interest accruing on the security being repackaged into interest stated to be payable on the trust certificates or similar securities). In addition, the performance of a structured finance obligation will be affected by a variety of factors, including the level and timing of payments and recoveries on and the characteristics of the underlying repackaged securities, the quality and cost of the servicer, remoteness of those assets from the originator or transferor and the adequacy of and ability to realize upon any related collateral. Moreover, to the extent Funds invest in non-U.S. debt obligations, they may be subject to additional risks and considerations, including the uncertainties involved in enforcing and collecting debt obligations against sovereign nations, which may be affected by world events, changes in U.S. foreign policy, currency risk and other factors outside of Castlelake’s control. Mortgage-Backed and Asset-Backed Securities. Mortgage-backed securities represent an interest in a pool of mortgages. When market interest rates decline, more mortgages are refinanced, and the securities are paid off earlier than expected. Prepayments may also occur on a scheduled basis or due to foreclosure. When market interest rates increase, the market values of mortgagebacked securities decline. At the same time, however, mortgage refinancing and prepayments slow, which lengthens the effective maturities of these securities. As a result, the negative effect of the rate increase on the market value of mortgage-backed securities is usually more pronounced than it is for certain other types of fixed income securities. Asset backed securities are structured like mortgage-backed securities, but instead of mortgage loans or interests in mortgage loans, the underlying assets may include, but are not limited to, such items as motor vehicle installment sales or installment loan contracts, leases of various types of real and personal property, and receivables from credit card agreements. The ability of an issuer of asset-backed securities to enforce its security interest in the underlying assets may be limited, and such securities are subject to many of the same risks as mortgage-backed securities.

Asset-backed securities are also subject to risks associated with their structure and the nature of the assets underlying the security and the servicing of those assets. Payment of interest and repayment of principal on asset-backed securities is largely dependent upon the cash flows generated by the assets backing the securities and, in certain cases, supported by letters of credit, surety bonds or other credit enhancements. The values of asset-backed securities may be substantially dependent on the servicing of the underlying asset pools and are therefore subject to risks associated with the negligence by, or defalcation of, their servicers. Furthermore, debtors may be entitled to the protection of a number of state and federal consumer credit laws with respect to the assets underlying these securities, which may give the debtor the right to avoid or reduce payment. In addition, due to their often-complicated structures, various asset-backed securities may be difficult to value. Mortgage Servicing Rights. The Fund will invest in undervalued and distressed assets, which may include financial assets such as mortgage servicing rights. The value of mortgage servicing rights can be volatile. Changes in interest rates or prepayment speeds could negatively impact the value of mortgage servicing rights. Mortgage servicing rights carry interest rate risk because the total amount of servicing fees earned, as well as changes in fair-market value, fluctuate based on expected loan prepayments (affecting the expected average life of a portfolio of residential mortgage servicing rights). The rate of prepayment of residential mortgage loans may be influenced by changing national and regional economic trends, such as recessions or stagnating real estate markets, as well as the difference between interest rates on existing residential mortgage loans relative to prevailing residential mortgage rates. During periods of declining interest rates, many residential borrowers refinance their mortgage loans. Changes in prepayment rates are therefore difficult for us to predict. The loan administration fee income (related to the residential mortgage loan servicing rights corresponding to a mortgage loan) decreases as mortgage loans are prepaid. Consequently, in the event of an increase in prepayment rates, Castlelake would expect the fair value of portfolios of residential mortgage loan servicing rights to decrease along with the amount of loan administration income received. Further mortgage servicing rights requirements may change and require the Fund to incur additional costs, expenses and risks. The U.S. Consumer Financial Protection Bureau (the “CFPB”) and the bank regulators continue to bring enforcement actions and develop proposals, rules and practices that could increase the costs of providing mortgage servicing. Regulation of mortgage servicing could make it more difficult and costly to timely realize the value of collateral securing such loans upon a borrower default. Tenant Protection and Affordable Housing. Affordable housing and tenant protection regulations may limit the Fund’s ability to increase rents and pass through new or increased operating expenses to tenants. Certain states and municipalities have adopted laws and regulations imposing restrictions on the timing or amount of rent increases and other tenant protections. The Funds may operate and acquire assets in areas that either are subject to these types of laws or regulations or where such laws or regulations may be enacted in the future. Such laws and regulations limit the Fund’s ability to charge market rents, increase rents, evict tenants or recover increases in operating expenses and could make it more difficult for the Fund to dispose of assets in certain circumstances.

The Fund is permitted to own debt or equity interests in affordable housing communities and other properties that benefit from governmental programs intended to provide housing to individuals with low or moderate incomes. These programs, which are typically administered by the United States Department of Housing and Urban Development (“HUD”) or state housing finance agencies, typically provide mortgage insurance, favorable financing terms, tax credits or rental assistance payments to property owners. As a condition of the receipt of assistance under these programs, the properties must comply with various requirements, which typically limit rents to pre-approved amounts and impose restrictions on resident incomes. Failure to comply with these requirements and restrictions may result in financial penalties or loss of benefits. In addition, the Fund or its affiliate will typically need to obtain the approval of HUD in order to acquire or dispose of a significant interest in or manage a HUD-assisted property. Warrants. The Fund could receive warrants, and in certain circumstances prior to exit, may be required to exercise such warrants in order to hold the underlying securities. Warrants generally give the holder the right to receive, upon exercise, a security of the issuer at a stated price. Risks associated with the use of warrants and rights are generally similar to risks associated with the use of options. Unlike most options, however, warrants and rights are issued in specific amounts, and warrants generally have longer terms than options. Warrants and rights are not likely to be as liquid as exchange-traded options backed by a recognized clearing agency. In addition, the terms of warrants may limit the Fund’s ability to exercise the warrants at such time, or in such quantities, as the Fund would otherwise wish. The Fund would seek to negotiate “cashless” exercise for all warrants that it receives, whereby no investment will be required to convert, however, on occasions it may not be possible to negotiate such “cashless” exercise, and the Fund may be required to invest cash to convert warrants and hold underlying securities, which may subsequently lose some or all of their value. Consumer Credit. Accounts are permitted to invest in consumer credit, such as consumer loans, including credit card receivables and similar assets, automobile loans, student loans, small balance installment loans or other loans. The performance of such assets or loans will be affected by general economic conditions and conditions impacting the individual underlying borrowers including but not limited to interest rates (including any caps that could be imposed on credit card interest rates), unemployment levels, gasoline prices, upward adjustments in monthly mortgage payments, the rate of inflation, consumer perceptions of economic conditions generally and changes in consumer confidence levels, as well as the quality and cost of the servicer. By its nature, lending to consumers also carries with it different risks and typically a higher risk of consistent loss than commercial lending. Although the net interest margins are intended to be higher to compensate the Accounts for this increased risk, an economic downturn could result in higher loss rates and lower returns than expected and could affect the profitability of Castlelake’s consumer loan portfolios. During periods of economic slowdown, delinquencies, defaults, repossessions, and losses generally increase, and consumers may reduce their discretionary spending in areas such as recreation and home improvement, which could adversely affect the Accounts. These periods have been, and may continue to be, accompanied by increasing unemployment rates and declining values of consumer products securing outstanding accounts, which weaken collateral coverage and increase the amount of a loss in the event of default.

These loans are also subject to risks of prepayment, delinquency and default similar to those present in mortgage loans. The ability of a borrower to repay any such loan is dependent on a number of factors, including, among other things, the income and assets of the borrower. Accounts may invest in consumer loans that have been made to borrowers of varying creditworthiness, have been extended pursuant to varying underwriting guidelines, have no underwriting guidelines at all, or have been subject to fraudulent origination practices. Risks specific to different categories of consumer loans may affect the Accounts’ return on such investments. In the case of credit card loans, for example, various and unpredictable social, economic and geographic factors may affect the payment patterns and rates of default by borrowers, including consumer confidence and attitudes toward debt, rates of inflation and unemployment and prevailing interest rates. Rates of prepayment and default on consumer loans will similarly vary based on a number of factors but will also be affected by contractual terms present in such loans, including the extension of grace periods, deferment periods and, under some circumstances, forbearance periods. The actual rates of delinquencies, defaults, repossessions, and losses on these loans could be more dramatically affected by a general economic downturn. During an economic slow-down or recession, the Accounts’ servicing costs may increase without a corresponding increase in net interest income. Castlelake cannot predict how these, and other factors may affect the Accounts’ investments in consumer loans. In addition, the risk of recession, higher gasoline prices, volatile real estate values and market conditions, resets of adjustable rate mortgages to higher interest rates, increases in inflation, general availability of consumer credit, or other factors that impact consumer confidence or disposable income, could increase loss frequency and decrease consumer demand, particularly in the case of loans that are secured by rapidly depreciable assets, such as automobiles, or loans that are unsecured, as well as weaken collateral values on certain types of consumer products. In these cases, the Accounts face the risk that any collateral for a defaulted loan may not provide an adequate source of repayment of the outstanding loan balance. Thus, the recovery and sale of such property could be insufficient to compensate the Accounts for the principal and interest outstanding on these loans. Any decrease in consumer demand for those products could also have a material adverse effect on Castlelake’s ability to originate new loans and, accordingly, on the Accounts, financial condition, and results of operations. In addition, because loan applications may be completed by third parties, the Accounts assume the risks associated with that third-party properly complying with U.S. federal, state, and local or other applicable domestic or foreign consumer protection laws. It may become necessary to increase the Accounts’ provision for loan losses in the event that the Accounts’ losses on consumer loans increase, which would reduce the Accounts’ profits. Although declines in commodity prices, and more particularly gasoline prices, generally are financially beneficial to the individual consumer, these declines may also have a negative impact on unemployment rates in geographic areas that are highly dependent upon the oil and natural gas industry, which could adversely affect the credit quality of consumers in those areas. Renewable Energy. The highly cyclical nature of the industries within the energy sector may lead to volatile changes in energy prices, which may adversely affect the earnings of renewable energy related assets in which the Funds may invest and the performance and valuation of such investments. The performance of such investments may be substantially dependent upon the prevailing prices of oil and natural gas. As energy derived from fossil fuels becomes more

expensive, the value of such investments and renewable technologies generally should increase as well. Conversely, if new oil or gas deposits are found, or if the cost of producing energy from these or other potential sources decreases significantly for other reasons, the attractiveness of the Funds’ renewable investments would likely decrease. In addition, decreases in the retail prices of electricity from utilities or from other energy sources could decrease demand for renewable energy. •

Equipment and Supply Risk. The vast majority of the capital expenditure of a renewable energy project comes from procurement of the generation equipment and the construction of the facility. Therefore, the underlying agreements for the purchase of the generation equipment and the construction services are critical and if vendor performance under these contracts does not proceed as anticipated, one or more of the Funds’ investments may be adversely affected. In addition, a decrease in the production or availability of requisite supplies, including solar photovoltaic equipment, wind turbines and other relevant materials and equipment could interfere with renewable energy investments dependent on such supplies and thus adversely affect the returns of the Fund.

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Regulation of Wind and Solar Industries. The wind and solar energy industries targeted for investments by the Funds are highly regulated, both by domestic and foreign governmental agencies. In addition, U.S federal, state and local and certain foreign government regulations and policies concerning the electric utility industry, and internal policies and regulations promulgated by electric utilities, heavily influence the market for electricity generation products and services. Currently, U.S. federal, state and local and certain foreign governments provide incentives to end users, distributors and manufacturers to promote wind and solar electricity in the form of rebates, tax credits and other financial incentives such as system performance payments and payments for renewable energy credits associated with renewable energy generation. These incentives could expire on a particular date, end when the allocated funding is exhausted or be reduced or terminated without warning as wind and solar energy adoption rates increase, which could result in a significant reduction in the potential demand for renewable energy systems, including wind and solar energy projects.

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Solar Power. The Funds may invest in portfolio investments that develop and operate solar power products, which face a variety of risks. Materials and components used to develop solar power products are often procured from a limited number of third-party suppliers. A failure to develop or maintain relationships with these or other suppliers may lead to higher costs and delays, leading to order cancellations and loss of market share. Moreover, these portfolio investments often expect to derive their revenues from new solar power products that are still under development and not commercially available. There is a risk that these portfolio investments will not be able to recover losses incurred to develop these products and technologies and become profitable. In addition, to refine technology and develop and introduce new solar power products could cause products to become uncompetitive or obsolete, causing sales to decline. Widespread adoption or sufficient demand for solar power products could take longer to develop than anticipated, which would also cause a lack of profitability. These investments also face intense competition in a market that is rapidly evolving, and there is a possibility that competitors will attract and retain more

customers and achieve more success in cost-cutting and will establish a market position that is more prominent. •

Wind Power. The Funds may invest in portfolio investments that will be engaged in the development and operation of wind farms. The development of a wind farm can require substantial initial capital investments, and there are significant risks related to the development of wind farms, including: (i) the availability of favorable government tax and other incentives; (ii) the high cost and potential regulatory and technical difficulties in integrating into new markets; (iii) an often limited or unstable marketplace; (iv) competition from other sources of electric power and other wind farms; (v) regulatory difficulties including obtaining necessary permits; difficulties in negotiating satisfactory turbine supply, engineering and construction agreements and with respect to connecting to the existing electricity transmission network; (vi) difficulties in negotiating power purchase agreements with potential customers, educating the market regarding the reliability and benefits of wind energy products and services; and (vii) costs associated with environmental regulatory compliance.

Project Finance. Some of the Funds’ investments may be in structured project finance opportunities. A project finance structure entails the assumption of “project risk” by equity investors such as the Fund, usually without recourse to a project sponsor. Such risk can include construction risk, regulatory risk, operating and technical risks, bypass risk, demand, usage and patronage risks, catastrophic and force majeure risks, risk of environment liabilities, documentation risks and commodity price risks. The Fund may also invest in some projects and facilities at an early stage of development. These projects involve additional uncertainties, including the possibility that the projects may not be completed, operating licenses may not be obtained, and permanent financing may be unavailable. Loan Participations and Assignments. Funds may invest in fixed- and floating-rate loans, which investments generally will be in the form of loan participations and assignments of portions of such loans. Participations and assignments involve special types of risk, including credit risk, interest rate risk, liquidity risk, and the risks of being a lender. Participations in commercial loans may be secured or unsecured. Loan participations typically represent direct participation in a loan to a corporate borrower, and generally are offered by banks, other financial institutions or lending syndicates. When purchasing loan participations, Funds: (i) assume the credit risk associated with the corporate borrower; (ii) may assume the credit risk associated with an interposed bank or other financial intermediary; (iii) may only be able to enforce its rights through the lender; and (iv) may assume the credit risk of the lender in addition to the borrower. The participation interests in which the Fund invests may not be rated by any nationally recognized rating service. Investments in loans through a direct assignment of a financial institution’s interests with respect to the loan may involve additional risks to Funds. For example, if a loan is foreclosed, the Funds could become part owner of any collateral, and would bear the costs and liabilities associated with owning and disposing of the collateral. In addition, it is conceivable that, under legal theories of lender liability, the Funds could be held liable as a co-lender.

Currency Risk Relating to Companion Funds. The Accounts’ investments and the income received with respect to such investments, may be denominated in various currencies. However, the books of the Accounts are generally maintained, and capital contributions to and distributions from the Accounts will be made, in U.S. dollars. Accordingly, fluctuations in currency values could adversely affect the U.S. dollar value or other currency value, as applicable, of portfolio investments, interest, dividends and other revenue streams received by the Accounts, gains and losses realized on the sale of portfolio investments and the number of distributions, if any, to be made by the Accounts. Currencies of some countries in which the Accounts invest are often subject to government intervention, restrictions on repatriation and similar restrictions, which exacerbates the risk of unexpected fluctuations and/or could cause the Accounts and/or investments to incur significant costs or experience substantial delays in, or be prohibited from, converting currencies. If Castlelake offers an Account denominated in a currency other than U.S. dollars, then similar risks will apply with respect to such currency. In addition, the Accounts will incur costs in converting investment proceeds from one currency to another to the extent investments are made in a currency other than the currency of such Account. Where practicable, the Accounts might enter into hedging transactions designed to reduce such currency risks. Furthermore, the portfolio investments in which the Accounts invest could in many cases be subject to risks relating to changes in currency values, as described above. If a portfolio investment suffers adverse consequences as a result of such changes, the Accounts likely would also be adversely affected as a result. Furthermore, investments will be allocated among participating Accounts by Castlelake in accordance with its allocation of investments policy and/or Offering Documents, and to the extent different Accounts are denominated in different currencies, the portion of any investment allocated among such Accounts may differ materially based on exchange rates at the time of investment allocation. Also, if a Fund provides bridge financing attributable to an investment amount expected to be syndicated to another Fund or third-party, the amount ultimately syndicated will depend on exchange rates as of the date of syndication, which may result in either more or less of an investment being permanently held by the relevant Fund. Bridge Financings. Certain Funds are permitted to provide interim financing to facilitate an investment on a short-term, unsecured basis in anticipation of a future issuance of equity or long-term debt securities or other refinancing or syndication (including for co-investments or other Funds). Such bridge loans would typically be convertible into a more permanent, long-term security; however, for reasons not always within the Funds’ control, such long-term securities may not be issued, or refinancing or syndication may not occur, and such bridge loans may remain outstanding with an increased risk of default. In such event, the interest rate on such loans may not adequately reflect the risk associated with the unsecured position taken by the Funds, and such loans may cause the Funds to have increased concentration in the given investment. To the extent a Fund provides bridge financing to facilitate portfolio investments, it is possible that all or a portion of such bridge financing will not be recouped within the time period specified in the applicable Offering Documents, in which case the investment would be treated as a permanent investment of the Fund. As a result, the Fund’s portfolio could become more concentrated with respect to such investment than initially expected or otherwise provided for under the Fund’s investment limitations, certain of which exclude bridge financing investments.

A Fund could also be compelled to sell a portion of the excess investment to other parties at unattractive prices if the co-investor or other Funds do not also invest as expected. Non-Controlling Investments. Although Castlelake will typically seek to have control rights with respect to its investments, the Funds may make non-controlling investments and, therefore, may have a limited ability to protect its investments. The Funds may hold meaningful minority stakes in investments and in some cases may have limited minority protection rights. In addition, during the process of exiting investments, the Funds at times may hold minority equity stakes of any size such as might occur if portfolio investments are taken public. As is the case with minority holdings in general, such minority stakes that the Funds may hold will have neither the control characteristics of majority stakes nor the valuation premiums accorded majority or controlling stakes. Funds may seek to protect their interests or influence company management by negotiating the right to appoint a director or by obtaining certain other minority investor rights. Board service and some minority rights provisions may affect the Funds’ ability to dispose of such an investment. Where the Funds hold a minority stake, it may be more difficult for the Funds to liquidate their respective interests than it would be had the Funds owned a controlling interest in such investment. Even if the Funds have contractual rights to seek liquidity of the Funds’ minority interests in such investments, it may be very difficult to sell such interests or seek a sale of such investment upon terms acceptable to the Funds, especially in cases where the interests of the other investors in such investment have different business and investment objectives and goals. Controlling Interests. Because of equity ownership in certain companies, representation on the board of directors and/or contractual rights (if applicable), Funds may control, participate in the management of or influence substantially the conduct of portfolio companies. The exercise of control over a company imposes additional risks of liability for environmental damage, products, benefits, failure to supervise management, violation of laws and regulations, for which the limited liability generally afforded to investors may be ignored. The exercise of control may also subject Castlelake to claims from third parties, including minority investors of such company. In general, the Funds bear the costs of such claims and generally indemnify Castlelake parties when acting on behalf of the Funds. Investment in Junior Securities. The securities in which the Fund will invest may be among the most junior in a portfolio investment’s capital structure and, thus, subject to the greatest risk of loss. Generally, there will be no collateral to protect the Fund’s investment once made. Joint Venture Arrangements. The Funds are permitted to enter joint venture arrangements in which Castlelake does not retain all decision-making authority. In the event of such joint venture arrangement, Castlelake will seek to negotiate appropriate rights to protect Fund interests, although there can be no assurance that such rights will be available or that such rights will provide sufficient protection of Fund rights or interests. Such an investment may involve risks not present in investments where a third-party is not involved, including the possibility that the joint venture partner may be unable or unwilling to perform its duties or obligations under the relevant agreement, may have financial, legal or regulatory difficulties resulting in a negative impact on the joint venture, may have economic or business interests or goals which are inconsistent with those of the Fund, or may be in a position to take (or block) action in a manner contrary to the Fund’s investment objectives. In addition, the increased possibility of default by, diminished liquidity or insolvency of, the joint venture partner, due to a sustained or general economic

downturn (including in the event of default on its funding obligations, the Fund may have to make up for the shortfall) and the possibility that the Fund may be liable for the actions of its joint venture partner in certain circumstances. Any joint venture arrangements open up the Funds to potential increased reputational issues. In-House Asset Servicing Team. Servicing with respect to certain Fund assets is expected to be performed in-house by Castlelake employees or affiliates (including a Platform Servicing Company (as defined in Service Company Fees section)), and such services will relate to assets held through various investment structures, including, without limitation, any warehouse facility, CLO, private securitization, or other debt structure. In some instances, some of the loans held in the Fund’s portfolios could be originated or otherwise sourced by Castlelake or its affiliates (including a Platform Servicing Company), and/or Castlelake or an affiliate (including a Platform Servicing Company) could serve as administrative agent for the loans. In such cases, Castlelake and/or its affiliates are expected to perform the duties and responsibilities typically assigned to an administrative agent for and on behalf of each loan; apply the terms of each credit agreement; and have no authority to determine how cash is used, allocated or disbursed. Although Castlelake seeks to recruit and retain talented and skilled employees, there can be no assurance that Castlelake currently has, or will in the future be able to attract, train, develop, integrate or retain, suitable employees with the skills required to provide such servicing, and, as a result, the Fund may be adversely affected thereby. Qualified personnel, in particular technical aviation servicing professionals, are in great demand throughout the aviation industry. Competitors and other entities may attempt to recruit Castlelake’s employees. The loss of such personnel, the inability to identify, attract or retain qualified personnel, particularly technical aviation servicing professionals, in the future or delays in hiring qualified personnel may make it difficult for Castlelake to manage the Fund and its assets. Moreover, Castlelake’s servicing team may provide other services regarding investments where it is possible that other servicers or third parties have more experience so there is no guarantee that such services provided by Castlelake will be comparable to that which could be provided by one or more third parties. Although Castlelake believes that its aviation in-house servicing team differentiates Castlelake, one or more competitors may establish a dedicated servicing platform which may, now or in the future, be able to replicate Castlelake’s model, partially or entirely, on a more efficient and effective basis. Competitors seeking to develop similar in-house services could also hire Castlelake’s key employees. Such third parties may compete with the Fund for investment opportunities. Castlelake relies on trade secret and other similar laws and confidentiality agreements with employees and third parties to protect its proprietary aircraft and portfolio modeling approach, all of which offer only limited protection. Castlelake’s intellectual property rights may be invalidated, or competitors may develop a similar portfolio modeling approach independently. Legal proceedings to enforce Castlelake’s intellectual property rights may be unsuccessful and could also be expensive and divert management’s attention.

Asset Servicers. In addition, the Funds are permitted to enter into arrangements with industry specialized management or advisory teams (which may include joint venture partners) to acquire, manage and dispose of certain assets (such as consumer receivables, real estate and shipping assets), which can include fixed payments and/or profit-sharing arrangements with such persons, thus impacting the returns to the Funds. The failure on the part of Castlelake to select or retain the right management or advisory team for an asset class and/or to establish a governance and compensation structure that provides for the appropriate balance of economic incentives to the team and oversight by Castlelake, or to provide servicing with respect to certain assets (including securitizations) on its own, would have a material adverse effect on the Funds’ investment in such asset class. Reliance on Key Personnel. Control over the operation of the Funds, including decisions with respect to structuring, negotiating, purchasing, financing and divesting investments, will be vested with Castlelake, and limited partners generally have no right or power to take part in the management of the Funds. Consequently, limited partners will be relying on the ability of the relevant General Partner to locate and evaluate the investments to be made by the Fund. The success of the Funds will depend in large part on the skill and expertise of Castlelake’s investment professionals and other personnel. There can be no assurance that such personnel will continue to be associated with or remain in the same roles at Castlelake, and a loss of the services of any such personnel for any reason and for any period of time could impair Castlelake’s ability to implement its investment program or avoid losses. In light of ever increasing competition among alternative asset firms, financial institutions, fund sponsors and other industry participants (including portfolio companies) for hiring and retaining qualified personnel, there can be no assurance that any personnel will continue to be associated with, or remain in the same roles, at Castlelake. With respect to an open-ended Fund, some investors have redemption rights during the initial closing period (as defined in such Fund’s Offering Documents). If certain key personnel depart, it would further exacerbate the adverse effect of such events. Leverage. Castlelake has used leverage for certain purposes in managing the Funds (including entering into a subscription facility during the initial closing period and a net-assetvalue-based borrowing facility thereafter). Leverage generally magnifies both the applicable Fund’s opportunities for gain and its risk of loss from a particular investment. The cost and availability of leverage is highly dependent on the state of the broader credit markets, which state is difficult to accurately forecast, and at times it could be difficult to obtain or maintain the desired degree of leverage. The use of leverage will also result in interest expense and other costs to the Funds that could not be covered by distributions made to the Funds or appreciation of their investments. The lenders that provide financing to the Funds’ investments could apply discretionary covenants or repayment obligations, which, if not met, could result in loss of financing and forced liquidations of investments at disadvantageous prices. Such discretionary covenants or repayment obligations could also impair the applicable Fund’s ability to finance future operations and capital needs. Because the Funds’ investments will include securities of companies with leveraged capital structures and because unlimited non-recourse leverage can be used in connection with acquisition of investments, such investments will be subject to increased exposure to adverse economic factors such as an increase in interest rates, competitive pressures, a downturn in the economy or further deterioration in the economic conditions of such investment or its industry and could accelerate

and magnify declines in the value of the applicable Fund’s leveraged investments in a down market. Similarly, in the event that any investment of the Funds cannot generate sufficient cash flow to meet principal and interest payments on their indebtedness, the value of the Funds’ investment in such an entity could be significantly reduced or even eliminated due to further credit deterioration. Furthermore, should the credit markets be tight at the time a Fund determines that it is desirable to sell all or a part of a portfolio investment, the relevant Fund could not achieve an exit multiple or enterprise valuation consistent with its forecasts. Subscription Lines. Castlelake’s Funds generally enter into subscription line credit agreements with one or more lenders in order to finance investments and to pay Fund expenses. For administrative convenience and cash and liquidity management, capital calls, including those used to pay interest or principal on subscription lines, asset-backed facilities and other indebtedness, may be “batched” together into larger, less frequent capital calls, with a Fund’s interim capital needs being satisfied by such subscription line credit agreements. Fund-level borrowing subjects investors to certain risks and costs. For example, because amounts borrowed under a subscription line typically are secured by pledges of Castlelake’s right to call capital from the investors, investors may be obligated to contribute capital on an accelerated basis if the Fund fails to repay the amounts borrowed under a subscription line or experiences an event of default thereunder. Moreover, any limited partner or investor claim against the Fund would likely be subordinate to the Fund’s obligations to a subscription line’s creditors. In addition, Fund-level borrowing will result in incremental expenses that will be borne by investors. These expenses typically include interest on the amounts borrowed, unused commitment fees on the committed but unfunded portion of a subscription line, an upfront fee for establishing a subscription line, and other one-time and recurring fees and/or expenses, as well as legal fees relating to the establishment and negotiation of the terms of the borrowing facility. Because a subscription line’s interest rate is based in part on the creditworthiness of the relevant Fund’s investors and the terms of the Offering Documents, it may be higher than the interest rate a limited partner or investor could obtain individually. To the extent a particular investor’s cost of capital is lower than the Fund’s cost of borrowing, Fund-level borrowing can negatively impact an investor’s overall individual financial returns even if it increases the Fund’s reported net returns in certain methods of calculation. Interest will accrue on subscription lines at a rate lower than the preferred return of a Fund. Where a preferred return begins to accrue after capital contributions are due (regardless of when a Fund borrows, makes the relevant investment, or pays expenses) and ceases to accrue upon return of these capital contributions, the use of borrowing to shorten the period between calling and returning capital limits the amount of time the preferred return will accrue. In circumstances where there is not a preferred return on funds borrowed in advance or in lieu of calling capital, Fundlevel borrowing typically will reduce the amount of preferred return to which investors would otherwise be entitled had capital been called, and thus could result in Castlelake receiving Carried Interest sooner than it would without borrowing. As a general matter, use of leverage in lieu of drawing down commitments enhances internal rates of return (either negative or positive) to investors in a Fund. In light of the foregoing, Castlelake has an incentive to fund the acquisition and ongoing capital needs of investments and the Funds with the proceeds of such borrowings in lieu of drawing down commitments on a just-in-time basis.

In addition, when the management fee is calculated as a percentage of invested capital, an investor would generally pay management fees on borrowed amounts used to fund investments that have not yet been realized even though such amounts would not accrue preferred return as described above. Therefore, Castlelake generally earns a management fee whether it calls capital to fund an investment or uses the subscription line without calling capital. It is expected that the costs relating to the establishment and/or maintenance of a subscription line of credit will be significant, and there can be no assurance that the benefits to investors will be commensurate with such costs. A credit agreement may contain other terms that restrict the activities of a Fund and the investors or impose additional obligations on them. For example, a subscription line may impose restrictions on Castlelake’s ability to consent to the transfer of an investor’s interest in the Fund. In addition, in order to secure a subscription line, Castlelake may request certain financial information and other documentation from investors to share with lenders. Castlelake will have significant discretion in negotiating the terms of any subscription line and may agree to terms that are not the most favorable to one or more investors. Fund-level borrowing involves a number of additional risks. For example, drawing down on a subscription line allows Castlelake to fund investments and pay expenses without calling capital, potentially for extended periods of time. Calling a large amount of capital at once to repay the-then current amount outstanding under a subscription line could cause short-term liquidity concerns for investors that would not arise had Castlelake called smaller amounts of capital incrementally over time as needed by a Fund. This risk would be heightened for an investor with commitments to other funds that employ similar borrowing strategies or with respect to other leveraged assets in its portfolio; a single market event could trigger simultaneous capital calls, requiring the investor to meet the accumulated, larger capital calls at the same time. A Fund may also utilize Fund-level borrowing when Castlelake expects to repay the amount outstanding through means other than investor capital, including as a bridge for equity or debt capital with respect to an investment. If the Fund ultimately is unable to repay the borrowings through those other means, investors would end up with increased exposure to the underlying investment, which could result in greater losses. Investment and Intermediate Entity-Level Borrowing; NAV Facilities. In addition to fundlevel borrowing, Castlelake may cause an Account to enter into credit facilities secured in whole or in part by any or all the Account’s assets, including portfolio investments or distributions in respect thereof (a “NAV Facility”). A NAV Facility subjects investors to certain risks and costs, including many of those discussed in “Leverage” and “Subscription Lines” above. In connection with establishing a NAV Facility, Castlelake has authority to pledge all or certain of an Account’s portfolio investments (including economic rights in respect of those investments and the deposit accounts into which proceeds from those investments are deposited), including on a crosscollateralized basis, without taking into account the potential for non-pro rata investments by investors as a result of any particular investor’s excuse or other rights. Therefore, an investor could be required to fund amounts to repay borrowings incurred in connection with a NAV Facility related to an investment that such investor does not participate in and an investment that such investor does not participate in could cause a default under, or otherwise negatively impact such Account’s ability to utilize, any such NAV Facility.

With respect to any NAV facility entered into or guaranteed by an Account (or an affiliate thereof), a decrease in the market value of such Account’s investments securing such NAV Facility would increase the effective amount of leverage and could result in the possibility of a violation of certain financial covenants pursuant to which such Account must either repay the borrowed funds to the lender, which could, subject to any limitations set forth in such Account’s Offering Documents require investors to make additional capital contributions in respect of such borrowings, or suffer foreclosure or forced liquidation of the pledged or charged assets. Foreclosure or liquidation of an Account’s investments at an inopportune time in order to satisfy such financial covenants could adversely impact the performance of the Fund and could, if the value of its investments had declined significantly, cause the Fund to lose all or a substantial amount of its capital. Moreover, if additional capital contributions were required to satisfy such financial covenants, this would effectively reduce the amount of capital available for other investments and could adversely affect the diversification of an Account’s portfolio. In the event of a sudden, precipitous drop in the value of an Account’s assets, the Fund might not be able to dispose of assets quickly enough to meet its margin requirements (if any) or pay off its debt, resulting in a foreclosure or other total loss of some or all of the pledged or charged assets. Risks may increase due to the nature of an Account’s underlying portfolio investments, concentration, expected volatility and other factors. An Account may utilize a NAV Facility that is structured with a newly created intermediate entity acting as the borrower and holding, indirectly or directly, investment interests of the Fund. Such facility may be secured by the intermediate entity borrower’s interests in the underlying investments and/or in the distributions payable to the intermediate entity borrower in respect thereof. The Fund may be required to provide credit support for the obligations of the intermediate entity borrower, either by giving a full recourse guarantee or on a limited- or non-recourse basis. As such, there is a risk that any exercise of foreclosure remedies on any pledged equity interests or underlying investment interests could result in a total loss by such Account of such investments. Potential Restrictive Covenants. The Funds may enter into credit facilities with one or more lenders in order to finance their operations (including the acquisition of investments) and the Funds’ subsidiaries and investments are permitted to enter into various other financing arrangements and other transactional agreements. These financing arrangements will contain a number of common covenants that, among other things, might restrict the ability of the Funds and their subsidiaries and investments to: (i) acquire or dispose of assets or businesses; (ii) incur additional indebtedness; (iii) make expenditures, distributions or capital calls; create liens on assets; (iv) enter into leases, investments or acquisitions; (v) consent to transfers; (vi) restrict the use of information; (vii) make amendments to the Offering Documents; or (viii) engage in certain transactions with affiliates, and otherwise restrict activities of the Funds and investments without the consent of the lenders or other counterparties. In addition, these financing arrangements can require the Funds and their subsidiaries and investments to maintain specified financial ratios and comply with tests, including minimum interest coverage ratios, maximum leverage ratios, minimum net worth and minimum equity capitalization requirements. For credit facilities or other agreements in which multiple Funds are permitted as co-borrowers, a default by one Fund or the inability by one Fund meet applicable covenants or ratios would limit the activities and have other adverse consequences on the other Funds, including triggering cross-default provisions.

Risks Associated with Bankruptcy Cases. Investment and lending activities, particularly involving companies in distressed situations, may result in the Fund becoming involved as a creditor in bankruptcy cases. In addition, the Funds may purchase securities or assets of, or claims against, companies in bankruptcy. Many of the events within a bankruptcy case are adversarial and often beyond the control of the creditors. Generally, the duration of a bankruptcy case can only be roughly estimated. This process can involve substantial legal, professional and administrative costs to investors; it is subject to unpredictable and lengthy delays; and during the process the company’s competitive position may erode, key management may depart, and the company may not be able to reorganize and may be required to liquidate assets. Upon a bankruptcy filing by an issuer of debt, the U.S. Bankruptcy Code imposes an automatic stay on payments of its pre-petition debt. The debt of companies in financial reorganization will in most cases not pay current interest, may not accrue interest during the reorganization and may be adversely affected by an erosion of the issuer’s fundamental value. If an issuer were to seek relief under chapter 11 of the Bankruptcy Code, the Bankruptcy Code authorizes the issuer to restructure the terms of repayment of a class of debt even if the class fails to accept the restructuring as long as the restructured terms are “fair and equitable” to the class and certain other conditions are met. There exists a significant risk that Castlelake’s influence with respect to a class of securities can be lost by the inflation of the number and the amount of such claims in, or other gerrymandering of, the class. In addition, certain administrative costs and claims that have priority over the claims of certain creditors (for example, claims for taxes) may be quite high. Similar laws in foreign jurisdictions protect borrowers in similar ways and may often be less favorable to a lender than U.S. laws. Debt Securities. Debt securities are subject to the risk of an issuer’s ability to meet principal and interest payments on the obligation (credit risk) and may also be subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (market risk). With bonds and other fixed income securities, a rise in interest rates typically causes a fall in values, while a fall in interest rates typically causes a rise in values. The risk of debt securities can vary significantly depending upon factors such as the issuer (e.g., investors’ perceptions of the creditworthiness of the issuer, the issuer’s financial performance, perceptions of the issuer in the marketplace, performance of management of the issuer, the issuer’s capital structure and use of financial leverage and demand for the issuer’s goods and services) and maturity. For example, the issuer of a security or the counterparty to a contract may default or otherwise become unable to honor a financial obligation. The debt securities of some companies may be riskier than the stocks of others. Interest Rate Fluctuations. The prices of fixed-income and other portfolio investments tend to be sensitive to interest rate fluctuations and unexpected fluctuations in interest rates could cause the corresponding prices of positions to move in directions which were not initially anticipated. For example, as interest rates rise, the market value of fixed income securities tends to decrease. Conversely, as interest rates fall, the market value of fixed income securities tends to increase. This risk will be greater for long-term securities than for short-term securities. In addition, interest rate increases generally will increase the interest carrying costs to the Fund, including if an investment is levered.

Interest Rate Risk. Credit portfolios are subject to interest rate risks; changes in the prevailing market interest rates could negatively affect the value of Fund investments. The ability of companies or businesses in which Funds may invest to refinance debt instruments or repay debt obligations (including making payments to Funds as a creditor with respect thereto) may depend on their ability to obtain financing. Volatility and instability in the securities market may also increase the risks inherent in the Funds’ investments. Interest rate changes may affect the value of a debt instrument indirectly (especially in the case of fixed rate securities) and directly (especially in the case of instruments whose rates are adjustable). In general, rising interest rates will negatively impact the price of a fixed rate credit instrument and falling interest rates will have a positive effect on price. This risk will be greater for long term securities than for short-term securities. In addition, interest rate increases generally will increase the interest carrying costs to the Fund. Adjustable-rate instruments also react to interest rate changes in a similar manner, although generally to a lesser degree. Adjustable rate instruments carry certain risks not associated with fixed rate credit instruments. Rising interest rates could significantly increase the Funds’ interest expense and/or negatively impact the value of credit instruments or credit-like assets, causing losses and/or the inability to service debt levels. An increase in the interest rate could impair, potentially materially, the Funds’ ability to consummate or profit from investments. Interest rate sensitivity is generally more pronounced and less predictable in instruments with uncertain payment or prepayment schedules. Additional factors that may affect market interest rates include inflation, slow or stagnant economic growth or recession, unemployment, international disorders and instability in domestic and foreign financial markets. The Funds will periodically experience imbalances in their assets and liabilities as a result of changes in interest rates. In a changing interest rate environment, the Funds may not be able to manage this risk effectively. If a Fund is unable to manage interest rate risk effectively, the Fund’s performance could be adversely affected. While Funds may seek to do so, they are not required to hedge interest rate risk. Benchmark Rates. Many financial instruments use or may use a floating rate based on the London Interbank Offered Rate, or “LIBOR,” which is the offered rate for short-term Eurodollar deposits between major international banks. On July 27, 2017, the head of the United Kingdom Financial Conduct Authority announced a desire to phase out the use of LIBOR by the end of 2021. On March 5, 2021, the United Kingdom Financial Conduct Authority formally announced the respective dates for the cessation (or loss of representativeness where a “synthetic” LIBOR continues to be available) for most of the LIBOR benchmark settings published by the ICE Benchmark Administration (with such benchmark settings ceasing publication (or losing representativeness) on December 31, 2021 or June 30, 2023, respectively). The new regulatory powers included in the Financial Services Act 2021 enable the United Kingdom Financial Conduct Authority to, among other things, designate a critical benchmark, such as LIBOR, to direct a methodology change so that, in certain circumstances, such designated benchmark is published on a “synthetic” basis. On June 23, 2021 the United Kingdom Government announced that it intended to legislate to provide the United Kingdom Financial Conduct Authority with further regulatory powers to manage and direct any wind-down period prior to eventual LIBOR cessation, in particular to help deal with “tough legacy” contracts, and that it intends to bring forward further legislation to supplement these measures by reducing the scope for uncertainty or litigation that may arise from the exercise of the powers. On June 24, 2021, the United Kingdom Financial Conduct Authority launched a consultation paper in relation to its proposed decision to use its new

powers to require the ICE Benchmark Administration to continue the publication of certain “synthetic” LIBOR settings, in certain circumstances. There remains uncertainty regarding the impact of the upcoming cessation (or loss of representativeness) of LIBOR and the nature of any replacement rate. As such, the potential effect of a transition away from LIBOR on the Fund or any of the Fund’s investments cannot yet be determined. The upcoming cessation (or loss of representativeness) of LIBOR, or any currency and tenor combination thereof, could have an adverse impact on the Fund. Distressed Securities. The Funds is permitted to purchase, directly or indirectly, securities and other obligations of companies that are experiencing significant financial or business distress or material operating issues, including companies that could have been, are or will become involved in bankruptcy proceedings or other reorganization and liquidation proceedings. Although such purchases could result in significant returns, they involve a substantial degree of risk and may not show any return for a considerable period of time. In fact, many of these securities and investments ordinarily remain unpaid unless and until the company reorganizes and/or emerges from bankruptcy proceedings, and as a result may have to be held for an extended period of time. A wide variety of considerations, including, for example, the possibility of litigation between the participants in a reorganization or liquidation proceeding or a requirement to obtain mandatory or discretionary consents from various governmental authorities or others may affect the value of these securities and investments. The uncertainties inherent in evaluating such investments may be increased by legal and practical considerations which limit the access of Castlelake to reliable and timely information concerning material developments affecting a company, or which cause lengthy delays in the completion of the liquidation or reorganization proceedings. The level of analytical sophistication, both financial and legal, necessary for successful investment in companies experiencing significant business and financial distress is unusually high. There is no assurance that Castlelake will correctly evaluate the nature and magnitude of the various factors that could affect the prospects for a successful reorganization, restructuring, recapitalization, liquidation or similar action. In any reorganization or liquidation proceeding relating to the company in which the Funds invest, the investors may lose their entire investment or may be required to accept cash or securities with a value less, or with rights that are materially different than, than the original investment. Defaulted Securities. The Funds are permitted to invest in the securities of, and trade claims against, companies involved in bankruptcy proceedings, reorganizations and financial restructurings and may have a more active participation in the affairs of the issuer than is generally assumed by an investor. This may subject investors to litigation risks or prevent the investors from disposing of securities. In a bankruptcy or other proceeding, the investors as creditors may be unable to enforce their rights in any collateral or may have security interest in any collateral challenged, disallowed or subordinated to the claims of other creditors. While Castlelake will attempt to avoid taking the types of actions that would lead to equitable subordination (as discussed above) or creditor liability, there can be no assurance that such claims will not be asserted or that the Funds will be able to successfully defend against them. Because other investors may purchase the securities of these companies for the purpose of exercising control or management, the Funds may be at a disadvantage to the extent that the Funds’ interests differ from the interests of these other investors.

Trade and Other General Unsecured Claims. The Funds are permitted to acquire interests in claims of trade creditors and other general unsecured claim holders of a debtor (“trade claims”). Trade claims generally include, but are not limited to, claims of suppliers for goods delivered and not paid, claims for unpaid services rendered, claims for contract rejections and claims related to litigation. Trade claims are typically unsecured and may, in unusual circumstances, be subordinated to other unsecured obligations of the debtor. The repayment of trade claims is subject to significant uncertainties, including potential set-off by the debtor as well as the other uncertainties described herein with respect to other distressed securities. An investment in trade claims and high-risk receivables may also entail special risks including, but not limited to, fraud on the part of the assignor of the trade claim as well as logistical and mechanical issues which may adjust the underlying claim and/or affect the ability to collect the claim in whole or in part. Because of the absence of a regulated market for trade claims and the decreased transparency of pricing information with respect to trade claims (and the resulting difficulties in determining market values for them) as well as the risk that such claims could be disallowed or reduced by the bankruptcy court or treated differently from other forms of debt under the debtor’s plan of reorganization approved by the bankruptcy court, the prices realized on such investments could be less than the price originally paid by the Funds. Trade claims could also be subject to actions during the bankruptcy court proceedings with respect to where they rank in the insolvency waterfall. Such actions could negatively impact the value of the claims and could delay the realization of their value. Trade claims could also be subject to bankruptcy or insolvency proceedings that give priority to some claims over others, which could negatively impact the value of some claims or lead to further litigation, which could itself delay the realization of the value of such claims. Further, because of the absence of a formal market, indices, or regulation of trade claims, trade claims could be illiquid. The purchaser of a trade claim (such as the Funds) could also be subject to actions during the bankruptcy court proceedings, including preference actions and, in certain circumstances, equitable subordination actions, based solely on prior conduct of a seller of such trade claim. Such actions could result in the reduction or disallowance of a trade claim and losses to the purchaser of such claim, and a delay of realization of the value of such trade claim. Further, in the event a seller of a trade claim subsequently becomes insolvent or itself files for bankruptcy or other insolvency protection, the purchaser of such claim might not benefit from any warranties, representations, covenants or indemnities provided by the seller to the purchaser in the purchase documents (including recourse for disallowed claims). In addition, the trade claims markets generally lack standard documentation, which increases settlement risk. Trade claims are also subject to the credit and recovery risk of the bankrupt or insolvent company, as well as the general risks associated with bankruptcy or insolvency cases or proceedings (see “Risks Associated with Bankruptcy Cases” above). In the event these risks materialize with respect to trade claims purchased by a Fund, the applicable Fund could suffer significant losses. The purchaser of a trade claim (such as the applicable Funds) could also be subject to the risk that the seller of a trade claim will fail to deliver upon the terms of the investment. High-Yield Securities. The Funds are permitted to invest in “high-yield” bonds and preferred securities which are rated in the lower rating categories by the various credit rating agencies (or in comparable non-rated securities). Securities in the lower categories are subject to greater risk of loss of principal and interest than higher-rated securities and are generally considered to be greater risk with respect to the issuer’s capacity to pay interest and repay principal. They are also generally considered to be subject to greater risk than securities with higher ratings

in the case of deterioration or general economic conditions. Further, the yields and prices of such securities may tend to fluctuate more than those of higher-rated securities. The market for lowerrated securities is thinner and less active than that for higher-rated securities, which can adversely affect the prices at which they can be sold. In addition, adverse publicity and investor perceptions about lower rated securities, whether or not based on fundamental analysis, could be a contributing factor in a decrease in the value and liquidity of such lower rated securities. Privately Traded Securities and Instruments. Privately traded securities and instruments, including investments in companies undergoing debt restructurings and recapitalized companies, involve a high degree of business and financial risk. Such companies may have highly leveraged capital structures, require substantial additional capital to support expansion or to achieve or maintain a competitive position, produce substantial variations in operating results from period to period or operate at a loss. In addition, such investments may subject the Funds to risks that differ in type or degree from those involved with publicly held investments. Such risks may include, among other things, less liquidity and less transparency. Moreover, there will be no readily available market for such investments, and hence, most of such investments will be difficult to value. Although Castlelake may seek protective provisions, including, possibly, board representation, in connection with certain of its private equity investments, to the extent it takes minority positions in companies in which it invests, Castlelake may not be in a position to exercise control over the management of such companies. Private equity investments may have extended holding periods of several years and there can be no assurance that a viable exit mechanism will be available at the end of the anticipated holding period. Equity Securities. The Fund will make investments in equity securities, which involve a number of significant risks, including the risk of dilution, limited liquidity in the secondary trading market and subordination to debt securities or holders of senior equity securities. The Fund’s investment in equity securities could be subject to dilution as a result of the issuance of additional equity securities. An issuer may issue preferred securities or other classes of common securities with voting and conversion rights which could adversely affect the voting power of the Fund’s equity securities and could reduce the value of the Fund’s equity securities. The issuer could increase the number of equity holders entitled to distributions without simultaneously increasing the size of the issuer’s asset base. If an issuer created and issued preferred securities with a distribution preference over the Fund’s equity securities, payment of any distribution preferences of outstanding preferred securities would reduce the amount of funds available for the payment of distributions on the Fund’s equity securities. An equity investment may fail to appreciate and may decline in value or become worthless, and the Fund’s ability to recover its investment will depend on the issuer’s success. Even if an investment in equity securities is successful, the equity securities may be subject to restrictions on resale during periods in which it could be advantageous to sell them and the Fund’s ability to realize the value of its investment may be dependent on the occurrence of a liquidity event, such as a public offering or the sale of the issuer. In addition, any gains that the Fund realizes on the disposition of any equity interests may not be sufficient to offset any other losses the Fund experiences. The Fund may be unable to recover its investment in the event that the issuer is unable to meet its obligations to holders of debt and other senior securities or becomes subject to a bankruptcy process.

Preferred and Convertible Securities. Investments in preferred and/or convertible equity or debt securities involve special risks, such as the risk of deferred distributions, credit risk, illiquidity and limited voting rights. Preferred securities may permit the issuer to defer distributions for a stated period without any adverse consequences to the issuer. If the Fund owns a preferred security that defers distributions, the Fund may be required to report income for tax purposes before it receives such distributions. Preferred securities are generally subordinated to debt securities in terms of priority to income and liquidation payments and therefore will be subject to greater credit risk than an investment in debt securities. Preferred securities may be substantially less liquid than many other securities, such as common stock. Generally, preferred security holders have no voting rights, subject to limited exceptions (e.g., with respect to matters that would materially and adversely impact the holder of the preferred securities). Hybrid Securities. The Funds may obtain exposure to an issuer or asset by investing in hybrid instruments, which contain characteristics of both a debt security and an equity security. Therefore, hybrid securities are subject to the risks of equity securities and the risks of debt securities. The terms of hybrid instruments may vary substantially, and certain hybrid securities may be subject to similar risks as preferred stocks, such as interest rate risk, issuer risk, dividend risk, call risk and extension risk. The claims of holders of hybrid securities of an issuer are generally subordinated to those of holders of traditional debt securities in bankruptcy, and thus hybrid securities may be more volatile and subject to greater risk than traditional debt securities and may in certain circumstances even be more volatile than traditional equity securities. At the same time, hybrid securities may not fully participate in gains of their issuer and thus potential returns of such securities are generally more limited than traditional equity securities, which would participate in such gains. Hybrid securities may also be more limited in their rights to participate in management decisions of an issuer. Certain hybrid securities may be more thinly traded and less liquid than either publicly issued equity securities or debt securities, especially hybrid securities that are “customized” to meet the needs of particular investors, potentially making it difficult for the Funds to sell such securities at a favorable price or at all. Any of these features could cause a loss in market value of hybrid securities held by the Funds. Derivative Instruments. The Funds are permitted to use a variety of financial instruments, such as derivatives, options, interest rate swaps, caps and floors, futures, and forward contracts and expects to use them for limited hedging purposes, primarily for currency hedging, interest rate hedging, and hedging related to certain types of investments, such as oil and gas prices. In addition, the Funds could lend securities. New derivative instruments and other financial products, and various combinations thereof, continue to be developed, and the Funds could invest in any such instruments and products to the extent they are consistent with the Funds’ investment objectives and applicable regulatory requirements. Such derivative instruments could be volatile and may be subject to wide and sudden fluctuations in market value, with a resulting fluctuation in the amount of profits and losses. The market for derivative instruments could be limited and prevent prompt liquidation of positions, subjecting the Fund to the potential for greater losses. Derivatives could result in incurring synthetic leverage that could magnify the gains and losses experienced by the Funds. Non-exchange traded derivatives can have significant disparities between “bid” and “asked” price, and the Funds could be subject to a credit risk as a result of non-performance by an obligor in a bilateral derivative contract. When used, an imperfect or variable degree of correlation between price movements of the derivative instrument and the underlying investment sought to be

hedged may prevent the Fund from achieving the intended hedging effect or expose the Fund to risk of loss. Use of derivative instruments presents various risks, including the following: •

Tracking - When used for hedging purposes, an imperfect or variable degree of correlation between price movements of the derivative instrument and the underlying investment sought to be hedged may prevent Castlelake from achieving the intended hedging effect or expose the Fund to the risk of loss.

•

Liquidity - The market for derivative instruments may be limited and prevent prompt liquidation of positions, subjecting the Fund to the potential for greater losses.

•

Leverage - Trading in derivative instruments can result in incurring synthetic leverage that may magnify the gains and losses experienced by the Fund.

•

Over-the-Counter (“OTC”) Instruments - Derivative instruments that may be purchased or sold by Castlelake can include instruments not traded on an exchange. OTC options, unlike exchanged traded options, are bilateral contracts with price and other terms negotiated by the buyer and seller. The risk of nonperformance by the obligor on such an instrument may be greater and the ease with which Castlelake can dispose of or enter into closing transactions with respect to such an instrument may be less than in the case of an exchange traded instrument. In some cases, particularly in the context of OTC instruments, hedging arrangements will subject the Fund to the potential loss of assets held by a counterparty, custodian or intermediary in connection with such hedging. OTC contracts may expose the Fund to additional liquidity risks.

•

Counterparty relationship conflicts – Castlelake occasionally enters into and trades, and reserves the right to enter into and trade in the future, derivative instruments, including OTC instruments, for its own account with one or more of the same counterparties as an Account, and vice versa. Where both Castlelake and one or more Accounts have entered into or are negotiating derivative instruments with the same counterparty, conflicts of interest can arise, including with respect to the terms of such instruments and navigating any potential default scenarios (e.g., in light of the applicability of any cross-default provisions), as Castlelake will have an incentive to preserve and optimize its relationship with such counterparty and the value of its own derivative instruments, including potentially by taking actions with respect to one or more Account’s derivative instrument(s).

Furthermore, in connection with a hedging transaction, the Fund may be required to allocate funds or provide a credit line to be used as collateral for the margin capital of the hedge. Such a requirement would tie up a portion of the Fund’s capital that could otherwise have been available for investment. This could cause the Fund to be less invested than it would have been absent such hedging transaction and could possibly result in an adverse effect on the overall returns of the Fund.

Non-U.S. Investments and Currencies. Castlelake invests on a global basis and may invest a significant portion of assets of the Funds in foreign assets, issuers or securities which may be restricted or controlled to varying degrees. This requires consideration of certain risks typically not associated with investing in U.S. assets, issuers or securities. These risks include, among other things, trade balances and imbalances and related economic policies, potential price volatility in, and relative illiquidity of, some non-U.S. markets, unfavorable currency exchange rate fluctuations, potentially unsettled points of applicable governing law, capital repatriation regulations, imposition of exchange control regulation by the U. S. or foreign governments, U.S. and foreign withholding taxes, the application of complex U.S. and non-U.S. tax rules to crossborder investments, possible imposition of non-U.S. taxes on the Funds and/or their investors with respect to the Fund’s income and possible non-U.S. tax return filing requirements for the Funds and/or their investors, limitations on the removal of funds or other assets, policies of governments with respect to possible nationalization of their industries, political difficulties, including expropriation of assets, confiscatory taxation and economic or political instability in foreign nations. Laws and regulations of foreign countries may impose restrictions that would not exist in the United States and may require financing and structuring alternatives that differ significantly from those customarily used in the United States. Additional risks of non-U.S. investments include: (i) differing business cultures and legal regimes; (ii) less liquidity and smaller capitalization of securities markets; (iii) currency exchange rate fluctuations; (iv) higher rates of inflation; (v) controls on, and changes in controls on, foreign investment and limitations on the ability of an Account to exchange local currencies for U.S. dollars; (vi) greater governmental involvement in and control over the economies; (vii) differences in auditing and financial reporting standards, which may result in the unavailability of material information about issuers; (viii) less extensive regulation of the securities markets; (ix) longer settlement periods for securities transactions; (x) differences in tax regimes (including potential withholding obligations on proceeds paid from a Fund) and changes in tax treaties or U.S. tax law regarding foreign investments; (xi) less developed corporate laws regarding fiduciary duties and the protection of investors; (xii) less publicly available information about certain non-U.S. companies and assets than would be the case for comparable companies in the United States; (xiii) less well-developed regulatory institutions; (xiv) greater difficulty of enforcing legal rights in a non-U.S. jurisdiction; (xv) civil disturbances; (xvi) economic dislocations in the host country; (xvii) less publicly available information about certain non-U.S. companies and assets than would be the case for comparable companies in the United States; (xviii) less well-developed regulatory institutions; (xix) greater difficulty of enforcing legal rights in a non-U.S. jurisdiction; (xx) civil disturbances; (xxi) government instability; and (xxii) nationalization and expropriation of private assets. Moreover, non-U.S. companies may not be subject to uniform accounting, auditing and financial reporting standards, practices and requirements comparable to, or as uniform as, those that apply to U.S. companies. Banks and other counterparties in emerging markets may impose restrictions or require certain approvals that would not exist in the United States and may require extensive diligence (including in respect of anti-money laundering and know-your-customer or similar laws) that differ significantly from those in place in the United States. Further, non-U.S. investment in securities of investments in certain of the countries in which the Fund may invest is restricted or controlled to varying degrees. These restrictions or controls may at times limit or preclude non-U.S. investment above certain ownership levels or in certain sectors of the country’s economy and increase the costs and expenses of the Fund. Certain

countries require governmental approval prior to investments by foreign persons or limit the amount of investment by foreign persons in a particular company, or limit investment by foreign persons to a specific class of securities or assets of a company that may have less advantageous terms than the classes available for purchase by nationals. Some countries require governmental approval for the repatriation of investment income, capital or the proceeds of sales of securities by foreign investors. The Fund could be adversely affected by delays in, or a refusal to grant, any required governmental approval for repatriation of capital or earnings, as well as by the application to the Fund of restrictions on investments. In addition, because the Fund’s foreign investments in other countries will likely be denominated in the currencies of such countries, a change in the value of these currencies against the U.S. dollar may well result in a corresponding change in the U.S. dollar value of the Fund’s assets denominated in those currencies. Castlelake is under no obligation to employ hedging techniques to minimize the currency risks. Although Castlelake may attempt to enter into certain currency hedges in the Accounts to mitigate currency risk, there is no guaranty the hedging will be successful or sufficient to protect the entire investment and any gain on such investment. Moreover, non-U.S. companies may not be subject to uniform accounting, auditing and financial reporting standards, practices and requirements comparable to, or as uniform as, those that apply to U.S. companies. Because investments in other countries will likely be denominated in the currencies of such countries, any fluctuation in currency exchange rates will affect the value of the investments, and any restrictions imposed to prevent outflows of capital may make it difficult or impossible to exchange or repatriate foreign currency Castlelake may seek to hedge the foreign currency exposure, but such hedging strategies may not necessarily be available or effective and may not always be employed. Accordingly, the Funds, may at times be, directly or indirectly, subject to foreign exchange risks. Emerging Market Opportunities. The Funds invest in assets or companies located or doing business in emerging market geographies. An emerging market geography is any country determined to have an emerging market economy, considering factors such as the country’s credit rating, the development of its financial and capital markets and its political and economic stability. In addition, emerging markets may be commodity-dependent in nature and hold lower gross national products relative to more developed countries. Investing in emerging market opportunities includes all of the risks of non-U.S. investments noted above, but to an increased degree. In addition to the risks associated with foreign investments generally, investing in emerging markets involves additional risks and special considerations not typically associated with investing in other more established economies or markets. Emerging markets may have governments that are less stable, markets that are less liquid and economies that are less developed and variability in the ability to enforce legal rights and remedies legal jurisdiction. These markets may have heightened volatility, greater political, regulatory, legal and economic uncertainties, less liquidity, dependence on particular commodities or international aid, high levels of inflation, restrictions on foreign investment and restrictions on repatriation of investment income and capital. Due to the nature of investing in an emerging market, the Funds could face operational difficulties with investing, withdrawing or moving capital within, or out of, emerging markets. The Funds could encounter these types of operational difficulties with local banks and other service providers in emerging markets. Future economic or political situations could lead to price controls, forced mergers, expropriation, nationalization or the creation of government monopolies. The Funds could be

adversely affected by any delay or obstacle resulting from its investment in an emerging market opportunity. Economic problems in a single country are increasingly affecting other markets and economies. A continuation of this trend could adversely affect global economic conditions and world markets and, in turn, could adversely affect the Funds’ investments. Emerging markets may be commodity-dependent in nature and hold lower gross national products relative to more developed countries. Emerging markets are generally heavily dependent upon international trade or the health of particular economies and, accordingly, have been and may continue to be adversely affected by trade barriers, exchange controls, managed adjustments in relative currency values and other protectionist measures imposed or negotiated by the countries with which they trade. In emerging markets, there is often less government supervision and regulation of business and industry practices, stock exchanges, over-the-counter markets, brokers, dealers, counterparties and issuers than in other more established markets. Any regulatory supervision that is in place may be subject to manipulation or control. Many emerging markets have less developed corporate laws regarding fiduciary duties of officers and directors and the protection of investors. Some emerging market countries do not have mature legal systems comparable to those of more developed countries. Moreover, the process of legal and regulatory reform may not be proceeding at the same pace as market developments, which could result in investment risk. Legislation to safeguard the rights of private ownership may not yet be in place in certain areas, and there may be the risk of conflict among local, regional and national requirements or authorities. Additionally, many lending activities in emerging markets are regulated with varying (if any) levels of requirements that often are subject to inconsistent judicial interpretations. These requirements include consumer protections (such as disclosure requirements and usury), licensing (such as non-bank lending and debt collection) and supervision (in particular banking and insurance). There often is a tension between these regulatory regimes and U.S. federal and state regulation. Emerging Market Financial Standards. In addition, accounting, auditing and financial reporting standards, practices and disclosure requirements that prevail in emerging markets generally are not as high as standards in developed countries. Specifically, valuation of assets, depreciation, exchange differences, deferred taxation, contingent liabilities and consolidation may be treated differently from accounting standards in more developed countries and there is an increased risk of fraud or other deceptive practices. Consequently, less information is typically available concerning companies located in emerging markets. Accordingly, the Fund’s ability to conduct effective due diligence in connection with its emerging market investments and to monitor such investments may be adversely affected by these factors. Changes in the External Business Environment. The failure to identify, plan and execute strategies to address changes in the external business environment could have a material adverse impact on the Fund’s investments, especially with respect to its contracted assets. The revenue that the Fund will seek to generate from contracted assets is significantly dependent on short- and longterm fixed arrangements. Changes to public policy, laws or regulations (or interpretations thereof), customer behavior or technology could significantly impact the value of the contracted assets. Furthermore, changes in laws and regulations (or interpretations thereof) may, in certain cases, have retroactive effect and expose the Fund to additional costs or interfere with the Fund’s existing

financial and business planning. Such changes could also affect the Fund’s opportunities to make additional investments in such assets and the potential return on the investments. In some of the markets in which the Fund may operate, or in which the Fund may own assets, political instability, economic crisis or social unrest may give rise to a change in policies regarding long-term contracted assets with private institutions, like the Fund, in strategic sectors such as infrastructure. Any such changes could lead to modifications of the economic terms of the Fund’s contracts or, in extreme scenarios, the nationalization of Fund’s assets, which could have a material adverse effect on the Fund’s business, financial condition, results of operations and cash flows. Banks and other counterparties in emerging markets may impose restrictions or require certain approvals that would not exist in the United States and may require extensive diligence (including in respect of anti-money laundering and know-your-customer or similar laws) that differ significantly from those in place in the U.S. Commodity Investments and Price Volatility. The Funds may invest in commodities or invest in portfolio investments whose operations are dependent on the price of commodities. Volatility of commodity prices may also make it more difficult for companies in which the Funds invest to raise capital to the extent the market perceives that their performance may be directly or indirectly tied to commodity prices. The price of commodities has been, and is likely to continue to be, volatile and subject to wide fluctuations in response to many factors that are beyond the control of Castlelake or the Funds. Infrastructure Risks. The Funds may invest in infrastructure assets. Such investments are subject to additional infrastructure sector risks, including: (i) the risk that technology employed will be not be effective or efficient; (ii) the risk of equipment failures, failure to perform according to design specifications, failure to meet expected levels of efficiency, fuel interruptions, loss of sale and supply contracts; (iii) changes in power or fuel contract prices, bankruptcy of or defaults by key customers, suppliers or other counterparties, and tort liability; (iv) risk of changes of values of infrastructure sector companies; (v) risks associated with employment of personnel and unionized labor; (vi) political and regulatory considerations and popular sentiments that could affect the ability of the Fund to buy or sell investments on favorable terms; and (vii) other unanticipated events which adversely affect operations. These and other inherent business risks could affect the performance and value of the Funds’ investments. Further, the use of infrastructure assets may be interrupted or otherwise affected by a variety of events outside Castlelake’s control, including serious traffic accidents, natural disasters (such as fire, hurricanes, floods, tornadoes, tsunamis, windstorms, volcanic eruptions, earthquakes and typhoons), man-made disasters (including terrorism, war and riots), defective design and construction, slope failure, bridge and tunnel collapse, road subsidence, fuel prices, environmental legislation or regulation, general economic conditions, labor disputes, eminent domain and other unforeseen circumstances and incidents. Certain of these events have affected infrastructure assets in the past, and if the use of the infrastructure assets operated by portfolio investments is interrupted in whole or in part for any period as a result of any such events, the revenues of such portfolio investments could be reduced and the costs of maintenance or restoration as well as the overall public confidence in such infrastructure assets could be reduced. There can be no assurance

that such portfolio investments’ insurance would cover liabilities resulting from claims relating to the design, construction, maintenance or operation of infrastructure assets, lost revenues or increased expenses resulting from such damage. In some cases, project agreements could be terminated if the events described above were so catastrophic that they could not be remedied within a reasonable period or at all. Additional Risks Relating to Vehicles Vehicle Structure: Limited Liquidity and Recourse. An investor’s investment in a Vehicle is subject to the structure and terms of each Vehicle. Investors should have no expectation of a secondary market in securities or loans issued by a Vehicle, or that markets would provide investors with liquidity. The securities or loans issued by a Vehicle are limited recourse obligations; investors must rely on available collections from the collateral pledged by a Vehicle, as issuer, pursuant to the indenture and will have no other source of payment. Subordination. Payments on the senior-most class(es) or tranches of a Vehicle’s securities or loans are subordinate to the payment of certain fees and expenses payable to the servicer and other parties pursuant to the indenture, which in many cases may include payments to Castlelake as the servicer. Payments of principal and interest on any junior classes or tranches of securities or loans are subordinated under the priority of payments to payments on any senior class of securities or other instruments. To the extent any losses are suffered by any securities or other instruments, those losses will be borne by each class of or tranche of securities or other instruments in order of subordination and according to the Vehicle’s governing documentation. Accordingly, the most subordinated classes or tranches of securities or other instruments may not be paid in full and may be subject to 100% loss. In addition, the most subordinated class(es) or tranches of interests in a Vehicle’s securities or loans represent highly leveraged investments and will be most affected by any changes of market value of the collateral, including, but not limited to, defaults, prepayments and other risks associated with the collateral. Remedies. If an event of default occurs under a Vehicle’s indenture, the controlling class (generally the most senior class of notes or tranche of loans then outstanding) will generally be entitled to determine the remedies to be exercised under the indenture. The interests of the controlling class of a Vehicle may be averse to those of the subordinated classes or tranches. In pursuing its interest, the controlling class will have no obligation to consider any possible effect on other interests. In addition, the junior-most class or tranche of securities or other instruments is not generally entitled to exercise remedies under the indenture, nor is the trustee generally obligated to act on behalf of the holders of these securities, loans or other instruments. Servicer. The success of a Vehicle often relies to a significant degree on the quality of the servicer, as well as the costs thereof. While the servicer may often be Castlelake, some Vehicles may engage third-party servicers. Please see other risk factors discussing servicers. Sale of Collateral. If an event of default occurs under a Vehicle indenture, there can be no assurance that the proceeds of any sale of collateral will be sufficient to pay in full transaction expenses and principal and interest on the securities or other instruments. In addition, once more senior classes or tranches have been paid in full a fluctuation in values and costs resulting from

changes in supply and demand could impact the amount of proceeds received in the sale of remaining assets. Reinvestment Risk. In certain circumstances, certain funds will be reinvested in additional or substitute assets. A number of factors, including the need to satisfy certain reinvestment criteria set forth in the indenture, may result in a lower yield on additional or substitute assets. In addition, due to significant restrictions set forth in the Vehicle indenture on the ability to buy and sell collateral, the issuer may be unable to buy or sell obligations or take other actions which might be in the best interests of the security or loan holders in the absence of these restrictions. Valuation. For the Vehicles, Castlelake is often responsible for arranging for relevant thirdparty valuation or assisting with the valuation in accordance with the Vehicle’s Offering Documents. Valuation will depend on a variety of factors and actors that are not always within Castlelake’s control and valuation could at times be volatile.

Item 9. Disciplinary information

- Disciplinary Information

Registered investment advisers are required to disclose all material facts regarding certain legal or disciplinary events that would be material to an evaluation of Castlelake or the integrity of Castlelake’s management. Castlelake has no legal or disciplinary event responsive to this Item to report.

Item 10. Other financial industry activities and affiliations

Castlelake is the investment manager for each of the Funds, except CL II and CL II Opps as defined and noted below, and the servicer for Vehicles. The General Partner of Castlelake is RO Management, LLC, a Delaware limited liability company. Castlelake is a related person to the General Partners or managing members to the Funds. Please see Item 6 of this brochure regarding performance-based fees that may be paid by the Accounts to its servicer, General Partner or managing member. Castlelake (UK) LLP - Castlelake’s office in London is the headquarters for Castlelake (UK) LLP, a subsidiary of Castlelake and a United Kingdom limited liability partnership, which is an investment adviser authorized and regulated by the UK Financial Conduct Authority.

Read the rest of Item 10 (31,163 more words)

The London office hosts several partners, investment professionals focused on Castlelake’s Real Assets, Specialty Finance and Aviation strategies, and numerous professionals across Castlelake’s non-investment groups. Castlelake Aviation Holdings (Ireland) Limited - Castlelake’s office in Dublin is the headquarters for Castlelake Aviation Holdings (Ireland) Limited, a subsidiary of Castlelake and an Ireland private company limited, which primarily provides transaction management, risk, financial and accounting services, technical asset management services and remarketing support relating to aviation investments and assets and acts as the servicer for investments and financing structures held by certain Castlelake funds. Employees in the Dublin office are primarily focused on supporting Castlelake’s Aviation strategy.

Castlelake (Spain), S.L. - Castlelake’s office in Madrid is the headquarters for Castlelake (Spain), S.L., a subsidiary of Castlelake and a Spanish private limited company, that sources new investment opportunities for Castlelake in Spain and oversees the portfolio management of Castlelake investments in Spain. The Madrid office currently holds a small number of investment professionals with focus primarily on Castlelake’s Real Asset strategy in Spain. Castlelake Pte. Ltd. - Castlelake’s office in Singapore is the headquarters for Castlelake Pte. Ltd., a subsidiary of Castlelake and a Singapore private limited company, that provides technical asset management services and remarketing support relating to aviation investments. Certain of the employees located in the Singapore office assist with Castlelake’s capital formation activities, while others primarily support Castlelake’s Aviation strategy. Castlelake Lending Opportunities, L.L.C. - Castlelake Lending Opportunities, L.L.C., a subsidiary of Castlelake and a Delaware limited liability company. Castlelake Lending Opportunities, L.L.C. provides servicing to loans and other assets and may receive servicing, facility management or other administrative fees with respect to certain investments made by the Accounts. Merit AirFinance, L.P. – Merit AirFinance, a subsidiary of Castlelake, is an aviation lending business that focuses upon making debt capital available to airlines and leasing companies for new and used aviation assets. It seeks to provide separation between Castlelake’s proprietary leasing offerings, and focuses upon providing flexible, innovative debt solutions to airlines and leasing companies. Castlelake Investments (DIFC) Limited – Castlelake Investments (DIFC) Limited, a Castlelake subsidiary, is headquartered in Dubai. The company operates on a consultative basis with Castlelake’s US, UK and Dublin offices to maintain and source aviation counterparty relationships within the Middle East and Africa. Castlelake RA, LLC is a relying adviser responsible for the investment management of Castlelake II, LP (“CL II”) and Castlelake II Opportunities, L.P. (“CL II Opps”). Castlelake RA, LLC is ultimately controlled by Rory Joseph O’Neill and falls outside the control of Castlelake L.P. In early-May 2024, Castlelake reached an agreement with affiliates of Brookfield Asset Management (collectively, “Brookfield”) to form a strategic partnership (the “Transaction”). The Transaction closed on September 16, 2024 (the “Closing”) whereby Brookfield acquired a noncontrolling indirect interest of Castlelake LP, including future options to potentially obtain indirect control, but where the current intent of the parties is that Castlelake continues to operate independently and under the Castlelake brand for the reasonably foreseeable future. Upon the Closing of the Transaction and as more fully described in the Offering Documents of the Accounts, Brookfield acquired, amongst other things, (i) economic interests representing 51% of any net fee income to be generated by Castlelake, and each of Castlelake and Brookfield will, respectively, have a put/call right, as applicable, for up to 49% in respect of the remaining unsold fee interests, (ii) economic interests representing 7.5% of any Carried Interest to be generated by certain Castlelake-affiliated General Partners (or equivalent control persons) of Castlelake funds, with Brookfield having a call right to purchase an additional 12.5% of such Carried Interest, and (iii)

51% of Castlelake’s ownership in Castlelake owned, captive origination platforms, which ownership will increase pro rata in accordance with exercises in the put/call of fee interests described in clause (i) above. In connection with the Transaction, Castlelake and Brookfield have established a fiveperson board (the “Board”) which retains ultimate control of Castlelake. Three of the Board members have been appointed by Castlelake (Rory O’Neill, Evan Carruthers and Yen-Wah Lam) and the remaining two (Craig Noble (CEO of Brookfield Credit) and Hadley Peer Marshall (CFO of Brookfield Asset Management)) were appointed by Brookfield. Both Castlelake and Brookfield continue to operate their respective businesses independently, with each remaining under its prior brand and led by its prior management and investment teams. To the extent Brookfield crosses certain net fee income ownership thresholds following the exercise of certain put/call rights, Brookfield will become entitled to appoint three out of the five Board members no earlier than mid-2028; provided, that Rory O’Neill and Evan Carruthers will generally continue to be entitled to serve on the Board (or appoint a designee) until at least 2033 or otherwise for so long as they continue to be involved with Castlelake. Brookfield and its affiliates are not “advisory affiliates” or “related persons” for purposes of this Form ADV. For more information regarding Brookfield and its affiliates, please refer to the Form ADV of Brookfield affiliated investment advisers: Brookfield Public Securities Group LLC (CRD# 110497), Brookfield Asset Management PIC Canada, LP (CRD# 151605), Brookfield Asset Management Private Institutional Capital Adviser (Credit), LLC (CRD# 170811), Brookfield Asset Management PIC Adviser (Private Equity), L.P. (CRD# 171207), Brookfield Asset Management PIC U.S. LLC (CRD# 151599), Brookfield Asset Management PIC BMG, LLC. (CRD# 312797), BAM Credit and Insurance Solutions Advisor LLC (CRD# 312792), and Brookfield Renewable Energy Group LLC (CRD# 316590). Conflicts of Interest Investors should be aware that there will be occasions where Castlelake and its affiliates encounter conflicts of interest in connection with the Accounts’ investment activities. Castlelake has established policies and procedures to address potential conflicts of interest in its good faith judgment, and maintains and experienced legal and compliance team, as well as a Regulatory, Compliance and Conflicts Committee, to help identify and evaluate potential conflicts that may arise. Although Castlelake has established procedures to address such potential conflicts of interest, some of which are set forth herein, there can be no assurance that conflicts of interest will be resolved in a manner that is more favorable to the Funds. The following discussion enumerates certain of those conflicts of interest and more detailed discussion of conflicts may be contained within certain of the Offering Documents of the Accounts. Coordination Among the Accounts. While Castlelake generally devotes substantially all of its time and attention as is reasonably necessary to manage, service and dispose of the investments and assets of the Accounts, it cannot and does not devote all of its time and attention to any single Account and it may devote time and attention to other matters. In addition, given that the investment strategies of Funds may be similar, different or competing investment offers may be provided by one Fund as compared to another Fund, which may lead to the Funds competing for investment opportunities (it being under understood that this conflict of interest may not

necessarily be resolved in favor of one fund). Castlelake will engage in investment activities for multiple Accounts and, to the extent permitted by Castlelake’s compliance policies, act for its own account. Except as otherwise provided in a Fund’s Offering Documents, a Fund shall not have any rights in respect of investment activities of other Funds and these other investment activities can result in certain conflict of interest situations discussed below. Co-Investment Opportunities. Where possible and appropriate based on the size of the opportunity and other factors, co-investment opportunities have been, and are expected in the future to be, offered to various Fund investors or to third parties (including to Brookfield and/or its affiliates), whether through collectively owned SPVs and otherwise. These co-investment opportunities may be intended to close concurrently with the Funds or the Funds may invest with the expectation to subsequently arrange for co-investments. Conflicts of interest may arise in the allocation of co-investment opportunities, which may be made to one or more persons for any number of reasons as determined by Castlelake in its sole discretion and may not be in the best interests of the Funds or of their respective individual investors. Such investments may involve risks not present in investments where a third-party is not involved, including the possibility that a third-party co-venturer or partner may at any time have economic or business interests or goals that are inconsistent with those of the Funds, or may be in a position to take action contrary to the investment objectives of the Funds. In addition, there is risk that such third-party, co-venturer or partner may not ultimately invest or may fail to meet financial commitments, leaving a Fund responsible for such person’s share of fees and expense, bridge financing incurred in contemplation of such person investing and/or such person’s expected portion of the investment. In addition, a Fund may in certain circumstances be liable for actions of its third-party co-venturer or partner. In certain cases, determinations to allocate such amounts or investment opportunities to Operating Partners will be made prior to the determination of the availability of opportunity for other co-investors, and as such generally will decrease the amount of co-investment opportunities available. When co-investment opportunities are available, they will be allocated at the discretion of Castlelake based on a variety of factors that may include: (i) prior expression of interest in coinvestment opportunities by the prospective co-investor (including, but not limited to, via Side Letters); (ii) legal, regulatory, accounting and tax considerations affecting co-investment participation in the particular co-investment opportunity; (iii) confidentiality or publicity concerns, including those that have the potential to arise in connection with providing the prospective coinvestor with specific information relating to the investment opportunity; (iv) past experiences with the potential co-investor, including the potential co- investor’s willingness and ability to respond promptly and/or affirmatively to prior co-investment opportunities and past investment record relating to co-investment opportunities offered to such prospective co-investor; (v) the size, sophistication and financial resources of the potential co-investor and its ability to efficiently and expeditiously participate in the investment opportunity; (vi) whether the profile and characteristics of the potential co-investor may have an impact on the viability or terms of the investment opportunity and the ability of the Fund to take advantage of such investment opportunity; (vii) potential strategic benefits to the portfolio investment if a potential co-investor participates (e.g., by virtue of such co-investors experience, expertise, knowledge, relationships or other criteria deemed relevant by Castlelake); and (viii) any other reason for including a potential coinvestor as determined in the sole discretion of Castlelake. Allowing any co-investment generally reduces the amount of the relevant investment opportunity that theoretically could have been taken

by the Fund, and because co-invest opportunities generally appeal to the Fund investors and third parties, Castlelake expects to be subject to potential conflict of interest in determining the amount of investment opportunity that should be allocated to the Fund. Allocation of co-investment opportunities among Funds and other investors may not, and often will not, result in proportional allocations among investors that have expressed interest in co-investment opportunities. Co-investment opportunities may, and typically will, be offered to some and not to other Castlelake investors, and the consideration of the factors set forth above may result in certain investors receiving multiple opportunities to co-invest while others expressing interest in co-investments may receive none. Castlelake is also permitted to provide co-investment opportunities to third parties, e.g., sellers, company management, strategic and financial partners, finders, brokers or other sourcing persons, preferred stockholders, joint venture partners or lenders. In addition, the Fund’s participation in an investment in which co-investors also participate will be subject to tax or regulatory status of such co-investors and extraordinary events affecting such co-investors, which may result in adverse impact to the Fund or its investors and affect their participation in a portfolio investment. Co-investments may be completed at the time of the closing of the Fund’s investment, or following such date depending on market conditions, negotiations with investors and other factors. Third-party co-investors may be required to pay management and performance fees, but Funds in a co-investment are generally not assessed an additional layer of management or performance fees payable to Castlelake. Any fees (including management fees) or Carried Interest in respect of any co-investments paid to and/or received by Castlelake or its affiliates will be retained by such persons and will not offset management fees payable by any Funds. Similarly, given that Castlelake or its affiliates may be entitled to economics in respect of co-investments, Castlelake may be incented to provide co-investment opportunities which may in turn cause Castlelake to devote meaningful time thereon. In addition, the Funds’ participation in an investment in which co-investors also participate could be subject to tax or regulatory status of such co-investors and extraordinary events affecting such co-investors, which could result in adverse impact to the Funds and affect their participation in a portfolio investment. Further, expenses relating to potential co-investments that are not consummated may be borne by the Funds. Assets of each co-investor may become exposed to the risk of claims involving one or more other co-investors, e.g., a third-party to a transaction may require the co-investing Accounts to agree to joint and several liability, or certain types of investments may be pooled together in a common SPV without segregation of liabilities arising from different investments even though not all participating accounts participate in all investments entered into by the SPV. Castlelake intends to mitigate such risks as it deems appropriate from time to time, such as through crossindemnification arrangements, but there can be no guarantee that such risks can be mitigated in full. To the extent a co-investment vehicle purchases the portion of an investment from the Fund in a Bridge Financing transaction, Castlelake expects that the Fund would generally effectuate such Bridge Financing transaction by having the Fund sell the relevant portion of the investment to the co-investment vehicle at a price equal to cost (pro-rated based on the relative portion of the applicable investment being syndicated, including any transaction expenses (including associated legal expenses)) plus an interest charge for the applicable holding period at a rate equal to the one

of following: the interest rate of the Preferred Return (to the extent the General Partner called capital from investors with respect to such investment) and the rate paid by the Fund to borrow on its subscription line (or other line of credit or applicable borrowing) to make the investment (if applicable) or such other reasonable rate or methodology determined by Castlelake. Notwithstanding the foregoing, Castlelake may use another syndication methodology to the extent it determines another formulation to be fairer and more equitable under the particular circumstances. In order to facilitate the acquisition of a portfolio company, a Fund reserves the right to make (or commit to make) an investment in the company with a view to selling a portion of the investment to co-investors or other persons prior to or following the closing of the acquisition. In such event, the relevant Fund will bear the risk that any or all of the excess portion of such investment may not be sold or may only be sold on unattractive terms, including for example the risk that a portion of the investment will be syndicated at reduced cost, at cost, or at a lower amount at a time when the General Partner believes the value of such investment has appreciated or should be higher than that paid (or willing to be paid) by a co-investor. To the extent such a syndication is made, the General Partner’s interest in limiting the Fund’s exposure to a given investment while providing a potential benefit to co-investors investing at such lower values will give rise to a potential conflict of interest. As a consequence of a failed co-investment syndication process or a co-investment syndication on unattractive terms, the relevant Fund would be required to (i) bear the entire portion of any break-up, topping or other fees, costs and expenses related to such investment (including the proportionate share of such amounts that were expected to have been borne by co-investors), (ii) hold a larger-than-expected investment in such portfolio company, (iii) receive less-than-fair-market value for the syndicated portion of the investment and/or (iv) be diluted or realize lower than expected returns from such investment. When and to the extent that personnel and related persons of Castlelake and its affiliates make capital investments in or alongside certain Funds, Castlelake and its affiliates are subject to potentially conflicting interests in connection with these investments. There can be no assurance that any Fund’s return from a transaction would be equal to and not less than another Account participating in the same transaction or that it would have been as favorable as it would have been had such conflict not existed. Allocation of Investment Opportunities. Until the time that the relevant General Partner is permitted under a Fund’s Offering Documents to commence a successor Fund, substantially all appropriate investment opportunities that meet the Fund’s investment criteria will be pursued by Castlelake principals for the benefit of such Fund, subject to certain limited exceptions set forth in the Offering Documents and Castlelake’s allocation policy. In addition, the Offering Documents provide Castlelake with wide-ranging authority to make determinations such as the cessation of a Fund’s investment period and the commencement of a successor Fund’s investment period (including timing determinations relating to each of the foregoing). Such determinations generally dictate whether a predecessor or successor fund will be allocated investment opportunities and therefore Castlelake faces conflicts of interest in making such determinations. Castlelake currently manages, and is expected in the future to manage, Accounts with similar or overlapping investment mandates and will need to allocate certain relevant investment opportunities among those Accounts. Castlelake’s policy requires it to treat the Accounts in a fair and equitable manner over time, considering a variety of circumstances and such factors as Castlelake deems relevant when allocating investments. Certain investment opportunities suitable for one Account are likely to be

suitable for other Accounts. For the duration of the investment period, if an investment opportunity generally falls within the investment mandate of more than one Account, allocation will be determined by Castlelake in its sole discretion in light of one or more relevant factors affecting the Accounts. To determine whether, and to what extent, the Accounts will participate in the relevant investment opportunity, and the amount of any such allocation, Castlelake generally assesses whether an investment opportunity is appropriate for an Account based on the Account’s Offering Document, as well as factors including but not limited to: any investment restrictions and objectives of the Account (including those set forth in the relevant Offering Documents and Side Letters, where applicable), investment strategy, sourcing of the transaction, targeted return profile, amount of capital commitments, available capital or projected future capacity for investment, current and projected capital deployment targets, liquidity and capital constraints, reserves, portfolio and/or counterparty diversification, risk and cash flow considerations, applicable investment limitations, the size and nature of the investment, ability to divide an investment among Accounts, anticipated duration/ hold period, the nature of the investment focus of the Account, use and/or availability of leverage, status of investment as a follow-on investment with respect to the participating Accounts’ portfolio, duration of investment and timing in the Accounts’ life cycles, investment horizons (i.e., capital obligations, funding or distribution requirements) tolerance for turnover, asset composition, suitability, tax and other structural and operational considerations and provisions in the governing agreements of the participating accounts, and other considerations, including agreements with co-investors, deemed relevant by Castlelake and in good faith. In addition, certain Accounts may include structures designed to achieve certain ratings from one or more third-party rating agencies. Such rating agencies are expected to set certain concentration, leverage and other investment restrictions and/or requirements, which may shift from time to time, in connection with issuing any rating. Any such restrictions and/or other requirements issued by a rating agency, or other determination made by Castlelake in connection with securing a rating in respect of such structures may impact the portfolio construction for the Account and thereby impact the allocation of investment opportunities amongst the eligible Accounts. In particular, the Accounts will focus on acquiring what Castlelake and its affiliates believes to be, after taking into account the underwriting factors and risk assumptions at the time of evaluating each investment, opportunities on the lower end of the risk spectrum, relative to some Accounts. Castlelake will be solely responsible for determining whether an investment is suitable for the Account, and the appropriate amount of any such allocation, as specified in Castlelake’s allocation policy (as amended from time to time). Castlelake is subject to a potential conflict of interest with respect to making allocation determinations, including because the compensation structures in the Accounts can differ (e.g., different management fees and offsets, different Carried Interest structures, or other compensation arrangements) Castlelake is subject to a potential conflict of interest with respect to making allocation determinations, including because the compensation structures in the Accounts can differ (e.g., different management fees and offsets). Castlelake’s Allocation Policy (as amended from time to time) requires it to treat the Accounts in a fair and equitable manner over time when allocating investments, which may from time-to-time results in certain investments being allocated on a non-pro rata basis. Additionally, the Offering Documents and investment programs of certain Accounts may restrict, limit or prohibit, in whole or in part, or subject to certain procedural requirements, investments of the Account in issuers held by such Accounts, or may give priority with respect to investments to such Accounts. Some of these restrictions could be waived or consented to by

investors (or their representatives) in, or the Advisory Committees of, such Accounts. However, Castlelake may or may not, in its sole discretion, seek any such waiver or consent and, in any event, there can be no assurance that any waiver or consent sought will be obtained. Castlelake’s allocation of investment opportunities among a Fund and any Accounts may not always, and often will not, be proportional. Therefore, such allocations may be more advantageous to the Fund relative to one or all of the Accounts, or vice versa. While Castlelake will allocate investment opportunities in a way that it believes in good faith is fair and equitable to the Fund over time, there can be no assurance that a Fund’s actual allocation of an investment opportunity, if any, or terms on which the allocation is made, will be as favorable as they would be if the conflicts of interest to which Castlelake may be subject did not exist. Allocation may vary from pro rata based on one or more factors where Castlelake determines another allocation is appropriate in light of one or more relevant factors, including, but not limited to, Fund size, available capital, portfolio diversification and concentration, existing allocations, duration of investment, structuring and size of investment and relevant investment limitations. Additionally, conflicts of interest can arise if a Fund makes an investment in a portfolio investment in conjunction with an investment made by the Accounts. For instance, a Fund may not invest through the same investment vehicles, have the same access to credit or employ the same hedging or investment strategies as such Account. These investments may also occur at different times, including, after one of the Accounts has established a position in an investment (or vice versa). This may result in differences in price, investment terms, leverage and associated costs between a Fund and any such Account. There can be no assurance that a Fund’s return on such an investment will be the same as the returns achieved by any Account(s). Given the nature of these conflicts, there can be no assurance that the resolution of these conflicts will be beneficial to a Fund. Further, a Fund may finance the lease or acquisition of an aircraft or provide other financing to parties that are, or will be, counterparties or participants in agreements, transactions or other arrangements with the Accounts, and vice versa. For example, an Account may provide financing to an airline to satisfy its PDP obligations to an aircraft manufacturer, including where such PDP obligations were financed by a Fund, and vice versa. Such arrangements may give rise to actual or potential conflicts of interest for Castlelake and/or its affiliates given that such airlines may also lease aircraft from an Account, including aircraft that a Fund provided PDP financing in respect of. For example, Castlelake may have a conflict of interest regarding (i) pricing such aircraft financing given that such financing may result in future PDP arrangements with a given airline and/or would extinguish any potential airline default in respect of PDP obligations or (ii) enforcing an airline default on the financing which could impact such airline’s ability and/or willingness to satisfy a PDP obligation. Such conflicts may also arise where an airline defaults on PDP obligations financed by the Fund. In such cases, Castlelake may determine that an Account repay such PDP financing and take delivery of the relevant aircraft. Subject to Castlelake’s policies, Castlelake and its Principals and employees may carry on investment activities for their own accounts and for family members and friends who do not invest in a Fund, and may give advice and recommend securities to the Accounts which may differ from the advice given to, or securities recommended or bought for, a Fund, even though their investment objectives may be the same or similar. Further, the Principals and Castlelake employees will carry on investment activities that are different than the Fund’s investment activities. Castlelake personnel and its Principals reserve the right to manage their own personal investments, whether or not through a formal family office or estate planning structure, to establish trusts, endowments, charitable programs, foundations or similar arrangements, and to pay or receive compensation relating to the foregoing. The Principals and Castlelake’s investment staff will continue to manage

and monitor such investments until their realization. Such other investments that the Principals expect from time to time to control or manage generally have the potential to compete with investments acquired by the Fund. To the extent an advisory opportunity is received that is unsuitable for a Fund, in Castlelake’s sole discretion, Castlelake and its personnel reserve the right to refer such opportunity to third parties or to make personal investments in the relevant opportunity. Castlelake personnel and the Principals are permitted to serve on boards or act in other roles unaffiliated with Castlelake or the Fund, including boards of charitable and educational institutions, public companies and former portfolio companies, and receive compensation in connection with such services and roles. Allocation of Financing and Refinancing Opportunities. Subject to applicable law, an Account can provide financing to a borrower or other person which, in turn, will use such financing proceeds directly or indirectly (e.g., to provide financing to a borrower) for the purposes of refinancing or modifying an existing loan or other debt position in the relevant borrower held by an Account, or for the purpose of enabling the relevant borrower to repurchase or redeem equity interests in such borrower held by an Account, or otherwise for the purpose of providing liquidity to an Account that holds an interest in the relevant borrower, or vice versa. To the extent such investment opportunities arise, Castlelake will face actual or apparent conflicts of interest, in particular, the incentive to use financing provided directly or indirectly by an Account to facilitate a successful exit of any such investment by the relevant Account. Moreover, an Account could refinance or modify loans or debt positions or provide financing to a borrower or other person, which, in turn, will use such financing (directly or indirectly) to refinance loans or debt positions held by an Account in a borrower prior to their stated maturity. Such prepayments will generally result in the relevant Account receiving a lower than anticipated yield on such investments, which it cannot recoup through the redeployment of the relevant investment proceeds or otherwise mitigate through any early repayment penalties negotiated with the relevant borrower. An Account could be required to pay pre-payment penalties to one or more Accounts or their portfolio investments (or vice versa). While not limited to such periods, debt refinancings are more likely to occur during periods of declining interest rates. To the extent that an Account reinvests the proceeds of a prepayment in these circumstances, it will likely receive a rate of interest that is lower than the rate on the debt positions that were prepaid as a result of the refinancing. In considering such refinancing opportunities, Castlelake will face actual or apparent conflicts of interest, in particular in respect of its incentives to source attractive refinancing opportunities for the benefit of Accounts. The pricing and terms of any of the foregoing refinancing transactions are expected, from time to time, to be established solely by Castlelake without the involvement of an independent third-party and could be above or below then current market expectations and the pricing and terms related to the prior financing. The refinancing party (and/or the original party to the loan) could ultimately benefit from (or be harmed by) the refinancing, and the Accounts could consequently profit (including in relation to their incentive allocation calculations) or realize losses as a consequence thereof. It is possible that Castlelake will allocate the opportunity to refinance a loan or other debt position held by Accounts in a different proportion (which can be higher or lower) to the proportion in which the Accounts participated in the position being refinanced and, in certain circumstances, the relevant Account could have insufficient available capital or otherwise be unable to participate in such refinancing.

Allocation of Fees and Expenses. A variety of potential conflicts of interest arise when determining allocations of various fees and expenses among the Funds that are involved in the same investment or utilizing the same Fund-Owned Administrative Entities, including is such (for instance, CASL) are providing services directly to Castlelake. Castlelake, in its sole discretion, will allocate fees and expenses in accordance with the Funds’ Offering Documents and in a manner that it believes in good faith is fair and equitable to the respective Funds under the circumstances and considering such factors as it deems relevant. The allocations of such expenses is permitted to be made on a non-proportional basis, and any such determinations involve inherent matters of discretion, e.g., in determining whether to allocate pro rata based on number of Funds or coinvestors receiving related actual or potential benefits or proportionately in accordance with investment size (including with respect to potential investments or co-investments that are not consummated) or another fair and reasonable approach determined by Castlelake. Further, because certain expenses are paid for by the Funds and/or their portfolio investments or, if incurred by Castlelake, are reimbursed by the Funds and/or their portfolio investments, Castlelake will not necessarily always seek out the lowest cost options when incurring (or causing the Funds to incur) such expenses. Additionally, as noted above, Castlelake may structure a co-investment opportunity such that the proposed participants (including third-party co-investors) in such co-investment opportunity do not bear any broken deal or related expenses, or Castlelake may not be able to find third-party co- investor(s), in which case the Fund would generally be expected to bear additional expenses related thereto. As noted above, Castlelake personnel or the Principals reserve the right to buy securities in transactions deemed unsuitable for the Fund, but will not in such circumstances be required to share in or reimburse the Fund for due diligence or any other expenses (including broken deal expenses) incurred by the Fund in connection with the Fund’s consideration of the relevant investment opportunity. Distributions. In connection with the sale of (or certain other events at) a portfolio company, while Castlelake intends to timely distribute the amounts owed to investors and/or the relevant Fund(s), Castlelake reserves the right to retain certain amounts to establish various escrow, holdback and reserve accounts relevant to the portfolio company and/or relevant Fund(s). Such amounts generally are not subject to any pre-defined limits in the applicable Offering Documents, transaction agreements or any of Castlelake’s policies and procedures. Castlelake will have potential conflicts of interest in determining the amount and timing of distributions to limited partners and/or the relevant Fund(s), and regarding the timing in which such distribution is made. As a general matter, to the extent reserve amounts are held in cash by a Fund, intermediate entity or portfolio company, such amounts will not accrue a preferred return under the relevant Fund’s Carried Interest arrangements unless and until they are used to make an investment or pay expenses or other liabilities. To the extent these amounts do not accrue a preferred return, or are not reflected in the relevant Fund’s performance figures, Castlelake expects to have incentives to continue to hold the amounts for extended periods. Pooled Indebtedness. The Funds may incur indebtedness, leverage or other obligations and/or guarantees on a joint, several, cross-collateralized (which may be on an investment-byinvestment or portfolio wide basis) or joint and several basis in order to acquire a portfolio of assets or to obtain more favorable financing terms. While such arrangements may be joint and several with respect to the Funds, such arrangements may not necessarily impose reciprocal joint and several obligations on such Funds. As a result of the incurrence of indebtedness on a joint and several or cross-collateralized basis, the Funds may be required to contribute amounts in excess of

its pro rata share, including additional capital to make up for any shortfall if such other Funds (or co-investors) are unable to or are not required to repay their pro rata share of such indebtedness. Moreover, the Funds could also lose their interests in performing investments in the event such performing investments are cross- collateralized with poorly performing or non-performing investments. In addition, a third-party to a transaction may require the Funds to agree to joint and several liability, which will give rise to similar risk and conflicts. Also, any co-investment the Accounts through a SPV may expose the Accounts to additional risk given that the SPV may not have segregation of liabilities arising from different investments, and the Accounts can have liability regardless of whether it participates in all investments made by such SPV or otherwise in excess of its participation percentage if any other SPV participant defaults on its obligations. Securitization Vehicles. Accounts are permitted to, alongside one or more other Accounts, gain exposure to underlying assets (including aircraft assets) through lending to, or acquiring debt (including debt originated by Castlelake or an affiliate) and/or equity interests in, any platform, warehouse and/or securitization-like vehicle or facility, including by contributing, or committing to contribute, assets, investments and/or cash consideration to such facilities or vehicles in exchange for interests therein. In furtherance of the foregoing, Accounts are permitted to, alongside one or more other Accounts, originate or otherwise utilize credit facilities, repurchase agreements, warehouse facilities, securitizations and other forms of financing to finance assets, which would be expected to involve similar structures as contemplated by the foregoing sentence. To the extent multiple Accounts participate, a participating Account may hold or acquire positions in (or otherwise gain exposure to, directly or indirectly) investments or assets in which other Accounts have invested and/or have otherwise contributed to such facility or vehicle. Such investments or transactions by multiple Accounts have the potential to be coincident with or precede one another and may be at different valuations. Accounts may invest in classes or tranches of securities in such facility or vehicle on different terms than other Accounts. As such, the interests of the Accounts in such a facility or vehicle will not necessarily be aligned. In certain circumstances Castlelake reserves the right to restructure or refinance existing investments to allow for optimal financing and/or to facilitate the return of capital to the Accounts which have passed their term expiration dates in a manner consistent with Castlelake’s allocation policy. This can include refinancing existing investments, in whole or part, into new structures in combination with assets from the Accounts, as well as assets from term or warehouse facilities of the Accounts. Castlelake will seek for any consolidation of assets relating to these restructurings or refinancings to be valued on a fair and consistent basis, as determined by Castlelake in its sole discretion. CLOs. Funds may, from time to time, invest in CLOs, including in CLOs sponsored by, and in which the assets were originated and securitized by, Castlelake, a Fund, and/or an affiliate thereof (an “Affiliated CLO”). Castlelake or an affiliate thereof would generally act as a collateral manager or servicer (“Collateral Manager”) of such Affiliated CLO. The fact that the management fees and servicing fees that Castlelake or its affiliates may receive from an Affiliated CLO are based on the size of the assets of that vehicle could create a conflict of interest. In particular, the Collateral Manager (potentially Castlelake or an affiliate thereof) could have an incentive to cause the Affiliated CLO to hold investments that have poor prospects for improvement in order to receive ongoing fees in the interim and, potentially, a more likely or larger fee or distribution if the value of such assets appreciates in the future. Similar conflicts of interest exist in Castlelake’s

exercise (or failure to exercise) an Account’s rights as holder of a CLO (and/or otherwise creating additional tranches of the CLO further subordinating the Accounts’ equity or investment in such Affiliated CLO equity, including rights relating to the refinancing of such Affiliated CLO), approval of amendments and removal of the Collateral Manager. Accounts or third parties may invest in Affiliated CLO classes or tranches of securities other than direct or indirect equity interests in an Affiliated CLO or on different terms (including different economic terms). The interests of the Accounts investing in different classes or tranches of securities of the Affiliated CLO are particularly acute in the case of financial distress of the Affiliated CLO. The ability of the Collateral Manager to recommend actions that are in the best interests of the Accounts might be impaired as a result of competing interests that are more fully discussed as capital structure conflicts. Furthermore, in instances where partners, officers or employees of Castlelake or its affiliates serve as directors of certain borrowers the loans of which are collateral of the Affiliated CLO, they will be required to make decisions that they consider to be in the best interests of such borrower. In certain circumstances, such as in situations involving bankruptcy or near insolvency of a borrower, actions that may be in the best interests of such borrower may not be in the best interests of the Affiliated CLO, and vice versa. Accordingly, in these situations, there may be conflicts of interest between an individual’s duties as a partner, officer or employee of Castlelake or its affiliates and such individual’s duties as a director of such borrower. Consolidation of Existing Investments. In certain circumstances Castlelake will restructure or refinance existing investments to allow for, among other things, optimal financing, facilitate new capital and/or to facilitate the return of capital to Funds which have passed their commitment period, term and/or have liquidity needs. This can include refinancing existing investments, in whole or part, into new structures in combination with assets from other Funds, as well as assets from term or warehouse facilities in other Funds. In some combinations, each contributing party retains economic exposure solely to its contributed assets, but assets are shared in a single legal vehicle for purposes like accessing what Castlelake believes to be more efficient financing or to facilitate a return of capital as described above. These structures can result in risks such as crossdefault, tracking risks and/or credit quality of other contributing parties. In other combinations, the assets will be consolidated and, in addition to the foregoing risks, the contributing parties will obtain exposure to new assets and/or be diluted as to exposure in existing assets contributed to the combined vehicle. Any consolidation of assets relating to these restructurings or refinancing will be valued on a fair and consistent basis in accordance with Castlelake’s valuation policies and procedures. Investments in Transactions by Multiple Funds. Investments by multiple Funds in private transactions are generally made through collectively owned SPVs or otherwise as determined by Castlelake (provided that a Fund will not, except as otherwise provided in the Offering Documents, effectively bear any additional management fees or incentive compensation in favor of Castlelake or its affiliates in connection with its investment in any such SPVs). In some cases, all or a portion of the management fees determined with respect to the Fund may be debited at the level of any such SPV or other intermediate investment vehicle and any such amounts will generally offset the management fees payable by the Fund. Investment through an SPV may expose the Funds to additional risk given that the SPV may not have segregation of liabilities arising from different

investment, and a Fund can have liability regardless of whether it participates in all investments made by such SPV or otherwise in excess of its participation percentage if any other SPV participant defaults on its obligations. In addition, a third-party to a transaction may require Funds to agree to joint and several liability. Castlelake will be subject to a potential conflict of interest when acting on behalf of multiple clients with divergent interests. Castlelake will mitigate these risks as it deems appropriate from time to time, such as through cross-indemnification arrangements among participating Funds, or valuation procedures in the event of potential dilution, but there can be no guarantee that these risks can be mitigated in full. Additionally, conflicts of interest can arise if the Fund makes an investment in a portfolio investment in conjunction with an investment made by Accounts. For instance, the Fund may not invest through the same investment vehicles, have the same access to credit or employ the same hedging or investment strategies as such Accounts. These investments may also occur at different times, including, after an Account has established a position in an investment (or vice versa). This may result in differences in price, investment terms, leverage and associated costs between the Fund and the Accounts. There can be no assurance that each Fund’s return on such an investment will be the same as the returns achieved by any Account. Given the nature of these conflicts, there can be no assurance that the resolution of these conflicts will be beneficial to all Accounts. In connection with the foregoing, Castlelake may use one SPV as the “lender of record,” which would provide loans (or otherwise participate in loan transactions) on behalf of multiple Accounts (it being understood one Account may not participate in all of the loans or investments held by such SPV). In addition to the risks set forth above, using one SPV may result in an Account being liable with respect to not only its own share of any obligation but also the share attributable to the Accounts (including, for the avoidance of doubt, an obligation attributable to an investment or loan the Account and did not participate in). Accordingly, as a result of the incurrence of any such obligation, an Account may be required to contribute amounts in excess of its pro rata share of any obligation (or may otherwise suffer a loss of value due to forfeiture or otherwise), including additional capital to make up for any shortfall if such Accounts are unable to repay their pro rata share. Transfer of Interests. In certain cases, Castlelake will have the opportunity (but, subject to any applicable restrictions or procedures in the Offering Documents, no obligation) to identify one or more secondary transferees of interests in a Fund. In such cases, Castlelake will not receive compensation for identifying such transferees, and is permitted to use its discretion to assist in selecting such transferees, and unless required by the Offering Documents, will determine in its sole discretion whether the opportunity to receive a transfer of Fund interests should be offered to one or more existing Fund investors. The relevant General Partner also generally has authority under the Offering Documents to consent to (or reject) transfers requested by one or more limited partners, and reserves the right to consent to certain transfers in advance, or to condition its consent on any number of factors agreed with individual investors via Side Letter, including the condition that the transferor, transferee or their affiliates invest (or invest above certain amounts) in future Funds. The relevant General Partner also is permitted, but not obligated, to purchase Fund interests from limited partners that desire to transfer their interests. The General Partner is subject to conflicts of interest in purchasing such interests, as it generally possesses certain confidential information relating to the Funds and their investments, not all of which is expected to be known by the transferring limited partner, and the General Partner generally will not obtain a fairness

opinion or third-party valuation of such interests. The relevant General Partner similarly expects to use its discretion to select limited partners from whom it will acquire Fund interests based on eligibility and other factors similar to those employed in selecting co-investors, and will determine in its sole discretion whether it will offer to purchase Fund interests from one or more limited partners. Although in many cases the relevant transferor and transferee will bear the full costs of their transfers, to the extent that they do not do so, the costs typically will be borne by the relevant Fund. Investments at Different Levels of Capital Structure. The Funds are permitted to 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 or otherwise in different classes of an issuer’s securities. In addition, in some circumstances, Castlelake will originate an investment (for instance, a unitranche loan) with a counterparty and then use its discretion to structure such investment into multiple new investments with different levels of seniority, which investments may be held by different Funds and/or third parties and which may create conflicts when making decisions on terms. To the extent a Fund hold securities or loans that are different (including with respect to their relative seniority) than those held by other Funds, Castlelake is likely to be presented with decisions when the interests of the two (or more) Funds are in conflict. In these circumstances, Castlelake’s duties to each of the Funds may, and in certain circumstances will, conflict. If such a capital structure conflict did arise, Castlelake would expect to take reasonable steps to mitigate the conflict, which may include obtaining third-party pricing or validation of pricing of the debt instrument from a third-party, requiring a competitive process prior to agreeing to complete the transaction, requiring a certain level of third-party participation in the transaction, carrying out arm’s length negotiations through incentivized management teams at the portfolio company level or requiring the lender act on its own behalf in a default situation. Castlelake will in its discretion take steps to reduce the potential for adversity between the Funds, including by causing the Funds to take certain actions that, in the absence of such conflict, it would not take. In some cases, a decision by Castlelake to take any such step could have the effect of benefiting one Fund (and, incidentally, may also have the effect of benefiting Castlelake or an affiliate) and therefore may not have been in the best interests of, and may be adverse to, another Fund. For example, if the issuer requires amendments or waivers or becomes insolvent or suffers financial distress, there may be a conflict between the interests insofar as the issuer may be unable to satisfy the claims of all classes of its creditors and security holders. Because of the different legal rights associated with debt and equity of the same issuer, Castlelake may face a conflict of interest in respect of the advice it gives to, and the actions it takes on behalf of Accounts investing in debt (e.g., the terms of debt instruments, the enforcement of covenants, the terms of recapitalizations and the resolution of workouts or bankruptcies) as compared to the action taken for Accounts investing in the equity. Under these circumstances it will not always be feasible for Castlelake to reconcile the conflicting interests of the Accounts in a way that protects all of the interests. In certain circumstances Accounts may be prohibited from exercising (or Castlelake may deem it appropriate to refrain from exercising) voting or other rights in order to mitigate the relevant potential conflicts, notwithstanding the fact that the investment(s) of one Fund or the other may be subject to creditor claims regarding subordination of interests.

With respect to aviation-related investing, an Account may finance the lease of an aircraft to parties that are, or will be, counterparties or participants in agreements, transactions or other arrangements with Accounts. For example, an Account may provide debtor-in-possession or exit financing to an airline emerging from bankruptcy which may convert to equity in such airline. Such arrangements may give rise to actual or potential conflicts of interest for Castlelake given that such airlines may also lease aircraft from Accounts. Such conflicts may arise if the airline defaults on the lease or finance lease obligations while the other Account is an equity owner in such airline. In addition, given that the investment strategies of Accounts fall within an Accounts’ investment strategy, such Accounts may offer potential counterparties different or competing investment offers as compared to the Account, which may lead to the Account and the Accounts competing for investment opportunities (it being understood that such arrangements may give rise to conflicts of interest that may not necessarily be resolved in favor of the relevant Accounts). Because of the different legal rights associated with debt and equity of the same issuer, Castlelake may face a conflict of interest in respect of the advice it gives to, and the actions it takes on behalf of a Fund versus another Fund or Account (e.g., the terms of debt instruments, the enforcement of covenants, the terms of recapitalizations and the resolution of workouts or bankruptcies), and the action taken for an Account investing in the equity of an issuer may be adverse to the Fund investing in the debt of the same issuer, particularly in the case of financial distress of an issuer. If an Account has the potential to incur a loss on its investment as a result of such difficulties, Castlelake may have an incentive to cause an Account (or the Fund) to provide such additional financing even though doing so is not considered to be in the Account’s (or the Fund’s) best interest. Similarly, if additional equity capital is necessary to support, enhance or protect the value of an investment, an Account may have an incentive to not provide such additional capital to limit their own losses, or if provided, to provide it in an aggregate amount that is less than the amount required. Given the nature of such conflicts and legal constraints (including bankruptcy laws), there can be no assurance that any such conflict can be resolved in a manner that is beneficial to the Fund and/or an Account. It is possible that in a bankruptcy, insolvency or similar proceeding, the Fund’s interest may be subordinated or otherwise adversely affected by virtue of the involvement and actions of an Account relating to its investment. Where an Account is a creditor of an issuer senior to the Fund, the Account may take actions in its own interests with respect to its rights as a creditor (e.g., with respect to breaches of covenants) that may be adverse to the interests of the Fund as a subordinated debt holder compared to that of the Account. In such circumstances, Castlelake may, to the fullest extent permitted by applicable law, take steps to reduce the potential for conflicts between the interests of the Fund and the Accounts, including causing one or more of such Accounts to take certain actions that, in the absence of such conflict, it would not take. Any such step could have the effect of benefiting Accounts or Castlelake at the expense of the Fund. Interfund Transactions. Castlelake is permitted to determine that a purchase, sale, lease, cross-fund financing or participating by an Account position from or to one or more of the Accounts to another is in the best interests of both Accounts. For example, one Fund could acquire investments from unrelated sellers and may re-offer a portion of such investments to affiliated investment vehicles, including those that were subject to legal, fiscal or other restrictions on

participating in the original transaction. Alternatively, an affiliate can acquire an investment from an unrelated seller in anticipation of offering it to another Fund at a future date if the latter Fund does not have available capital to make the investment when it is being marketed by the unrelated seller. This could also arise, for example, if one Fund is being wholly or partially liquidated, while another account has cash available for investment. An Account reserves the right to acquire certain assets from the other Accounts or sell such assets to the other Accounts, provided that Castlelake concludes that such transaction is in the best interests of each participating account. The Funds are permitted to acquire investments from or sell investments to an affiliate of Castlelake that is in the business of originating and syndicating loans or other assets, or originate and syndicate such loans or other assets itself and sell them to the other Accounts or third parties. Furthermore, the Funds are expect to exit or partially exit an investment or a series of related investments through contribution of such assets to an affiliated securitization or similar vehicle established by Castlelake or its affiliates in which the Funds would, among other investment structures and types of holdings, typically retain a relatively small investment in a junior tranche on a non-recourse basis while the senior tranches would typically be offered to third parties, including banks, but could also be held initially or through market purchases by other Accounts. For a securitization vehicle, the Funds would typically hold junior tranches on a non-recourse basis while the senior tranches would typically be offered to third parties, including banks. In addition, Castlelake has established warehouse financing facilities in order to finance aircraft purchases for multiple participating Funds. Because the lenders in the warehouse facilities have cross collateralized aircraft financed by the participating Funds, it is possible that an investment made by one Fund may not be able to satisfy its debt obligations to the warehouse facility and could rely on the cash flows from investments owned by other Funds that are utilizing the warehouse facility. Subject to relevant Offering Document, Castlelake will be entitled to collect and retain, directly or indirectly, servicing (or advisory) and disposition fees with respect to any such asset backed debt vehicles, with only a portion of such fees attributable to the Fund’s equity investment being applied to offset against the management fee, as further described in “Service Company Fees” below. The Funds are permitted to acquire certain assets from other Accounts or sell such assets to other Accounts, provided that Castlelake concludes that such transaction is in the best interests of each participating account. In connection with such transactions, Castlelake seeks to make determinations of competitive pricing based on its consideration of a number of factors, which are generally expected to include third-party pricing and/or market data with respect to comparable transactions, and other methodologies determined by the General Partner to be appropriate under the circumstances. While Castlelake generally intends to obtain third- party data regarding the pricing by third parties of similar transactions, relevant comparisons may not be available (and in certain circumstances will not be available) for a number of reasons, including, without limitation, as a result of a lack of sufficient comparable transactions for similar assets in the market or the confidential and/or bespoke nature of the type of transaction or assets. Therefore, such market comparisons may not result in precise market terms or pricing for comparable transactions. In addition, Castlelake is in the process of forming a fund (the “Operating Platform Fund”) with an investment strategy designed to acquire asset originators. If successful, Castlelake expects that the Operating Platform Fund will also serve as a source of asset origination for the Funds. The Operating Platform Fund in addition to originating assets, it is expected that the companies owned by the Operating Platform Fund would service the assets sourced or originated by it. To the extent

an asset originator is acquired or formed by the Operating Platform Fund and transacts with the Funds, Castlelake will notify the Advisory Committee of such arrangement in accordance with the terms of the Offering Documents. A Fund is permitted to acquire securities, loans and other credit assets originated, structured, sourced, placed and/or arranged by portfolio companies (including platform investments) of Accounts (including, the Operating Platform Fund if formed), without the need to obtain investor or relevant Advisory Committee consent. In connection with such activities, conflicts of interest will arise with respect to, among other things, the role of the portfolio company in such transaction, including the information available to such portfolio company (or Castlelake) with respect to such transaction and the fees and other terms (including as to whether such terms are at market rates) on which such person is participating in such transaction (for the avoidance of doubt, Castlelake is permitted to cause the Funds to enter into such transactions without the need to obtain a third-party price determination). These purchases and sales will cause conflicts of interest, including with respect to the consideration paid in connection therewith and the other terms and conditions of such transaction. Except as set forth above with respect to transactions between the Funds and asset originators acquired or formed by the Operating Platform Fund, it is generally not expected that the investors or the Advisory Committee will have oversight or advance knowledge of the terms and conditions of any such transactions. While these transactions with related parties expand the universe of opportunities that are available to Castlelake, all Funds will not necessarily derive a benefit from each such transaction, and the Funds that are parties to a particular transaction may have divergent interests. In order to minimize the conflict, Castlelake conducts any such transactions on an arms-length basis, including documentation/rationale to support fair market value of the purchase, lease or contribution of assets. In addition, Castlelake reports annually to Funds’ Advisory Committees regarding any key interfund transactions. If required by the Offering Documents, Castlelake will consult with or seek advice by, or consent form the Advisory Committees of the relevant Funds. Investors will have no opportunity to participate in the evaluation of the terms or merits or valuation of any such transactions and will be bound by any consent of the Advisory Committee. Advisory Committee. Castlelake will establish an Advisory Committee for the Funds composed of investors in the Funds selected by the relevant General Partner (all of whom are, and any additional members will be, unaffiliated with the applicable General Partner). A conflict of interest could exist when some, but not all, investors are permitted to designate a member to the Advisory Committee. Except where the Offering Documents specifically requires that a matter be brought to the Advisory Committee, the relevant General Partner will have sole discretion to decide whether to present any potential conflict to the Advisory Committee. In the event that a General Partner consults with the relevant Advisory Committee as to certain potential conflicts of interest, it could be disadvantageous to the investors, including those investors who do not designate a member to such Advisory Committee, and the interests of the members of the Advisory Committee could not be aligned with the other investors. Furthermore, the members of an Advisory Committee cannot be expected to be experts in alternative asset investing, and, as a result, certain of the Advisory Committee’s determinations could, in fact, adversely affect the performance of the relevant Fund.

To the fullest extent permitted by law, none of the members of the Advisory Committees, nor the investors and/or investors in any parallel investment entities on behalf of whom such members act as representatives, if applicable, shall owe any duties (fiduciary or otherwise) to any other investor in respect of the activities of the Advisory Committees and each member shall be entitled to consider solely the interests of the investor such member represents in connection with his or her service in the Advisory Committees. Also, members of the Advisory Committees are expected to have conflicts of interest that do not disqualify such members from voting or consenting to matters submitted to the Advisory Committees for consideration or review. In addition, members of the relevant Advisory Committee are expected to have various business and other relationships with Castlelake and its partners, employees and affiliates (and could be investors in, and/or serve on similar committees of other Castlelake funds or arrangements, including those engaged in transactions with the Funds). The presence of these other relationships could influence their decisions as members of such committee. Under the Offering Documents, a Fund’s Advisory Committee generally has the ability to review and waive compliance with certain provisions thereof, including consenting to conflict of interest situations, as well as certain approvals or consents required by U.S. federal securities laws. Pursuant to the terms of the Offering Documents, all limited partners are bound by the determinations of the Advisory Committee, regardless of whether an individual limited partner is represented by a member of the Advisory Committee. A Fund’s Advisory Committee is expected to be comprised of representatives of limited partners with divergent interests, objectives, regulatory treatment, tax sensitivities, portfolio compositions, experience and other factors. In addition, certain Advisory Committee members are expected to have various business and other relationships with Castlelake (including longstanding investing relationships) and its partners, employees and affiliates. In certain circumstances, these factors will influence Advisory Committee members to be more aligned with Castlelake and the relevant General Partner and favor proposals brought to the Advisory Committee; in other circumstances, these factors will make Advisory Committee members more likely to oppose these proposals. Advisory Committee members are expected to be subject to potential conflicts of interest in approving or rejecting proposals based on factors that are applicable to the firms they individually represent, rather than considerations relevant to limited partners as a whole. In many cases, limited partners (including limited partners making commitments in excess of certain amounts) are expected to request (by Side Letter or otherwise) a role on the Advisory Committee, and Castlelake expects to be subject to varying incentives and potential conflicts of interest in determining which limited partners will be permitted to appoint a representative thereto. A General Partner is authorized to appoint limited partners to the advisory committee of its Fund in its sole discretion, and is permitted to consider various factors including the timing and amount of a limited partner’s commitment to a Fund or future Fund, their perception of a limited partner’s effectiveness on an Advisory Committee, legal and regulatory considerations, the interests of the limited partner and the degree to which they are likely to align with the relevant Fund and the General Partner and other factors. Castlelake is permitted to seek the consent of the relevant Fund’s Advisory Committee(s) to approve conflicts, although based on these varying incentives limited partners should not expect that every vote cast by an Advisory Committee member, or decision made by an Advisory Committee as a whole, will fully represent their individual interests.

Aggregation of Trades. Situations can arise in multiple Funds seek to acquire or dispose of an investment, but it is not possible under prevailing market conditions to fill the entire order for more than one of these accounts at the same price that would be obtainable if an order were placed for only one of the accounts. In such situations, whenever transactions are executed on behalf of the Funds, Castlelake’s policy is to seek an allocation of the trades among the participating accounts in such a manner that, to the extent feasible, no participating account receives less favorable treatment than any other participating account. In order to achieve this objective in situations involving contemporaneous trades, Castlelake is authorized to arrange for the placement of orders on a combined basis so that each participating account experiences the same average price for the trade. The combination or coordination of orders as described above will not be deemed to constitute participating accounts acting in concert with respect to the securities purchased or sold or otherwise constituting a group for any other purpose. Investments in Existing ABS Securitization-Like Vehicles. Funds are permitted to purchase interests in or invest in, in each case, on the secondary market, certain ABS securitization-like vehicles established by Castlelake or its affiliates in which other Funds have exited, or have partially exited, an investment by contributing their assets to such vehicle. The other Funds typically will, among other investment structures and types of holdings, retain an investment in a junior tranche on a non-recourse basis. Castlelake and/or its affiliates will generally act as servicer and receive compensation from such ABS securitization-like vehicles. Castlelake will be entitled, directly or indirectly, to collect and retain any such compensation (whether in the form of servicing, advisory, disposition or any other type of fee or expense) with respect to any such ABS securitization-like vehicles without the need to offset such compensation against a Fund’s management fee except as otherwise provided in a Fund’s Offering Documents. In addition, any and all costs and expenses or other amounts that are borne or paid by a Fund, directly or indirectly, in respect of its investment in such ABS securitization-like vehicle will not offset the management fee. For the avoidance of doubt, the foregoing shall not apply to any ABS securitization-like vehicle in which a Fund has exited, or has partially exited, an investment by contributing assets to such vehicle. Pooled Asset Purchases. There may, in some cases, be opportunities for Funds to acquire a portfolio of assets from a seller on a pooled basis (i.e., a pool of assets), whether required by the seller or deemed advisable by the Fund in light of commercial and/or other considerations. Accordingly, there may be circumstances where there is a seller who is seeking to dispose a pool or combination of assets where more than one Fund participate as a buyer in a single or related transactions with a particular seller where all or certain of such assets are specifically allocated (in whole or in part) to specific Funds as part of the same transaction or related transactions. The allocation of such assets generally would be based on Castlelake’s determination of, among other things, the type of asset, age of asset, expected risk-return of such asset, lease status (if applicable), access to financing and other factors. In any such case the asset specific purchase price paid to a seller would be allocated among the Funds based on a determination by Castlelake as to the value of the assets, which may or may not be consistent with how the purchase price was allocated as a result of the negotiations between or among, the seller and Castlelake.

Given that only certain of the assets in the portfolio may be suitable for each Fund, such transactions raise potential conflicts of interest, including where the investment of each Fund is necessary or otherwise being used to complete the transaction or to support the value (or may support the value) of another Funds’ assets in the portfolio. These conflicts are heightened to the extent the relevant assets do not have a readily ascertainable value, and there generally can be no assurance that the price at which such transactions are entered into, or the price allocated to the assets that the Fund will acquire, represents what would ultimately be the asset’s fair value. The foregoing paragraphs also hold true with respect to collective dispositions by Fund and one or more of the other Funds of a pool of assets. Castlelake intends that any such transactions be conducted in a manner that it believes in good faith to be fair and equitable to the Fund over time and considering such factors as the General Partners deem relevant. Aviation Financing. Under certain circumstances, an Account may make a loan to, or an investment in, an airline (or any other Person) that is expected to sell aircraft to, or lease or purchase aircraft from, one or more of the other Accounts, or in an airline (or any other Person) that has already leased or purchased, or concurrently will lease or purchase, aircraft from, or sold aircraft to, one or more of the other Accounts or vice versa. As a result, Castlelake and the participating Accounts may have conflicting interests in negotiating the terms of such financing, purchase or other agreements. In negotiating the purchase price of the aircraft and/or pool of aircraft and/or the price of the financing, the rate of interest or stated dividend yield of such securities or loan, the nature of the covenants and other terms and conditions of such securities or loan, the Accounts and/or Castlelake may have interests that conflict. In that regard, actions may be taken by the Accounts and/or Castlelake that are adverse to the other Accounts. Such conflicts could also exist in the negotiations of amendments or waivers or in a workout or bankruptcy as well as the enforcement or lack thereof of any payment default. It is possible that in a bankruptcy proceeding, an Accounts’ interests could be adversely affected by virtue of the other Accounts’ involvement or vice versa. It may not be feasible for Castlelake to reconcile the conflicting interests of the Accounts in a way that protects the interests of all Accounts. An opportunity to provide senior asset-based funding to airlines or other purchasers of aircraft could be presented. Castlelake expects this financing activity to generally focus on new deliveries or young aircraft, but potential purchasers of aircraft from certain Accounts may also seek financing. Certain Accounts could provide an alternative financing source to enable additional purchasers to transact and potentially drive better results for the selling account. While not expected by Castlelake, there can be no guarantee that the availability of financing from other Accounts would not be a condition to a purchaser bidding on an aircraft being marketed by an Account. Aviation Lending. There may be opportunities to provide senior asset-based funding to airlines or other purchasers of aircraft. Castlelake expects this financing activity to generally focus on new deliveries or young aircraft, but potential purchasers of aircraft from the Accounts may also seek financing. The Funds may provide an alternative financing source to enable additional purchasers to transact and potentially drive better results for the selling Fund or Funds. Castlelake does not expect that the availability of financing from one Fund or Vehicle to be a condition to a purchaser bidding on an aircraft being marketed. The potential conflict of interest in purchaser financing is commercially mitigated by the auction process run by an investment team primarily

focused on aviation lending within Castlelake’s aviation leasing platform, as well as by the depth and scope of Castlelake’s sales activities that generate many offers. Servicing Fees from Vehicles. Castlelake and/or its management company affiliates enter into servicing agreements with the Vehicles, debt facilities and other financings and are permitted to do so for certain Fund investments or entities. Pursuant to these servicing agreements, Castlelake and/or its affiliates receive certain fees. Because these fees are generally paid at the Vehicle, facility or other financing level, both equity owners, such as the Funds, and third-party debt owners or lenders bear such fees. Castlelake is subject to a conflict of interest in creating these Vehicles, facilities and other financings because of its ability to receive additional compensation by retaining all or a portion of these fees. Castlelake addresses this conflict by ensuring that servicing fees attributable to the Funds’ investments are offset against each Fund’s management fee so that, in addition to the payment of management fees, a Fund does not effectively bear the fees with respect to its allocable portion of its investment in the Vehicles or other entity, provided that in some instances the offset may be limited as further detailed in the Offering Documents. As the servicing fee offset is no longer applicable if a Fund no longer has an investment in the Vehicle or other entities or when a Fund ceases to pay management fees, Castlelake could have an incentive to either monetize the Fund’s equity position and/or delay the process of monetizing the investments subject to such financings. In addition, Castlelake receives additional compensation when there is no offset of servicing fees associated with the debt or investments not held by the Funds. Castlelake retains all servicing fees that are paid by any third parties with respect to investments in which the Funds also invest. Service Company Fees. Castlelake expects that the Accounts will enter into arrangements with Service Providers (“Service Companies”) for specific assets held by an Account. As further discussed below, service Companies may be affiliated with Castlelake, or in some cases, Castlelake itself may act as a Service Company. The services of such Service Companies are expected to include asset sourcing or referral, asset or collateral management, debt servicing, facility management, loan origination, administration and/or due diligence services to the Account or its portfolio investments (the “Services”). Services are expected to typically be provided by a Service Company pursuant to service or management agreements between the Fund (or an SPV in which the Fund owns an interest) and such Service Companies. These agreements can provide for the payment for the Services or other fees (each of which are in addition to Castlelake’s management fees and Carried Interest and are not subject to an offset except as provided below with respect to Castlelake affiliated Service Companies or as otherwise set forth in a governing agreement for a Fund) that are expected to be determined in accordance with one or more of the following methods: (i) a percentage of the value of the assets being serviced, (ii) a percentage of the equity invested in the assets being serviced, (iii) a percentage of the cash flows from the assets being serviced, (iv) a percentage of the net return from the assets being serviced and/ or (v) a flat fee per asset serviced or service. For example, payments in respect of facility management and similar services are expected to be charged as a running fee or an upfront fee (e.g., the net present value of a running fee) or a combination of both. While Castlelake will seek to ensure that any upfront fees will be reflective of the services provided, there can be no assurance that any such upfront fees will be returned or reimbursed in the event the services in connection with such upfront fees are not provided in full or at all. Some incentive fees may be set up as profit-sharing arrangements payable, on a temporary or permanent basis, to servicers of specific assets which profit sharing arrangements will likely be based on specialized expertise, systems and processes

(including trade secrets) and other relevant considerations, as well as the performance of the specific assets that they service. It is possible that certain Service Companies receive incentive compensation, even though the Fund, as a whole, does not have net capital appreciation. In the case of servicing (including collateral management, debt servicing, facility management, administration and loan origination) or disposition fees received by Castlelake or a management company affiliate in connection with the Fund’s investments (excluding, for the avoidance of doubt, fees that accrue to the Accounts or their portfolio companies or investments and fees paid to any Platform Servicing Companies (as defined below), each of which will not offset the management fee), a portion of such fees attributable to the Fund’s equity investment will be offset against the management fee, to the extent provided in a Fund’s Offering Document. However, for the avoidance of doubt, the management fee will not be offset by any portion of servicing or disposition fees attributable to leverage utilized in connection with any such Fund investments. In determining the amount of leverage with respect to each investment, Castlelake will be subject to a potential conflict of interest in light of its ability to retain a portion of servicing and disposition fees attributable to the debt financed portion of the Fund’s investments. Please see “Investments in Transactions by Multiple Accounts” for a description of the limitations on management fee offsets by transaction fee amounts attributable solely to the Fund. The Account reserves the right to purchase interests in or invest in, in each case, on the secondary market, certain ABS securitization-like vehicles established by Castlelake in which the Accounts have exited, or have partially exited, an investment. Castlelake and/or its affiliates expect to receive compensation from such ABS securitization like vehicles, and for the avoidance of doubt, in certain circumstances as set forth in the relevant Offering Documents, any such compensation will not offset against the management fee. To the extent any of the Funds establish Service Companies to support an investment or investment platform, services may be provided to investments made by other Funds and will not offset a Fund’s management fee. This will result in one or more Funds being entitled to receive and retain fees for providing services to other Funds. In these circumstances, Castlelake would expect to compare the cost and level of services provided with those available from third parties to ensure fair market arrangements. Subject to the terms of the particular arrangement or agreement with the Service Company, the Fund is permitted to replace any Service Company as it deems appropriate. Platform Servicing Companies. Castlelake also holds interests through affiliated companies in one or more Service Companies (each, “Platform Servicing Company” and, collectively, the “Platform Servicing Companies”). Platform Servicing Companies are service companies or other similar persons (excluding, for the avoidance of doubt, any broker-dealer registered with FINRA) that are owned, in whole or in part, directly or indirectly, by Castlelake or any of its affiliates and that, subject to certain oversight by Castlelake and any of its affiliates, and provide services, including but not limited to loan sourcing, referral, collateral, reporting, diligence, loan and other investment-related (e.g., real assets) origination, administration and/or other similar debt-related and other investment-related services, on a temporary or permanent basis, to one or more investment entities or servicing platforms which may be owned, in whole or in part, by the Fund. Castlelake currently holds interests in the two Platform Servicing Companies described below and may hold interests in other Platform Servicing Companies in the future. Loans

and other investments originated and/or sourced (and ultimately serviced) by a Platform Servicing Company could be appropriate for the Accounts, and Castlelake is permitted to allocate such loans or other investments to the Accounts for direct or indirect investment. Any origination, upfront, servicing, administration, compensation (including salary and/or bonuses), incentive based, or other similar fees paid to, or profit sharing or expense reimbursement arrangements entered into by, a Platform Servicing Company (“Platform Service Company Fees”) will not offset or reduce the management fee (including, for the avoidance of doubt, where such fees are shared by the Platform Servicing Company, in whole or in part, with Castlelake or its affiliates, and including, for the avoidance of doubt, where such fees are generated with respect to a Fund’s allocable portion of any portfolio investment, where another portion of such portfolio investment (whether relating to different parts of the debt or capital structure or otherwise) is syndicated or otherwise sold to another Person following a Fund’s investment therein). A Fund will directly bear or indirectly bear through portfolio investments and other entities in or through which such Fund invests, some or all of the compensation costs (including salary and/or bonuses) of Platform Servicing Companies to the extent that any Platform Servicing Companies are engaged by the Fund or the portfolio investments and other entities through which the Fund invests. Platform Servicing Companies may in certain circumstances also be entitled to reimbursement for expenses incurred while providing services to Castlelake, the Fund and/or the Accounts, and the Fund will reimburse directly, or indirectly through portfolio investments and other entities in or through which the Fund invests, such Platform Servicing Companies for their expenses. None of the compensation and expense reimbursement received by such Platform Servicing Companies will be shared with the Fund or offset against the management fee (whether or not such compensation or expenses are generated with respect to the Fund’s, an Account’s or a third-party’s allocable portion of a portfolio investment, where such portfolio investment or tranche thereof (whether relating to different parts of the debt or capital structure or otherwise) is syndicated or otherwise sold to another Person following the Fund’s investment therein). To the extent a Platform Servicing Company provides services to an investment of the Fund, Castlelake will provide notice of such arrangement, consistent with the terms of the Partnership Agreement to the Advisory Committee. Prior to or at the time of establishing a Platform Servicing Company, Castlelake will obtain a third-party market study to demonstrate that such Platform Service Company Fees and other amounts to be paid to such Platform Servicing Company are, in Castlelake’s view, generally consistent with market terms for a comparable provision of services and Castlelake will use commercially reasonable efforts to ensure that such Platform Service Company Fees and other amounts to be paid to such Platform Servicing Company are generally consistent with such market terms, with such study generally to be provided to the Advisory Committee at the outset of the platform Servicing Company relationship for a particular Fund and updated on an annual basis. Castlelake will disclose to the Advisory Committee or the investors of a Fund, on an annual basis, the aggregate amount of any fees paid by or in respect of a particular Fund to a Platform Servicing Company (as well as the aggregate amount of any Structuring and Syndication Fees which are paid to a Castlelake person in respect of the Fund’s allocable portion of a Portfolio Investment (as discussed below)). Notwithstanding anything herein, Castlelake does not represent that any market study regarding Platform Service Company Fees ultimately will be accurate, comparable or relate specifically to the assets, services or comparable markets to which such rates or terms relate.

Aequum Capital Financial, LLC (“Aequum”) is a specialty finance lender focused on sourcing, structuring and servicing loans to small and medium sized businesses, primarily in the United States. Castlelake holds a majority interest in Aequum. The Accounts are expected to hold loans sourced and serviced by Aequum. Concora Credit, Inc. (“Concora”) is a provider of consumer credit, including direct-toconsumer credit card programs (GPCC), for non-prime consumers. The company, previously known as Genesis Financial Solutions, administers and services private-label credit card programs through point-of-sale partnerships with merchants and retail partners. Castlelake holds a majority interest in Concora. Certain Accounts are party to forward-flow transactions with Concora for GPCC assets, which will continue to be serviced by Concora, and are expected to purchase additional assets from Concora in the future. Lendmarq, LLC (“Lendmarq”) is a residential lending platform that sources and services secured loans to borrowers who typically business focused. Loans sourced by Lendmarq include fix and flip loans, bridge loans, construction loans and rental loans. Castlelake holds a minority interest in Lendmarq, with an option to increase its interest to a controlling stake. The Accounts hold loans sourced and serviced by Lendmarq. Castlelake will face a conflict of interest in selecting and/or replacing a Service Company given its ownership interest in any Platform Servicing Company and will be incentivized to utilize Platform Servicing Companies. As noted above, any fees payable to a Platform Servicing Company will not offset or reduce the management fees or otherwise reduce any fees or expenses paid to Castlelake and/or its affiliates. Accordingly, Castlelake is incentivized to utilize a Platform Servicing Company to generate additional revenue for such Platform Servicing Company. Affiliated Servicing Fees. Castlelake and/or its management company affiliates (including any Platform Servicing Company) expect to act as Service Companies and receive compensation from certain of the Accounts’ investments (such as via asset backed debt vehicles) and/or third parties, including, without limitation, collateral and/or asset management, debt and other investment servicing, facility management, administration and disposition fees from the Accounts and the credit and other investment providers in connection with the Funds’ investments in accordance with the underlying financing documents or other agreements with respect to the relevant entities. Fees payable to management company affiliated Service Companies (other than any Platform Servicing Companies other than as described above) may be structured (but will not always be structured) so that the Fund does not effectively bear any such amounts with respect to its allocable portion of the applicable investments. Castlelake addresses this conflict through special allocation of the relevant fees to investors other than the Funds, or if the Funds are subject to such fees payable to Castlelake or its affiliates (other than the Platform Servicing Companies), such amounts (net of related expenses) will be applied to offset the management fee payable to Castlelake by each Fund, subject to each Fund’s Offering Documents. In the case of servicing (including collateral management, debt servicing, facility management, administration and loan origination) or disposition fees received by Castlelake or its affiliates in connection with a Fund’s investments (excluding (i) fees that accrue to other Funds or their portfolio companies or investments or (ii) fees paid to any Platform Servicing Companies, each of which will not offset

Castlelake’s management fee other than as set forth in the Offering Documents), a portion of such fees attributable to that Fund’s equity investment will be offset against Castlelake’s management fee, subject to each Fund’s Offering Documents. However, Castlelake’s management fee will not be offset by any portion of servicing or disposition fees attributable to leverage utilized in connection with any Fund investments. For example, if equity contributed by Accounts subject to an offset represents 50% of the acquisition cost and the remainder is financed through borrowing, only 50% of the servicing and disposition fees received by Castlelake or its affiliates will offset the management fee. In determining the amount of leverage with respect to each investment, Castlelake will be subject to a potential conflict of interest in light of its ability to retain a portion of servicing and disposition fees attributable to the debt financed portion of the Fund’s investments. To the extent any of the Funds establish Service Companies to support an investment or investment platform, services may be provided to investments made by other Funds. This will result in one or more Funds being entitled to receive and retain fees for providing services to other Funds. In these circumstances, Castlelake would expect to compare the cost and level of services provided with those available from third parties to ensure fair market arrangements. Further, the terms of the relevant arrangement or agreement with a Service Company (including a Castlelake owned Service Company) may provide for a termination fee, accelerated payments or other compensation to the Service Company upon the termination or replacement of the arrangement or agreement with such Service Company; provided, that in the case of a Castlelake affiliated Service Company, the Fund’s allocable share (as described above) of the relevant fees, payments or other compensation paid to such Castlelake affiliated Service Company may offset the management fee if so provided in the Offering Documents of such Fund. Additionally, certain current servicing agreements do not provide a right to unilaterally replace the Service Company (including a Castlelake owned Service Company), and in such case, Castlelake and/or the Service Company may seek termination fees, accelerated payments or other compensation in the event of such termination or replacement, subject to potential offset as set forth above. The ability for a Castlelake affiliated Service Company to receive termination fees, accelerated payments or other compensation in connection with the termination or replacement of such Service Company creates a potential conflict of interest for Castlelake as it may incentivize Castlelake to favor investment opportunities that provide the capacity for third parties to participate, or to dispose of investments at inopportune times, for lesser amounts or to inopportune counterparties in order for such Castlelake affiliated Service Company to receive termination fees, accelerated payments or other compensation in respect of such third parties. Insurance Servicing Fees: One or more Fund currently holds, and other funds may hold in the future, an interest in a reinsurance company which reinsures credit insurance exposure backed by aviation assets and may hold interests in other insurance or reinsurance companies (each, an “Insurance Portfolio Company” or “Insurance Portfolio Companies”). Such Insurance Portfolio Companies may also reinsure credit insurance exposure back by non-aviation assets. Castlelake, or its management company affiliates, provide servicing with regard to the underlying aviation assets in the current investment and generate fees for such services, and may provide similar services with respect to non-aviation assets (“Insurance Servicing Fees”). In the case of these Insurance Servicing Fees received by Castlelake or its management company affiliates in connection with certain Accounts’ investments in Insurance Portfolio Companies, the Insurance

Servicing Fees may be subject to offset against management fees if so provided in the Offering Documents of such Account. If Insurance Servicing Fees are subject to offset against management fees, generally only the portion of such Insurance Servicing Fees attributable to the amount of the Accounts’ capital invested in the Insurance Portfolio Companies relating to the underlying insurance policies as a percentage of the total principal amount of the loans (or other financing), in whole or in part, for which insurance is provided by such Insurance Portfolio Companies will be offset against the management fee. For the avoidance of doubt, the management fee will not be offset by the portion of such Insurance Servicing Fees attributable to the portion of the loans (or other financing), in whole or in part, for which insurance coverage is not provided by an Insurance Portfolio Company (and, for example, is provided by a third-party insurance or reinsurance provider). Therefore, there will be no applicable offset to Insurance Servicing Fees to the extent an Insurance Portfolio Company does not provide any insurance coverage. As a result of the foregoing, Castlelake or its management company affiliates will, from time to time, receive Insurance Servicing Fees and can be incentivized to participate in and pursue investments in Insurance Portfolio Companies, or can be incentivized to reduce premiums charged by Insurance Portfolio Companies and/or participate in riskier reinsurance transactions (whether due to the lower creditworthiness of the underlying borrower to whom the reinsurance transaction pertains, the value of the collateral or other factors), in each case, due to the prospect of earning such Insurance Servicing Fees. Third-Party Servicing. Similarly, Castlelake, on behalf of the Fund or an Account, may submit a bid to acquire an asset, enter into a lease arrangement or to provide financing to a counterparty, and such counterparty may reject the bid but nonetheless choose to engage Castlelake or an affiliated Service Company (including, but not limited to CASL) to provide services to such third-party. Castlelake may also become aware of opportunities in the market through discussions on behalf of the Fund or an Account where third-party servicing is needed, but there is no immediate opportunity to enter into a transaction on behalf of the Fund or Account. In such transactions, Castlelake is exposed to a conflict because the transaction creates an incentive for Castlelake to choose buyers, sellers, lessors, lessees or other counterparties for the Fund’s assets or debt instruments (or underwrite a loan to or for a borrower or underwrite or syndicate to or for financial buyers) who will maintain the servicing or development relationship, which can create an incentive to sell the assets or debt instruments at a lower value (or underwrite a riskier loan in favor of more servicing opportunities) than would otherwise be received (or earlier than would otherwise be the case or to a less creditworthy counterparty) or to make other investment or divestment decisions based on anticipated servicing or other fees. Additionally, when assets or debt instruments are sold by a Fund (or a loan is repaid) but Castlelake or its affiliates maintain a servicing or development relationship with respect to the asset or collateral underlying such asset or debt instrument, Castlelake would generally be entitled to retain the servicing or development fees without such servicing or development fees offsetting or reducing the applicable management fee. As a result, while Castlelake’s ability to provide servicing or development to a third-party purchaser (or other third parties) could enhance a Fund’s exit opportunities, Castlelake is subject to a conflict of interest in that it is presented with opportunities to use a Fund to generate additional sources of income for itself. Similarly, as discussed above, when investments in Insurance Portfolio Companies are sold by a Fund, or where the loan or financing associated with reinsurance coverage provided by a Fund owned an Insurance Portfolio Company is repaid or assigned and the reinsurance coverage is cancelled or ceded to a third party reinsurance company, but Castlelake or its affiliates maintain a servicing relationship with the buyer, creditor or third party reinsurance

company such that Castlelake or its affiliates continue to provide Insurance Services in respect of the underlying collateralized aircraft or other aviation asset collateral, Castlelake would generally be entitled to continue generating Insurance Servicing Fees without any offsets to or reductions of the management fee and would be incentivized to accept a lower sale price , and/or to allow the Fund to bear the risk of inheriting legacy liabilities, operational issues, or adverse claims history for such Fund’s share in order to preserve such servicing rights, each of which could negatively impact returns. As a result, while Castlelake’s ability to provide Insurance Services could enhance a Fund’s exit opportunities, Castlelake is subject to a conflict of interest in that it is presented with opportunities to use a Fund’s former investments to generate additional sources of income for itself. Finally, Castlelake is expected to provide servicing and management to third parties on assets that are not held by a Fund (including through a Platform Servicing Company). Third-party servicing has potential to create an incentive for Castlelake in determining whether the third-party or the Fund (whichever is applicable) will be provided with a lease, financing, purchase or disposition opportunity. Castlelake seeks to mitigate these conflicts through the application of its conflict of interest policies and procedures. As discussed further above in “Engagement of Service Providers and Other Personnel”, the provision of the foregoing services by Castlelake and/or its affiliates and related parties and any such methodology (including the choice thereof and any benchmarking, verification or other analysis related thereto) involves inherent conflicts. Any fees, payments or expenses in respect of any such arrangements paid by the Fund to (or received by) Castlelake, the Accounts, their affiliates or their respective portfolio investments or portfolio companies, as well as the expenses, charges and costs of any benchmarking, verification or other analysis related thereto, will be retained by such persons and will not offset the management fee payable by the Fund, and will, in certain circumstances, result in incurrence of greater expenses by the Fund and its portfolio investments than would be the case if such services were provided by third parties. Furthermore, expenses incurred in direct connection with the making, maintaining, or disposing of an investment increase the invested capital in a portfolio investment as a result of being capitalized along with other transactionspecific expenses incurred by a Fund with respect to such portfolio investment and, therefore, result in an increase to the management fee base. In cases where CASL is used by Castlelake to provide any services in the context of a thirdparty servicing arrangement, Castlelake expects to compensate CASL on what it believes to be a fair and reasonable basis, taking into account the scope of services provided in the context of the overall servicing arrangement, the fees paid to CASL for similar services to the Fund or an Account and other factors. Castlelake anticipates that the primary method for determining CASL fees would be to allocate CASL costs and expenses across all CASL workstreams, whether for the Fund, the Accounts, Castlelake or third parties, on a pro rata basis. Although CASL generally participates in the process of seeking to set a fair and reasonable fee, the fact that Castlelake controls CASL will likely cause such discussions to be on an other-than-arm’s length basis. There is no guarantee that the fees charged by CASL in connection with third-party servicing arrangements will be comparable to what CASL might earn from an unaffiliated third-party. The fees generated by CASL for third-party services would go to reducing CASL’s operating costs which would, in turn, could reduce the fees, on a pro rata basis, paid by the Fund and the Accounts for services provided by CASL.

Structuring and Syndication / Arranger Fees. The Fund’s investments are generally expected to be privately negotiated transactions. Castlelake expects to have potential conflicts of interest in negotiating the terms and the type and amount of fees that Castlelake and/or its affiliates receive. For certain loans, including those in which a Fund invests or its portfolio investments are borrowers, Castlelake is permitted to syndicate all or portions of the loan(s) to Accounts or third party financing facilities, Castlelake will syndicate the financing facilities to the Accounts or thirdparty lenders and in such instances, fees received by Castlelake relating to such Accounts or thirdparty lenders do not offset the management fee (including, for the avoidance of doubt, where such fees are generated with respect to the Fund’s allocable portion of any portfolio investment, where another portion of such portfolio investment (whether relating to different parts of the debt or capital structure or otherwise) is syndicated or otherwise sold to another Person following or substantially simultaneously with the Fund’s investment therein). In addition, in certain Fund investments, Castlelake expects to structure financing senior or pari passu to a Fund’s portion of the investment. In these situations, Castlelake is permitted to typically seek to obtain the most advantageous financing for a Fund’s investment from traditional and non-traditional lenders. Investments structured in this way include unitranche loans where Castlelake structures a senior tranche, pools of assets where Castlelake structures senior financing within an asset purchasing vehicle or senior financing facilities for forward flow purchase contracts. In structuring these facilities Castlelake is permitted to earn a structuring fee as described above and will only offset the portion of such fee against the management fee that corresponds to a Fund’s allocable portion of the investment. In connection with Fund investments and related lending arrangements negotiated by Castlelake, Castlelake (or an affiliate) typically expects to receive some or all of the following fees from the Accounts, broker and/or a third- party lender including structuring, origination, placement, syndication, and/or arrangement fees (“Structuring and Syndication Fees,” sometimes also referred to as “Arranger Fees” or “Arrangement Fees”), which, in each case, do not offset the management fee, except to the extent of a Fund’s allocable portion of such investment (as set forth in the Offering Document). This may be arranged through one or more structures, including, without limitation, whereby (i) Castlelake originates a single tranche loan into an SPV which SPV then issues multiple tranches of debt instruments; (ii) Castlelake arranges with a third-party borrower to fund a multi-tranche loan structured by a third- party, which loan is allocated by Castlelake to one or more of the Fund, an Account and/or a third-party investor; (iii) Castlelake originates a unitranche loan and syndicates a portion of the loan across the Fund, an Account and/or a third-party investor by way of participation agreement or otherwise; (iv) Castlelake purchases an asset and concurrently arranges financing through securitization of the asset and the Fund, an Account and/or third-party investor then take different positions in the capital structure of such securitized asset; or (v) Castlelake owns an asset or investment that requires financing or refinancing and Castlelake arranges for a securitization of such asset or investment. In each of the foregoing instances, Castlelake (or an affiliate) typically expects to receive structuring, origination, placement, syndication, and/or arrangement fees, which, in each case, do not offset the management fee, except to the extent of the Fund’s allocable portion of such investment (as set forth in the Offering Document). Structuring and Syndication Fees received by Castlelake could relate to loans or portions of loans funded by third-party lenders, and in a scenario where Castlelake helps to arrange a multi-tranche loan that is funded directly to a borrower, a Fund that funds a junior tranche of such a loan would pay to Castlelake the Structuring and Syndication Fees with respect to the senior tranche(s) thereof funded by third-party lenders, without any offset to the Fund’s manage fee as further discussed below. Third parties are expected to participate in a

loan or credit facility where Castlelake has identified a lending opportunity with respect to which, due to size, profile or other considerations, Castlelake determines, in its sole discretion, it is appropriate to obtain participation from additional lenders. Loans made by third-party lenders may be senior to the Fund, a different tranche of the same seniority as the Fund and/or the same tranche as the Fund. Structuring and Syndication Fees are expected to be paid to Castlelake on account of Castlelake’s time, effort and resources spent on identifying additional lending parties, working with such third parties and structuring and negotiating the loan facilities for the participation and benefit of third-party lenders. Castlelake determines whether a particular loan is appropriate for syndicating to third parties in its sole discretion, considering such factors as are described above. Financings in relation to which Castlelake receives a structuring or arrangement fee could be structured through various investment structures, including, without limitation, any warehouse facility, term loan facility, CLO, private securitization, or other debt structure in which an Account and/or a third party participate (whether through a side-by-side co-investment or a post-investment syndication, and whether the Accounts and/or third party hold interests or rights at different levels of the debt or capital structure). As permitted under a Fund’s Offering Document, Structuring and Syndication Fees received by Castlelake (or its affiliate) will not offset the management fee to the extent such structuring fees are payable by, or earned with respect to, an Account or third-party, including, for the avoidance of doubt, in respect of (A) a bridge financing or any other portfolio investment (or portion of a portfolio investment) that is not ultimately retained by the Fund (including with respect to any portfolio investment (or portion thereof) syndicated or otherwise sold (whether relating to different parts of the debt or capital structure or otherwise)) to an Account or third-party following the Fund’s investment therein and/or (B) any investment (or portion of any investment) structured or arranged by Castlelake but ultimately made by, allocated to, or syndicated to persons (including Accounts or third parties) other than the Fund (even if such investment could have been made by the Fund and/or whether such portion is relating to different parts of the debt or capital structure or otherwise). Furthermore, Structuring and Syndication Fees received by Castlelake (or its affiliate) increase the invested capital in a portfolio investment as a result of being capitalized along with other transaction-specific expenses incurred by a Fund with respect to such portfolio investment and, therefore, result in an increase to the Management Fee base. The terms of Structuring and Syndication Fees and arrangement fees vary based on terms negotiated with such third-party lenders. Uncertainties Arising from NAV. The calculation of a Fund’s Net Asset Value will determine, among other items, the Price Per Unit, and the management fee and incentive allocation. The General Partner will rely on both external and internal valuations to calculate the Net Asset Value of the Fund and can include both observable inputs supported by market activity and unobservable inputs supported by little or no market activity. In the case of Level 3 assets of the Fund, market price quotations are unlikely to be readily available. Valuation methods are inherently imprecise and rely on significant judgment, subjectivity, and assumptions about the future which may or may not occur. Valuations do not necessarily represent the price at which an investment would sell since market prices of Level 3 assets can only be determined by negotiation between a willing buyer and seller. In addition, valuations must be based in large part on information that is both incomplete and available only as of a date preceding the date of the valuation. Markets and conditions may change materially after that date and prior to the date of the determination of Net Asset Value. Moreover, valuations of the same security can vary substantially from one dealer or pricing service to another and may fluctuate materially over short periods of time. Accordingly, valuations may not accurately reflect the values for which assets

could be sold between a willing buyer and seller, and such values could differ materially. Further, trading and other agreements may include termination provisions related to declines in the Fund’s Net Asset Value over certain periods of time. Material changes, fluctuations or differences in the Fund’s Net Asset Value could adversely affect the financial performance and operations of the Fund. The ultimate realization of the value of an investment depends on economic and other conditions that are beyond the General Partner’s control. If the Fund were to liquidate an asset, particularly in a forced liquidation, the realized value may be less than the amount at which the asset is recorded, which would negatively affect the financial performance of the Fund. The exercise of discretion in valuation by the General Partner presents conflicts of interest, including in connection with determining the amount and timing of distributions of incentive allocation and the calculation of management fees. Notwithstanding the valuation procedures set forth in the Partnership Agreement, the General Partner has an incentive to value such investments at a higher level in order to enhance performance reporting and to receive a higher management fee or other fees. Further, in connection with the General Partner’s discretion in valuing certain assets, the General Partner maintains discretion to determine whether certain assets have experienced an impairment in value. A permanent impairment or write-off of an investment would generally reduce the basis from which the management fee or other fees are calculated. The General Partner therefore has an incentive to hold onto assets or other investments that have poor prospects for improvement and/or to avoid or otherwise delay determining that an investment has been subject to a permanent write-off or impairment in order to receive ongoing management fees and/or other fees in the interim. Transactions with Former Employees. Former partners or employees of Castlelake may provide Castlelake with access to certain investment opportunities suitable for one or more Funds. In addition, if Castlelake determines that any Funds should invest in any such investment opportunities, Castlelake may engage former employees to provide certain services to the Funds and/or portfolio investments. In connection with these services, it is expected that such former employees would receive payments from, or allocations or performance-based compensation with respect to, the Fund and/or its portfolio investments. Former partners or employees may also be engaged to assist with the management, monitoring and monetization of investments, as well as assisting with due diligence and other operational support. Further, former partners or employees may serve as directors with respect to entities holding various investments held by the Accounts. Payments, allocations or performance-based compensation paid to former employees or entities which they control pursuant to the arrangements described above will generally be treated as Fund expenses and will not be subject to the management fee offset provisions, nor provisions of Offering Documents governing transactions with affiliates Castlelake. In addition, certain former Castlelake partners will have the right or be offered the ability to co-invest alongside the Funds in the portfolio investments which the former employee sources or for which the former employee serves as an asset manager (and for which such former employee would generally be entitled to receive performance-related incentive fees, which will reduce the Funds’ returns). Castlelake intends to mitigate any conflicts of interest by engaging former partners or employees only if it believes such engagement, based on the terms negotiated, is in the best interest of the Funds.

Board Participation. The investment programs of the Funds could enable Castlelake to place its representatives on creditors’ committees and/or boards of certain companies in which the Funds have invested. While such representation may enable Castlelake to enhance the sale value, it may also prevent Castlelake from freely disposing of investments and may subject Funds to additional liability. The Funds will typically indemnify Castlelake, its affiliates, or any other person designated by any of them for claims arising from creditors’ committee and/or board representation. Castlelake will attempt to balance the advantages and disadvantages of such representation when deciding whether and how to exercise its rights with respect to such companies, but the exercise of such rights could produce adverse consequences in particular situations. Additionally, certain Castlelake employees serve on boards of directors of portfolio companies which arise from governance agreements negotiated at the time of investment or restructuring of an investment. Such employees are not permitted to receive and/or retain compensation in connection with officer or board of director roles. In many cases, the Funds may be the sole equity holder of a company and thus the board and its members will be aligned with the Funds interests. However, there may be instances when a Fund is not the sole equity holder, and in such instances conflicts of interest may arise for individuals serving as directors. These individuals would in such cases have fiduciary duties to the company that are in conflict with the interests of the Funds. Further, the service as a director may limit the Funds’ ability to transact in the company’s securities or prevent Castlelake from sharing information with investors in the Funds. As noted above, former employees or partners may also serve on boards on behalf of Castlelake and will be subject to these same types of conflicts, provided that fees paid to former employees and partners are generally retained by such parties. Different Types of Investors. The Accounts are often commingled entities, and their investors are expected to be comprised of a variety of domestic, foreign and tax-exempt investors, which may have conflicting investment, tax and other interests. The conflicting interests of investors may adversely impact the nature of investments made by Castlelake, the structuring or acquisition of investments and the timing of disposition of investments. Conflicts may arise in connection with decisions made by Castlelake regarding an investment that may be more beneficial to one investor than another, especially with respect to tax matters. Castlelake is generally not required to take into account individual investor considerations in conducting the Funds’ operations, except that certain Side Letters may require it to do so and Castlelake may impose such requirements on the Account as a whole. Disclosure of Information. Certain investors in the Accounts will be subject to U.S. state public records or similar U.S. and non-U.S. freedom of information laws (“FOIA”), which may compel public disclosure of confidential information regarding the Accounts, investments and investors. The amount of information about investments that is required to be disclosed has increased in recent years, and that trend may continue. To the extent that disclosure of confidential information relating to the Account or its portfolio investments results from interests being held by public investors, the Account may be adversely affected. Castlelake may, in order to prevent any such potential disclosure, withhold information otherwise to be provided to such public investors and may do so with respect to all investors. To the extent that the General Partners determines in good faith that, as a result of FOIA, any governmental public access law, any state or other jurisdiction’s laws similar in intent or effect to FOIA, or any other similar statutory or

regulatory requirement, an investor or any of such investor’s affiliates could be required to disclose information relating to the Funds, their affiliates and/or any entity in which an investment is made (other than certain fund-level, aggregate performance information), which disclosure could, for example, affect the Fund’s competitive advantage in finding attractive investment opportunities, the General Partner could, to the fullest extent permitted by law, withhold all or any part of the information to be provided to such investor, as described in the Offering Documents. Without limiting the foregoing, in the event that any party seeks the disclosure of information relating to the Funds, their affiliates and/or any entity in which an investment is made under FOIA or any such similar law, the relevant General Partner could, in its discretion, initiate legal action and/or otherwise contest such disclosure, which could not be successful, and any expenses incurred therewith will be borne by the applicable Fund. Conversely, potential future regulatory changes applicable to investment advisers and/or the accounts they advise could result in Castlelake and/or the Funds becoming subject to additional disclosure requirements the specific nature of which is as yet uncertain. Further, disclosure of any such information by an investor pursuant to FOIA or any similar statute or regulation could have a material adverse effect on the Funds or one or more of their portfolio investments. Side Letters. Castlelake has entered into, and may in the future enter into, Side Letters with certain investors in the Funds which provide those investors with different and/or preferential rights or terms, which may include, without limitation, (i) more favorable fee and other economic arrangements (including discounts and terms applicable in exchange for closing by a specified deadline, making a certain size capital commitment or other parameters) with respect to such investors, including, but not limited to, higher preferred return rates and/or lower Carried Interest or management fee rates; (ii) excuse or exclusion rights applicable to particular investments or withdrawal rights (with the consent of Castlelake) from the Fund, including without limitation, as a result of an investor’s specific policies or certain violations of U.S. federal, state or non-U.S. laws, rules or regulations, such as so-called “pay-to-play” rules with respect to public pension plan investors (which may materially increase another investor’s pro rata interest in that particular investment (in the case of an opt-out) or all future investments (in the case of a withdrawal) and may reduce the overall size of the Fund); (iii) extension of certain information rights or additional or modified reporting (including customized reports) to such investor, including, without limitation, to accommodate special regulatory or other circumstances of such investor, which will be time-consuming, divert the attention of personnel and the management teams of Castlelake and its affiliates and the costs of which will be borne the Fund and are likely to be material, including on a cumulative basis over the life of the Fund; (iv) prior consent of Castlelake to certain transfers by such investor or other exercises by Castlelake of its discretionary authority for the benefit of such investor; (v) special priorities, rights and economic and other terms with respect to coinvestment allocation and participation; (vi) waiver of certain confidentiality obligations; (vii) consent rights to certain amendments to the Fund’s Offering Documents ; (viii) certain obligations or restrictions on Castlelake with respect to the exercise of its discretion on certain matters, including amendments, exercising default remedies and waiving confidentiality or terms; (ix) restrictions on, or special rights of such investor with respect to the activities of Castlelake; (x) rights or terms necessary in light of particular legal, regulatory or policy characteristics of an investor (including with respect to limitations on the ability to provide indemnification); (xi) certain adjustments with respect to economic provisions (including potential mandatory waivers of compensation as a result of certain violations of law with regard to public pension plan investors); (xii) additional obligations and restrictions of Castlelake and the Fund with respect to

the structuring of any particular Investment in light of the legal, tax and regulatory considerations of particular investor (including with respect to alternative investment vehicles); (xiii) agreements to assist with the taking or defending of tax positions; (xiv) the right of Castlelake to waive any requirements of investors to execute acknowledgements or other documents in connection with any subscription line or other credit facility; (xv) agreement to various sovereign immunity, jurisdiction and venue provisions applicable to certain governmental, sovereign, or other types of investors on behalf of Castlelake and/or the Fund (which could limit the ability to initiate or maintain legal proceedings against certain investors in certain jurisdictions); or (xvi) any other matters described herein, which may be more favorable than those offered to any other investors. As a result of certain Side Letters, investors holding the same interest will have different returns, or receive different information, depending on any arrangements applicable to a given investor’s interest in the Funds. In addition, if the relevant General Partner enters into a Side letter entitling an investor to be excused or excluded from a particular investment or withdraw from a Fund, (a) any election to be excused or excluded or to withdraw by such investor will increase the percentage interest of other investors in, and contribution obligations of other investors with respect to, future investments, and reduce the overall size of the relevant Fund and/or (b) the relevant Fund’s ability to consummate certain investments could be inhibited. Co-investment rights granted to an investor in a Side Letter or other similar agreement will, in certain cases, result in fewer co-investment opportunities (or reduced or no allocations) being made available to other investors. Castlelake is likely to have its own economic and/or other business incentives to provide certain terms to certain investors (e.g., based on commitment amount to a Fund or the timing thereof), the ability of an investor to provide sourcing or other services to Castlelake, its affiliates and personnel or an Account, or the potential to establish, recognize, strengthen or cultivate relationships that have the potential to provide longer-term benefits to Castlelake, its affiliates and personnel, or Accounts. Further, Side Letters may also relate to strategic relationships under which an investor agrees to make capital commitments to multiple funds managed by Castlelake or being an existing investment in an Account. Except where otherwise required by the terms of an applicable Side Letter, other investors will not receive disclosure of Side Letters or related provisions, and as a general matter, the other investors have no recourse against Castlelake in the event that certain investors have received additional and/or different rights and/or terms as a result of such Side Letters. Side Letters subject Castlelake to potential conflicts of interest, including in circumstances where an investor’s right to serve on the relevant Fund’s advisory committee results in the investor receiving additional information relative to other investors. To the extent an investor is subject to statutory or other limitations on indemnification, or otherwise negotiates rights relating thereto, other investors may be subject to increased losses, or be required to bear an increased portion of indemnification amounts. As a consequence of one or more limited partners being excused or excluded, or from regulatory, tax or other factors altering or limiting their participation in investments, the aggregate returns realized by participating or non-participating limited partners could be adversely affected in a material manner by the unfavorable performance of particular investments. Although Castlelake believes it to be unlikely, excuse rights requested or received by one or more limited partners (or such regulatory, tax or other factors applicable to such limited partners) representing a substantial percentage of the Fund have the potential to create significant variations in limited partner investment returns, or to influence or affect the investment strategy and pursuit of investment opportunities by Castlelake on behalf of a Fund as a whole. An

investor’s voting rights for regulatory or other reasons can be limited in circumstances specified in the Offering Documents; conversely, a limitation on one or more investor’s voting rights generally will increase the voting rights percentage of other investors. Further, limited partners with different domiciles or tax categorizations could receive different investment returns or amounts of tax basis and/or pay different levels of expenses, e.g., based on tax savings or ownership of AIV, “blocker” or other structures used to facilitate their investments. As a result, it is possible that a Fund or co-invest vehicle will benefit (or benefit disproportionately) from expenses borne in whole or in part by another Fund. Castlelake is generally not, subject to applicable law and various “most favored nations” provisions, under any obligation to give all investors notice of any Side Letters entered into absent an agreement to the contrary. Material Non-Public Information. Castlelake or its affiliates may acquire confidential or material non-public information or be otherwise restricted from initiating certain transactions. Because the Funds will not be free to act upon any such information, such Funds may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold. In addition, as a result of certain information wall procedures established between Castlelake and Brookfield, as well as the applicable of the laws, rules and regulations of certain jurisdictions, Castlelake could be restricted in its transaction activities notwithstanding have no access to confidential or material non-public information including in circumstances which could limit or otherwise restrict Castlelake’s investment activities to the detriment of the Funds. Castlelake may choose to limit the information, or withhold certain information, that would otherwise be disclosed to investors in the Funds due to its confidential nature. To the extent any investor becomes aware of any such confidential or material, non-public information, such investor may be restricted with respect to its own investment or other activities and/or be subject to certain laws, regulations or rules with respect to such confidential or material, non-public information. Castlelake or the Accounts may also be subject to confidentiality, other agreements or applicable law with or related to investments, which may prohibit Castlelake from disclosing certain information to the investors in the Accounts. Cross Transactions. In certain scenarios, Castlelake could seek to effect a purchase or sale or a participation, financing, or refinancing of an investment (a “cross transaction”) between a Fund and one or more Accounts, including in connection with forming any warehouse vehicle or any CLO or other activities. Subject to the terms of the relevant Offering Document, a Fund is permitted to, in particular, but without limitation, enter into cross transactions in connection with the acquisition of loans or other debt instruments or participations in such investments from Accounts. Without limiting the foregoing, subject to the terms of the relevant Offering Document, (i) a Fund could engage in cross-trades and cross-investments with the Accounts, (ii) none of the Accounts will be prohibited from acquiring, or otherwise engaging in transactions with respect to securities of any person (including a special purpose vehicle) in which a Fund has a financial interest (whether in the same or a different class of securities) or selling, divesting, making further acquisitions or otherwise engaging in transactions with respect to securities of such person, including following a co-investment, and (iii) a Fund will not be prohibited from acquiring, or otherwise engaging in transactions with respect to, securities of any person (including a special

purpose vehicle) in which any Account has a financial interest (whether in the same or a different class of securities) or selling, divesting, making further acquisitions or otherwise engaging in transactions with respect to securities of such person, including following a co-investment. Valuation. The Funds hold positions in non-marketable investments or other investments for which independent quotations are unavailable or are not reliable indications of the fair value of such Funds’ position. Castlelake is permitted to value such positions in its discretion, and the Funds are not required to obtain independent appraisals or valuations of any such positions. The process of valuing investments for which reliable market quotations are not available is based on inherent uncertainties and the resulting values may differ from values that would have been determined had an active market existed for such investments and may differ from the prices at which such investments ultimately may be sold. The exercise of discretion in valuation by Castlelake may give rise to conflicts of interest, including in connection with determining the amount and timing of distributions of Carried Interest and the calculation of management fees, servicing fees and facility management fees (and other payments to Castlelake), as well as impacting the determination of the allocation of certain costs and expenses. Further, in the event Castlelake’s compensation is based on a Fund’s net asset value, Castlelake is subject to a conflict of interest in valuing portfolio investments. In addition, Castlelake or its affiliates have an incentive to value such investments at a higher level in order to enhance performance reporting. Fringe Benefits. Castlelake and its respective personnel can be expected to receive certain intangible and/or other benefits and/or perquisites arising or resulting from their activities on behalf of the Funds that will neither be subject to an offset against any management fees payable to the Funds nor will otherwise be shared with the Funds, investors and/or portfolio companies and which may create a conflict to select an option that may be more expensive than other suitable options. For example, airline travel or hotel stays incurred as Fund or account expenses typically result in cash rebates, “miles,” “points” or credit in loyalty/status programs, and such benefits and/or amounts will, whether or not de minimis or difficult to value, inure exclusively to Castlelake and/or such personnel (and not the Funds, investors and/or portfolio companies) even though the cost of the underlying service is borne by the Funds, investors and/or portfolio companies. Placement Agents. Castlelake expects to utilize one or more placement agents. Placement agents do not act as investment advisers, municipal advisors, or fiduciaries to potential purchasers in connection with the investments into the Funds. A placement agent would not be advising an investor regarding whether a Fund is more appropriate for an investor’s investment needs than other similar funds that may be available. Potential investors must make their own investment decisions. In making those decisions, potential investors should be aware that the placement agents will receive a placement fee from Castlelake (or an affiliate) that is generally based upon the amount subscribed for by certain investors. Castlelake or the Funds are generally also responsible for certain costs and expenses (including travel) incurred by placement agents in connection with providing services. Investors should also consult with their own internal and external advisors before taking action with respect to any services, material or information provided to them by the placement agent. The placement agents may also seek to do business with and earn fees or commissions from Castlelake or the Funds and their portfolio companies, as well as with other third-party fund sponsors that may have similar or different investment objectives as the Funds. Examples of such business may include, without limitation: provision of financing or investment banking services; lending or arranging credit; provision of prime brokerage; and placement

services. Accordingly, placement agents may be influenced by an interest in such current or future fees and commissions, including differentials in the placement fees that are offered by other thirdparty fund sponsors for which the placement agent acts as placement agent. In addition, certain affiliates or employees of the placement agent might invest in a Fund on their own behalf and/or on behalf of their clients. Potential investors should consider these potential conflicts in making their investment decisions. By investing in the Fund, each investor will be deemed to have consented to these potential conflicts and acknowledged that these potential conflicts are not material to its decision to provide such consent. No Limitations on Activities of Investors. The Accounts do not limit the ability of investors (other than affiliates of Castlelake to the extent provided in the Offering Documents) to engage in any activities, including activities that may be competitive with the Accounts. The investors may also seek to do business with and earn fees or commissions from Castlelake and the Accounts and their investments. Examples of such business may include, without limitation: provision of financing or investment banking services; lending or arranging credit; provision of prime brokerage; and placement services. Castlelake expects to enter into letter agreements with certain investors recognizing their interest in providing such services. Legal Counsel. Castlelake may appoint the same Service Provider to perform services for some or all of the Accounts and for Castlelake and its affiliates. In certain circumstances, such a Service Provider may have conflicting interests, which will not necessarily be resolved in favor of the Accounts. For instance, legal counsel often represents Castlelake solely with respect to the specific matters as to which it has been retained and consulted by Castlelake, including certain matters with respect to the Accounts. Other matters may exist that could have a bearing on the Accounts and underlying portfolio investments. Legal counsel is not providing any advice, representation, warranty or other assurance of any kind as to any matter to any investor in the Accounts. Calculation of Management Fees. Management fees for each account are calculated based upon the terms of their Offering Documents. The base upon which management fees are calculated varies between Accounts. As further specified in certain Offering Documents, for most Accounts, from the initial closing date of an Account until a date specified in the Offering Document (the “Stepdown Date”), management fees generally will be calculated based on a formula tied to the amount of investment contributions (including any amounts recycled and, where applicable, an Account borrowing component (including interest expenses) and any unrecouped Bridge Financings) made by the Account relating to investments that have not been disposed of or completely written-off for U.S. federal income tax purposes (such investments, “Impaired Value Investments”); provided that investments (other than Bridge Financings) in a portfolio investment will be treated for this purpose as having been disposed of or completely written-off for U.S. federal income tax purposes only to the extent that, as of the date of any such disposition or writeoff, the aggregate value of all remaining investments (other than Bridge Financings) in such portfolio investment is less than the aggregate investment contributions with respect to all existing and former investments in such portfolio investment (such amount, “Invested Capital”). Due to differences in the criteria set forth in their respective Offering Documents, in the event where more than one Fund participates in an investment, there is the possibility that an investment will become an Impaired Value Investment for purposes of one Fund’s Offering Documents but not those of one or more other Funds. Further, after the Stepdown Date, management fees generally will be

calculated and charged based on a formula tied to the lesser of Invested Capital and the “value” of each remaining investment (as further described in the Offering Document). As a result, the amount of management fees generally will not correspond with fluctuations in the value of the Account’s portfolio investments, including following the investment period (except to the extent that, following the Stepdown Date, the “value” of remaining investments is less than the Invested Capital), and will not be reduced in connection with any write downs, except in the case of investments completely written-off for U.S. federal income tax purposes, or to the extent that, following the Stepdown Date, the “value” of remaining investments is less than the Invested Capital. Management fees will not be reduced (in whole or in part) in the case of partial distributions or partial sales of investments to the extent an investment is not an Impaired Value Investment (except to the extent that, following the Stepdown Date, the “value” of remaining investments is less than the Invested Capital). For certain other Accounts, the management fee base is calculated using the Account’s net asset value or actively invested capital. The management fee base will include, and will accordingly be increased by, capitalized transaction-specific expenses of unrealized investments and other fees and expenses incurred by the Account, including any such amounts (such as Structuring and Syndication Fees) paid, payable, or reimbursable to Castlelake (or its affiliates). Further, management fees generally will not be reimbursed or refunded under the Offering Document in the event of realizations, dispositions or write downs that occur partway through the relevant calculation period. The Offering Document Agreement sets forth the full list of terms under which management fees will be reduced, offset, or otherwise be limited, and consequently investors should expect to bear the full specified management fee rate set forth in the Offering Document. In many circumstances, the calculation of post-Stepdown Date management fees will include the value of capitalized fees, expenses, costs or other amounts relating to, unrealized investments, including Structuring and Syndication Fees and other amounts payable or reimbursable to Castlelake and its affiliates. Castlelake and its affiliates have incentives to capitalize such amounts into a transaction, not only to avoid having portfolio companies pay such amounts out of available operating cash, but also to increase the base on which future management fees will be calculated. These incentives run counter to Castlelake’s incentives to reduce the amount of fees, expenses and costs borne by the Funds’ investments in light of the effect of these amounts on the Funds’ Carried Interest calculations. Impaired Value Investment Determinations. The Offering Document provides Castlelake with wide ranging authority to make determinations, including those related to investment purchases and dispositions (and their timing), valuation and other matters, such as the cessation of the relevant Fund investment period and the later commencement of a successor Fund’s investment period (including timing determinations relating to each of the foregoing) that have the potential to affect the compensation of Castlelake and its affiliates. In making such determinations, Castlelake is subject to potential conflicts of interest. Past performance is not necessarily indicative of future results and there can be no assurance that projections or estimates of future performance will be realized. The potential to earn additional compensation can create an incentive for Castlelake to make investments and to hold investments longer than otherwise would be the case in the absence of the Fund’s management fee and Carried Interest compensation arrangements. Castlelake expects to be incentivized to cause the Fund to make investments and hold on to investments (and to delay or forego a determination that investments have become “Impaired Value Investments” or that the “value” of investments is less than the Invested Capital thereof) in order to generate greater ongoing management fees and, potentially, larger Carried Interest distributions than would otherwise be the case if such investments had not been made or held (or

if such determination had not been made), including because of the possibility that the investments’ values will appreciate in the future. Because the management fee is calculated, in part, based upon a determination of whether an investment has become an Impaired Value Investment and, in certain cases following the Stepdown Date, the “value” of unrealized investments, Castlelake will have incentives to make determinations that result in the continued payment of, or a higher, management fee. The Offering Document does not generally require management fees to be reduced in connection with investment restructurings, extraordinary dividends or similar transactions, and as such, Castlelake is incentivized to pursue such transactions. Additionally, the amount of Carried Interest owed to Castlelake is dependent in part on the amount and timing of investment dispositions, as well as in certain instances determinations that investments are Impaired Value Investments, and Castlelake expects to be subject to related conflicts of interest in determining whether and when to dispose of investments, make distributions, and/or determine that an investment is an Impaired Value Investment, within the requirements of the Offering Document. The Offering Document provides Castlelake with wide-ranging authority on the determination of Impaired Value Investments, and the criteria used by Castlelake or its affiliates in valuing an investment, or determining whether an investment is an Impaired Value Investment, have the potential to be subjective, to be influenced by market information and other factors, and to vary over time. There can be no assurance that a third-party or investor would agree with the substance or timing of Castlelake’s determination that an investment is an Impaired Value Investment, and, except as set forth in the Offering Document, neither Castlelake nor its affiliates is obligated to follow any third-party methodology in making its determination on whether an investment meets the relevant standards or whether value can be recovered or retained during the Fund’s holding period. In making its determination, Castlelake is entitled to make its own determination taking into account all facts and circumstances it deems relevant, subject to the provisions of the Offering Document. As a general matter, the standards for determining Impaired Value Investments are intended to be high and are not intended to apply to investments experiencing partial or temporary declines in value. Because the amount of compensation to Castlelake and its affiliates is dependent in part on an investment’s status as an Impaired Value Investment, Castlelake faces potential conflicts of interest in determining whether an investment meets, or continues to meet, the relevant criteria. Although Castlelake and its affiliates intend to operate in accordance with the Offering Document, as well as valuation and other practices, policies and/or procedures, in order to mitigate the potential for subjectivity in making such determinations, there can be no assurance that such practices, policies and/or procedures will address all of the necessary factors to do so, or completely eliminate all potential conflicts of interest in such determinations. Subdivision of Debt Obligations. Castlelake or any of its affiliates acting in respect of the Accounts may subdivide a debt, senior equity, or other obligation or financial instrument into two or more tranches, each of which has different terms, original obligation or contemplated obligation with respect to interest and principal repayment, seniority, subordination, default remedies, rights to collateral and other matters. Any such sub-division, including the terms, features, as well as seniority of any tranches, would be made based on facts, assumptions and determinations Castlelake believes to be reasonable under the circumstances. Such determinations may be different from what a third-party may arrive at (including the determination whether to subdivide at all) based on the same or similar facts and may result in the Account’s investment being subject to less favorable terms than may have otherwise been the case absent such sub-division, and will give rise to a variety of potential conflicts of interest with Castlelake and the Accounts, including,

without limitation, as discussed above regarding an Account owning an investment in which other Accounts own a part of the capital structure of or relating to the same portfolio investment (or its affiliates), and such sub-division would result in an Account owning an investment in a different part of the capital structure of the same portfolio investment (or its affiliates) owned by the Accounts or any other fund or account to whom Castlelake or its affiliates services or who has otherwise syndicated such other tranche to. Further, in the event the Account does not, or is unable to syndicate one or more tranches of a loan, the Account may be forced to retain larger amounts of such loan or tranches than originally intended. In such event, the Account’s investment portfolio could become significantly concentrated in a particular loan or tranche. Purchase Option Transactions. One or more Funds provide that under certain circumstances such Fund’s investors may elect to purchase a portion of the equity in a Platform Servicing Company from the Castlelake or its affiliate (a “Purchase Option Transaction”). If any Purchase Option Transaction is to be effected pursuant to the terms of the Offering Document, such transaction may be structured as determined by Castlelake, including by the purchase being effected by alternative investment vehicle structures. In light of the possibility of the Fund entering into one or more Purchase Option Transactions, Castlelake will face conflict of interests in determining whether to utilize Platform Servicing Companies or to make certain investments. For example, Castlelake will be incentivized not to utilize a Platform Servicing Company for the Fund and instead engage a Service Provider so that such services do not give rise to a Purchase Option Trigger Event. There can be no assurance that such Service Provider is more qualified to provide the applicable services or could provide such services at lesser cost. Similarly, Castlelake would have an incentive to cause the Fund not to participate in certain investments which are, or may be, serviced by a Platform Servicing Company. Moreover, Castlelake may cause the Fund to accelerate the Fund’s deployment of capital, or to cause the Fund to hold existing investments longer than it otherwise would have, so that there are not sufficient uncalled Commitments for the Fund to acquire interests of a Platform Servicing Company in a Purchase Option Transaction. Conversely, if the Fund acquires interests of a Platform Servicing Company in a Purchase Option Transaction, then the Fund will have less capital available to pursue other investment opportunities. In addition, even though the Fund will only enter into a Purchase Option Transaction upon receiving the written consent of investors representing at least a majority of the aggregate Commitments of the Fund, such transactions can be expected to give rise to certain potential or actual conflicts of interest. For example, Castlelake may cause the Fund to sell or otherwise dispose of Platform Servicing Company Portfolio Interests at any time and at such price as it determines in its sole and absolute discretion, including in instances where the Castlelake or its affiliates do not sell or otherwise dispose of their retained interests in the relevant Platform Servicing Company alongside the Fund (and Castlelake and its affiliates will be permitted to retain their interests in such Platform Servicing Company even after the dissolution and liquidation of the Fund), and vice versa, the Castlelake and its affiliates will be permitted to sell or otherwise dispose of their retained interests in the relevant Platform Servicing Company even where the Fund is not so disposing of its Platform Servicing Company Portfolio Interests (and the Fund will not have any associated “tag along” rights). In each case, Castlelake will consult with the Advisory Committee prior to the effectuation of any transaction relating to Platform Servicing Company Portfolio Interests where the Fund and the Selling Parties are not disposing of their respective interests in the Platform Servicing Company at the same time and at the same price (it being understood that Castlelake and its affiliates generally expect to maintain their interests in any Platform Servicing Companies beyond the anticipated term of the relevant Fund). Further, because a Purchase Option Trigger

Event (as defined in the Offering Document) is tied to the performance of the relevant portfolio investments being serviced by a Platform Servicing Company, Castlelake may be incentivized to hold onto such portfolio investments for longer, or dispose of such investments earlier, than would otherwise be the case in order to ensure that a Purchase Option Trigger Event does not occur. Further, because upon the occurrence of a Purchase Option Trigger Event, the Fund will only be entitled to purchase 50% of the Selling Parties’ ownership interests of such Platform Servicing Company, Castlelake may be incentivized to dispose of its ownership interests in a Platform Servicing Company prior to the occurrence of a Purchase Option Trigger Event to obtain a better price for such ownership interests than it would otherwise receive in a Purchase Option Transaction, and for the avoidance of doubt, Castlelake shall be entitled to dispose of its interests in a Platform Servicing Company at any time, including prior to the occurrence of a Purchase Option Trigger Event, including, prior to the expiration of the investment period, and any ownership interests sold by Castlelake will reduce the amount of potential ownership interests potentially available for sale in any Purchase Option Transaction. The terms for exercise of the option may differ between Funds, and certain Funds have the right only to a pro rata portion of proceeds relating to their use of the Platform Servicing Company. In addition, the right to trigger a Purchase Option Transaction may trigger earlier in one Fund or Account versus another, leading to a situation where the Fund’s limited partners own a portion of the Platform Servicing Company directly. In the event a Purchase Option Transaction is triggered and elected, Castlelake has discretion with regard to the structure of a Purchase Option Transaction, including using alternative investment vehicles to facilitate such execution. Conflicts Relating to Acquisition by Brookfield. Discussion below is qualified with reference to more detailed disclosures contained in the Offering Documents of the Accounts. Lack of Coordination with Brookfield Accounts. Brookfield Corporation (“BN”) and Brookfield Asset Management Ltd. (“BAM”), each of which is a publicly-traded company listed on the New York Stock Exchange, and their respective affiliates (collectively, including any BAM Affiliated Asset Manager (as defined below), “Brookfield”), is a leading global alternative asset manager, which (i) manages, sponsors and/or advises many investment funds, separately managed accounts and other investment vehicles across a wide spectrum of investment strategies (collectively, the “BAM Accounts”) and Brookfield is expected to establish many such additional BAM Accounts in the future, (ii) manages, invests and oversees a large portfolio of balance sheet assets cross a wide spectrum of investment strategies, industries and sectors, and (iii) owns, controls and/or otherwise holds a material stake in, or has a strategic, joint venture, or other partnership or arrangement with, other alternative asset managers, financial firms, investment advisers and other parties managing, sponsoring, advising, investing or administering assets, investment portfolios, balance sheets, accounts or other pools of capital (each, a “BAM Affiliated Asset Manager”), certain of which BAM Affiliated Asset Managers are global alternative asset managers (some of which are publicly traded) which also manage, sponsor and/or advise additional investment funds, separately managed accounts and/or other investment vehicles, or balance sheet assets, in each case, across a wide spectrum of investment strategies (each, an “Affiliated Asset Manager Account,” and together with the BAM Accounts, the “Brookfield Accounts”). BAM Affiliated Asset Managers may operate on an independent basis or on an integrated basis with respect to all or any other portions of the Brookfield business, and to varying degrees of control, influence and oversight by Brookfield, and in each case, subject to different governance structures and/or arrangements with various levels of day-to-day control, influence and oversight from

Brookfield, and varying degrees of information sharing, data integration and other synergetic characteristics with respect to other Brookfield business units. Brookfield and Castlelake operate their respective investment businesses largely independently, with each remaining under its current brand and led by its existing management and investment teams, and Brookfield and Castlelake generally managing their investment operations independently of each other, but in each case, subject to ultimate oversight, management and control being vested in the Board. Brookfield, the Brookfield Accounts, and their respective portfolio investments will not be treated as “affiliates” for purposes of Castlelake’s identification and management of conflicts of interest (e.g., allocation of investment opportunities, transactions or services with the Funds and Accounts (collectively, “Funds”), successor fund restrictions, etc.) and other internal policies of Castlelake, and it is expected that Castlelake and the Funds will not be treated as “affiliates” for purposes of Brookfield’s investment allocation, conflicts and other policies. As described in the Amendments, Brookfield and the Brookfield Accounts will also not be treated as “affiliates” for purposes of certain provisions of the governing agreements of the Funds (i.e., Brookfield will not have an obligation to allocate investment opportunities to the Funds, be restricted from raising competing funds, be restricted from investing in, or alongside, the Funds in portfolio investments, or be restricted from providing services to the Funds or their portfolio investments, but in each case, subject to any limitations or requirements under applicable law). There is (and in the future will continue to be) overlap in investment strategies and investments pursued by Castlelake and Brookfield. Nevertheless, although Brookfield will have representation on the Board, Brookfield is not obligated, and Castlelake does not expect that Brookfield will, coordinate or consult with Castlelake with respect to investment activities and/or decisions made by Brookfield with respect to the Brookfield Accounts and/or other business activities of Brookfield. Although Castlelake does not intend to adjust its investment strategy, investment decisionmaking processes or the composition of the Investment Review Committee of the Funds in light of the relationship with Brookfield, because the Board is comprised of members appointed by each of Castlelake and Brookfield, it is possible that Brookfield may advise Castlelake on certain investment decisions and other matters pertaining to the Funds, which may lead to Brookfield influencing determinations made by Castlelake personnel, and there can be no assurance that any such Brookfield influence will not have any adverse impacts on the Funds. While the operation of the Funds as a separate business from the other Brookfield Accounts, and having a majority of the Board members appointed by Castlelake, will in some respects serve to mitigate conflicts of interests between Castlelake and Brookfield, these same factors also will give rise to certain conflicts and risks in connection with Brookfield’s and Castlelake’s investment activities, and make it more difficult to mitigate, ameliorate or avoid such situations, and result in a lack of coordination between Castlelake and Brookfield in respect of the Funds and the Brookfield Accounts.

For example, Brookfield is not expected to coordinate or consult with Castlelake regarding its own business activities and the activities of the Brookfield Accounts, and as such, Castlelake will generally not have access to such information, while at the same time, Brookfield through its appointment of a majority of the Board members following a Threshold Acquisition (if any) (defined as a 67.5% or more of Castlelake’s net fee income), will have ultimate control of Castlelake, including in certain circumstances following the departure of Evan Carruthers as CEO/ CIO, ultimate investment decision making authority the ability to determine the composition of the Investment Review Committee and decisions pertaining to the hiring and firing of Castlelake investment professionals and other material determinations. Neither Brookfield nor Castlelake will be subject to any approvals by the other with respect to their respective management of the Funds and the Brookfield Accounts. Further, it is expected that Brookfield will pursue investment opportunities for Brookfield Accounts which are suitable for the Funds, but which are not made available to the Funds, and Brookfield will have no obligation, and it is not expected that Brookfield would, include the Funds within its investment allocation policy for purposes of determining a balanced investment allocation methodology between the Funds and the Brookfield Accounts. As such, the Brookfield Accounts and the Funds are expected to compete for the same investment opportunities. Such competition may adversely impact the purchase price of investments and/or result in the Funds missing out on potentially accretive investment opportunities. Brookfield will have no obligation to, and generally will not, share investment opportunities that may be suitable for the Funds with Castlelake, and Castlelake and the Funds will have no rights with respect to any such opportunities. In addition, Brookfield will not be restricted from forming or establishing new Brookfield Accounts, such as additional funds or successor funds, some of which are expected to have overlapping investment objectives with those of the Funds and which are expected to directly compete with the Funds for investment opportunities. Brookfield Accounts will be permitted to make investments of the type that are suitable for the Funds without the consent of the Funds or Castlelake. Subject to any limitations or requirements in the Offering Documents or under applicable law, Castlelake, the Funds, Brookfield and the Brookfield Accounts are also permitted to purchase investments from, or sell investments to, each other, as well as jointly pursue investment opportunities and participate alongside each other in the same investments, or participate in investments at different layers of the capital structure (as described below). In addition to Brookfield’s participation in the Funds through the General Partner Commitment and/or as a fee-paying limited partner (an “LP Commitment”), from time to time, Brookfield and/or Brookfield Accounts may hold interests in investments (or potential investment), or subsequently purchase (or sell) interests in investments held by Castlelake and/or the Funds. In such situations, Brookfield and/or the Brookfield Accounts could benefit from the Funds’ activities. Conversely, the Funds could be adversely impacted by Brookfield’s activities or refrain from taking certain actions as a result of such activities, which may have an adverse impact on the Funds. In connection with any transactions in which Brookfield, a Brookfield Account and Castlelake and/or a Fund participate, Brookfield may be incentivized to favor the allocation of expenses (or the bearing of any broken deal expenses) by Castlelake and/or the Funds, rather than Brookfield and/or the Brookfield Accounts. In addition, as a result of different investment objectives, views and/or interests in investments, it is expected that Brookfield will manage certain of Brookfield Accounts’ investments in particular issuers in a way that is different from the Funds’ investments in the same issuers (including, for example, by investing in different portions of the issuer’s capital structure, short selling securities, voting securities or exercising rights it holds in a

different manner, and/or buying or selling its interests at different times than the Funds), which could adversely impact the Funds’ interests. Brookfield and its affiliates are also expected to take positions, give advice and provide recommendations that are different from, and potentially contrary to, those which are taken by, given or provided to the Funds, including in respect of Board members appointed by Brookfield, and are expected to hold interests that potentially are adverse to those held by the Funds, and may exercise any voting, control or governance rights on behalf of the Brookfield Accounts (and may exercise such rights on behalf of the Funds as well, in connection with the Transaction, following the Threshold Acquisition (if any)) in different manners, including in ways which materially adversely impact Castlelake and the Funds. The Funds and the Brookfield Accounts will have divergent interests, including the possibility that interests of the Funds are subordinated to or otherwise adversely affected by virtue of such Brookfield Account’s involvement and actions related to the applicable investment, which could adversely impact the Funds’ interests. The potential conflicts of interest described above may be magnified as a result of the general lack of coordination between Brookfield and Castlelake with respect to their respective investment activities on behalf of the Funds and the Brookfield Accounts. For example, the Funds investment team is not expected to be aware of, and as a result will not have the ability to manage, such conflicts given each of Castlelake’s and Brookfield’s respective businesses are intended to continue to operate separately, and Castlelake controls a majority of the Board members. Brookfield will not have any obligation or other duty to make available for the benefit of Castlelake or the Funds any information regarding the activities, strategies or views of Brookfield or any Brookfield Accounts. Further, as described above, certain BAM Affiliated Asset Managers on the one hand, and BN, BAM and their respective affiliates on the other hand, operate independently from one another, and certain BAM Affiliated Asset Managers are subject to strict information barriers inserted between them. As such, the potential conflicts of interest described above between Brookfield, the Brookfield Accounts, Castlelake and the Funds, will be magnified as a result of any such information barriers or other systems designed to facilitate independence, and despite material representation on the Board by Brookfield (or even rights to appoint a majority of the Board members following a Threshold Acquisition), the investment professionals of such insulated BAM Affiliated Asset Managers will generally not be privy to any information shared between Board members, or determinations made or meetings held by the Board, making it more likely that insulated BAM Affiliated Asset Managers and/or their Affiliated Asset Manager Accounts would compete with Castlelake and/or the Funds, and that BAM Affiliated Asset Managers and/or their Affiliated Asset Manager Accounts would take actions which could be materially adverse to the Funds and/or Castlelake. As such, while the information barrier between a BAM Affiliated Asset Manager and other Brookfield business units could prevent certain conflicts of interest, such arrangements could also magnify other risks and conflicts of interest and create potential for additional risks and conflicts of interest to arise. Further, breaches of any information barriers and related internal controls between a BAM Affiliated Asset Manager and other Brookfield businesses could result in coordination between Brookfield’s business lines to the detriment of Castlelake and/or the Funds (which breaches could also have other adverse consequences).

Personal Investment Activities. Brookfield’s principals, members, investment professionals, employees and other personnel (including any Board members appointed by Brookfield) may manage their own personal investments, whether or not through a formal family office or estate planning structure, establish trusts, endowments, charitable programs, foundations or similar arrangements, and pay or receive compensation relating to the foregoing, and invest on behalf of family members and/or friends. Investment activities for their own accounts and for family members and friends, and advice and securities recommendations to any of the foregoing, may differ from the advice given to, or securities recommended or bought for, the Brookfield Accounts, and which may further differ from the advice given to, or securities recommended or brought by Castlelake for the Funds, even though their investment objectives may be the same or similar. Subject to any limitations imposed by the Offering Documents and anti-“assignment” provisions of the Advisers Act, Castlelake, its affiliates and its personnel are also permitted to offer, restructure and monetize the revenue streams they currently receive directly or indirectly from the Funds, or expect to receive from the Funds in the future. Subject to any restrictions in the Offering Documents, this monetization could occur in many forms, including: public offerings of Castlelake or an affiliate; borrowing against Castlelake’s or the general partner’s investment in, or right to receive revenues from, one or more Funds; preferred financing or other strategic investment by a third party in one or more Castlelake entities in which a third party provides liquidity in exchange for the right to receive a specified return; selling or donating their interests in the Funds or in one or more Castlelake entities to third parties; or other financial arrangements, including those in which Castlelake, its affiliates and personnel agree to pledge, sell, securitize, syndicate, participate or otherwise encumber or transfer their respective interests. Although Castlelake and its personnel intend to abide by any “key person” or “time and attention” requirements in the Offering Documents, they expect to be subject to potential conflicts of interest in that they will have financial and other incentives to pursue such monetization arrangements, or to operate Castlelake in a manner designed to maximize potential proceeds relating to any potential monetization arrangements in the future. To the extent third-party funding or borrowings are used to finance General Partner commitment amounts, the Castlelake and/or its personnel generally will be less aligned with limited partners than would otherwise be the case. Treatment as an Affiliate by Law. For purposes of certain laws and regulations, Brookfield and Castlelake may be considered as affiliates, due to, among other things, material Board representation and/or significant economic ownership of Castlelake and the General Partners of the Funds, and such treatment may have a material adverse effect on the Funds. For example, to the extent Brookfield Accounts and the Funds have positions in the same issuers, Brookfield and Castlelake will potentially need to aggregate their investment holdings, including holdings of Brookfield Accounts and the Funds, for certain securities law purposes (including trading restrictions under Rule 144 under the Securities Act, reporting obligations under Section 13 of the Exchange Act and reporting and short-swing profit disgorgement obligations under Section 16 of the Exchange Act) and other regulatory purposes (including (i) public utility companies and public utility holding companies; (ii) bank holding companies; (iii) owners of broadcast licenses, airlines, railroads, water carriers and trucking concerns; (iv) casinos and gaming businesses; and (v) public service companies (such as those providing gas, electric or telephone services)). Consequently, Brookfield’s activities could result in earlier public disclosure

of investments held by the Funds and restrictions on transactions by the Funds (including the ability to make or dispose of investments at times that Castlelake may otherwise have recommended), adverse effects on the prices of the Funds’ investments or the ability of the Funds to dispose of its investments, potential short-swing profit disgorgement, penalties and/or regulatory remedies, or otherwise create conflicts of interests for the Funds. In managing its investment activities, Brookfield is expected to act for its own account or on behalf of the Brookfield Accounts and act in its or their own interest, without regard to the interests of the Funds or Castlelake. Further, under the Advisers Act, Brookfield could be treated as an affiliate of Castlelake for purposes of “principal transaction” related considerations, and as such, Brookfield and/or Castlelake may not pursue certain transactions or forgo to engage in certain activities or may not obtain any required approvals under the Advisers Act or other relevant laws to carry out such transactions and/or activities. Certain investments or dispositions made by the Funds may also be subject to review by the Committee on Foreign Investment in the United States. Further, any regulatory or governmental investigations, enforcements, litigations or public inquiries commenced against Brookfield, or violations of laws, rules or regulations committed by Brookfield, and any other matters having a negative effect on Brookfield’s reputation, could materially and adversely impact Castlelake and Castlelake’s reputation, and have a materially adverse effect on the Funds. Service Providers. Conflicts may arise in connection with the engagement of Service Providers. Certain Service Providers and/or their respective affiliates (including accountants, administrators, lenders, bankers, brokers, attorneys, consultants and investment or commercial banking firms) to Castlelake and/or the Funds and their portfolio investments are permitted to provide goods or services to, or have business, personal, political, financial or other relationships with, Brookfield, the Brookfield Accounts and their respective portfolio investments. Such advisors and Service Providers may be investors in both the Brookfield Accounts and the Funds, sources of investment opportunities for Brookfield and/or Castlelake, or co-investors with or counterparties to transactions involving the foregoing or portfolio investments of either of them. These relationships may influence Brookfield, Castlelake and the Board in deciding whether to select or recommend any such advisor or Service Provider to perform services for the Funds or portfolio investments thereof. In certain circumstances, advisors and other Service Providers or their respective affiliates may charge rates or establish other terms in respect of advice and services provided to Brookfield, the Brookfield Accounts or their respective portfolio investment issuers that are different and more favorable than those established in respect of advice and services provided to Castlelake, the Funds and their portfolio investments (and vice versa). Brookfield could from time to time enter into arrangements with Service Providers that provide for fee discounts for services rendered to Brookfield, the Brookfield Accounts and their portfolio investments, without pursuing such discounts for Castlelake or the Funds. Brookfield LP Commitment. Brookfield has made an LP Commitment to certain Funds. Brookfield shall not be entitled to vote its limited partner interests in the Fund (irrespective of how it acquired such interests) (i) any amount of such LP Commitment that comprises more than an agreed upon percentage of the aggregate commitments to the Feeder Fund and (ii) in circumstances where such vote relates to a conflict of interest between the Fund and Castlelake and/or Brookfield. However, with respect to the portion of such LP Commitment that Brookfield is entitled to vote as a limited partner in the Fund, the interests of Brookfield and other investors in the Fund may not be aligned by virtue of Brookfield owning a portion of the Carried Interest and/or net fee income

generated with respect to the Fund. In exercising any vote, due to its participation in Carried Interest and/or net fee income, Brookfield is incentivized to exercise its voting rights in a manner which may be disadvantageous to the Fund’s investors, including approving lock-up period extensions, waiving conflicts of interest, voting against the exercise of any removal rights or terminations of the Fund, or otherwise not participating in any actions brought by Fund investors against Castlelake and/or the General Partner. Castlelake Managed Brookfield SMAs. Castlelake and Brookfield, have established, and may in the future establish additional separately managed accounts in which Brookfield and/or Brookfield Accounts will invest (the “Brookfield SMAs”) which may invest alongside certain Funds. Certain Brookfield SMAs are expected to pursue investments in a seeding strategy (the “Seeding Strategy”) which is expected to support the origination of investment product produced by Castlelake owned, captive origination platforms (“Platform Companies”), third parties with whom Castlelake has contracted for asset origination or other new lines of business that meet certain investment criteria (in each case, generally expected to comprise of investment grade debt) and including where a Fund may be allocated other investment opportunities (including in another part of the capital structure) sourced and/or serviced by such Platform Company. Any Platform Company sourced investment opportunities which are allocated to the Seeding Strategy will be subject to the origination, servicing and/or other fees payable to the relevant Platform Company and consistent with any fees charged by such Platform Company to any Funds for comparable services. Because fees payable to a Platform Company do not offset management fees payable by a Fund, and Brookfield is expected to own a portion of each Platform Company (as described in “Castlelake Services and Platform Companies,” below), Castlelake and Brookfield will be incentivized to establish additional Platform Companies and/or seek to generate investment opportunities on behalf of the Seeding Strategy, the Funds which are sourced and serviced by such Platform Companies. Castlelake may establish other Brookfield SMAs from time to time, including Brookfield SMAs which may have overlapping investment strategies with those of a Fund (including a Fund still in its investment period). Castlelake’s allocation of investment opportunities among such Funds and any such Brookfield SMAs may not always, and often will not, be proportional. While Castlelake will allocate investment opportunities in a way that it believes in good faith is fair and equitable to such Brookfield SMAs and the Funds over time, there can be no assurance that a Fund’s actual allocation of an investment opportunity or terms on which the allocation is made, will be as favorable as they would be if the conflicts of interest to which Castlelake may be subject did not exist. Castlelake Services and Platform Companies. Castlelake reserves the right to act as a service company and receive compensation from Brookfield, BAM Affiliated Asset Managers and/or Brookfield Accounts in connection with providing services thereto or to their respective portfolio investments, including, without limitation, collateral management, administrative, facility management, technical, remarketing, insurance, reinsurance, enforcement, maintenance, repossession and/or other aircraft related services, insurance related services, debt related services and other asset related services with respect to investments made or held by Brookfield, a BAM Affiliated Asset Manager or a Brookfield Account (collectively, “Servicing Fees”). Servicing Fees payable by Brookfield, a BAM Affiliated Asset Manager and/or a Brookfield Account to Castlelake will not be shared with the Funds and generally will not offset the management fees

payable by a Fund (unless pertaining to a Fund investment, and in such case, only to the extent provided under the applicable governing agreement of such Fund). The payment of Servicing Fees to Castlelake could create potential conflicts of interest. For example, Castlelake could be incentivized to cause a Fund to sell or otherwise transfer assets or debt instruments (including loans) or underwrite or syndicate loans or otherwise provide or arrange financings to or for a Brookfield Account that requires servicing and management expertise of Castlelake, with the intention that such Brookfield Account may elect to continue Castlelake’s servicing or development relationship with the asset or collateral underlying such loan or debt instrument. Similarly, Castlelake, on behalf of a Fund, may submit a bid to acquire an asset, enter into a lease arrangement or to provide financing to a portfolio investment of a Brookfield Account, and such Brookfield Account may reject the bid but nonetheless choose to engage Castlelake to provide services. Furthermore, Castlelake may choose to enter into a transaction with a Brookfield Account for the sale of assets or debt instruments to the extent they agree to maintain the servicing or development relationship with Castlelake, which can create an incentive to sell the assets or debt instruments at a lower value (or underwrite a riskier loan in favor of more servicing opportunities) than would otherwise be received (or earlier than would otherwise be the case or to a less creditworthy counterparty) or to make other investment or divestment decisions based on anticipated Servicing Fees. As a result, while Castlelake’s ability to provide servicing or development to Brookfield or a Brookfield Account may enhance a Fund’s exit opportunities, Castlelake is subject to a conflict of interest in that it is presented with opportunities to use a Fund to generate additional sources of income for itself. Castlelake will seek to mitigate these conflicts through the application of its conflict of interest policies and procedures. Additionally, Castlelake currently owns one or more independently operated Platform Companies, which originate products for and provide certain services to certain Funds and/or their portfolio investments, including loan, referral, collateral, reporting, diligence, origination, administration and/or other similar debt-related and other investment-related services. Financing or other investment opportunities originated by Platform Companies can be allocated to the Funds but may also be allocated to Brookfield and/or Brookfield Accounts. Brookfield indirectly holds a majority of Castlelake’s interest in certain existing Platform Companies, which ownership will increase pro rata in accordance upon future exercises of certain rights by Brookfield, and Brookfield has agreed to invest in future Platform Companies to be established by Castlelake from time to time, subject to certain consent rights by Brookfield (collectively, the “Platform Company Investment”). The Platform Company Investment may incentivize Brookfield to seek to influence Castlelake to cause Platform Company-sourced investments to be allocated to Brookfield and/or Brookfield Accounts, instead of the Funds, and/or cause the Platform Companies to provide services to one or more Brookfield Accounts (or their portfolio investments) to the detriment of the Funds (or their portfolio investments). Fees paid by Brookfield Accounts (or their portfolio investments) to a Platform Company may be lower than those paid by the Funds (or their portfolio investments). Conversely, because fees paid to Platform Companies in respect of services do not offset the management fees payable by the Funds, the Platform Company Investment may incentivize Brookfield to seek to influence Castlelake to pursue Platform Company-sourced investments on behalf of the Funds in an effort to generate fees to a Platform Company or to utilize Platform Companies to provide services in lieu of other potential Service Providers.

Finally, certain of the Funds hold a shared interest in one or both of the Administrative Affiliates, which provide certain corporate secretarial, reporting, tax, administrative, lease management and accounting services, as well as certain other services, to certain investment vehicles and structures of certain Funds. Such Administrative Affiliates could be retained by Brookfield in connection with one or more Brookfield Accounts and/or its portfolio investments, which could limit availability for use of such Administrative Affiliates by the Funds. Any services provide by an Administrative Affiliates or other affiliated Service Provider of Castlelake to Brookfield and/or a Brookfield Account could be on reduced rates or rates which are otherwise lower than those charged to the Funds. Transactions Between Funds, Portfolio Investments and Brookfield Accounts. Subject to applicable law or other regulatory considerations, to the extent Castlelake determines it to be in the best interest of a Fund, such Fund shall be permitted to engage in transactions with Brookfield Accounts and their respective portfolio investments or participate in the same investment opportunity, in each case on such terms as shall be determined by Castlelake, on behalf of any participating Funds, in its sole discretion. For example, Brookfield or a Brookfield Account, may purchase assets from a Fund or participate in investment opportunities sourced by a Fund portfolio investment, and vice versa. Similarly, an operating company, joint venture or other strategic arrangement entered into or owned by a Fund or its portfolio investments, may be retained by Brookfield or a BAM Affiliated Asset Manager to provide services to their respective portfolio investments, and vice versa. Additionally, Castlelake may cause a Fund portfolio investment to originate all or a portion of an investment opportunity in which a Brookfield Account participates (in the same instrument as a Fund or another portion of the capital structure), or where the financing being provided by such Fund is to the Brookfield Account or its portfolio investments (see also “Financing and Refinancing” below). In each of the foregoing cases, Castlelake and Brookfield may be subject to potential conflicts of interest in setting the purchase and sale price, transaction terms, interest rates, and/or service or other fee rates pertaining to the relevant transactions by and between a Fund and a Brookfield Account or their respective portfolio investments, and may be subject to capital structure conflicts, including those described in “Capital Structure Conflicts” below. In connection with the payment of any such servicing or other fees payable to or by a Fund portfolio investment, Castlelake will seek to make determinations of competitive pricing based on its consideration of a number of factors, which may, but are not required to include, third-party pricing and market data with respect to comparable transactions and other methodologies determined by Castlelake to be appropriate under the circumstances. However, even where Castlelake seeks to obtain third-party data regarding the pricing of similar transactions, relevant comparisons may not be available (and in certain circumstances will not be available) for a number of reasons, including, without limitation, as a result of a lack of sufficient comparable transactions for similar assets in the market or the confidential and/or bespoke nature of the type of transaction or assets. Therefore, such market comparisons are not expected to result in precise market terms or pricing for comparable transactions. Capital Structure Conflicts. As a result of the Commitment Letter (as defined below) and/or other transactions pertaining to Brookfield Accounts, the Funds and the Brookfield Accounts are expected to have conflicting interests if they 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 or otherwise in different classes of an issuer’s securities. For example, Castlelake or Brookfield may originate an investment with a counterparty and then use its discretion to structure

such investment into multiple new investments with different levels of seniority, which investments have the potential to be held by the Funds and one or more Brookfield Accounts, or vice versa, which could create conflicts with respect to the Funds and such Brookfield Accounts. To the extent a Fund and a Brookfield Account hold securities or loans that are different (including with respect to their relative seniority) than each other, Castlelake will be faced with a conflict of interest. Castlelake has adopted internal guidelines governing the management of capital structure conflicts, which will apply in these circumstances and be governed by Castlelake’s Regulatory, Compliance and Conflicts Committee and/or Investments Review Committee. For example, if the issuer becomes insolvent or suffers financial distress, a conflict is likely to exist between the interests of Castlelake and Brookfield insofar as the issuer may be unable to satisfy the claims of all classes of its creditors and security holders, including one or more Funds and Brookfield Accounts. Under these circumstances it will not always be feasible for Castlelake to reconcile the conflicting interests in a way that protects the Funds’ interests. In certain circumstances the Funds will be prohibited from exercising (or Castlelake and/or Brookfield could deem it appropriate to refrain from exercising) voting or other rights in order to mitigate the relevant potential conflicts, notwithstanding the fact that the investment(s) of the Funds or the Brookfield Accounts may be subject to creditor claims regarding subordination of interests. With respect to any Brookfield SMA, Castlelake may be required to pass through certain determinations to be exercised by the Brookfield SMA to Brookfield, and in any such cases, Brookfield may exercise such vote in a manner which is disadvantageous to Castlelake and/or the Funds. Because of the different legal rights associated with debt and equity of the same issuer, Brookfield may face a conflict of interest in respect of the advice it gives to, and the actions it takes in its capacity as a Board member of Castlelake versus decisions it makes on behalf of Brookfield Accounts, and the action taken for a Brookfield Account investing in the equity of an issuer may be adverse to the Funds investing in the debt of the same issuer, particularly in the case of financial distress of an issuer, or vice versa. If a Brookfield Account or a Fund has the potential to incur a loss on its investment as a result of such difficulties, Castlelake and/or Brookfield may have an incentive to provide, or to cause a Fund (or a Brookfield Account, as applicable) to provide, additional financing even though doing so may not be considered to be in Castlelake’s or a Fund’s best interest. Similarly, if additional equity capital is necessary to support, enhance or protect the value of an investment, Brookfield may have an incentive to encourage Castlelake to not provide such additional capital to limit its own losses, or if provided, to provide it in an aggregate amount that is less than the amount required. Given the nature of such conflicts and legal constraints (including bankruptcy laws), there can be no assurance that any such conflict can be resolved in a manner that is beneficial to Castlelake and/or the Funds. It is possible that in a bankruptcy, insolvency or similar proceeding, the Funds’ interests may be subordinated or otherwise adversely affected by virtue of the involvement and actions of Brookfield and/or a Brookfield Account relating to its investment. Where Brookfield or a Brookfield Account is a creditor of an issuer senior to the Funds, Brookfield may take actions in its own interests with respect to its rights as a creditor (e.g., with respect to breaches of covenants) that may be adverse to the interests of the Funds as a subordinated debt holder compared to that of the Brookfield Accounts. In such circumstances, Castlelake may, to the fullest extent permitted by applicable law, seek to take steps to reduce the potential for conflicts between the interests of the Funds and the Brookfield Accounts, including causing one or more of the Funds to take certain

actions (or avoid taking certain actions) that, in the absence of such conflict, it would not take. Any such step could have the effect of benefiting Brookfield or the Brookfield Accounts at the expense of the Funds. Syndications to Brookfield Accounts. Brookfield has signed a commitment letter to participate in loan originations recommended to it (the “Commitment Letter”), from time to time, by Castlelake. Loans originated under the Commitment Letter may include loans originated by the Funds. The Funds may originate loans or restructure loans into different tranches, or otherwise make investments, with the intention of selling or otherwise syndicating a portion of a Fund’s interests in such investments to Brookfield and/or one or more Brookfield Accounts. In the event that such Fund does not or is unable to syndicate the relevant portion of the investment, the Fund may be forced to retain larger amounts of such investment than originally intended. In such event, the Fund’s investment portfolio could become significantly concentrated in a particular investment, loan or tranche and/or such Fund may be forced to dispose of such investment at a disadvantageous price. The failure of any such transactions to be consummated may result in a Fund being over-exposed, or unable to participate, in an investment or on unfavorable terms. Further, any structuring, syndication or other fees paid by Brookfield, a Brookfield Account or other person in respect of the syndicated portion of the relevant investment will not offset the Fund management fees and would be in addition to any fees paid to Castlelake in respect of the Fund tranche (or other portion) of the relevant investment, as permitted under a relevant governing agreement of the Fund, for structuring such financings. Such transactions may also involve other potential conflicts of interest, as described in “Castlelake Managed Brookfield SMAs” above. Financing and Refinancing. Subject to applicable law, Castlelake and/or the Funds can provide financing to Brookfield and/or a Brookfield Account which, in turn, will use such financing proceeds directly or indirectly for the purposes of refinancing or modifying an existing loan or other debt position, to make investments or otherwise. Similarly, Castlelake a Fund could refinance or modify loans or debt positions with financing provided by Brookfield and/or a Brookfield Account. While not limited to such periods, debt refinancings are more likely to occur during periods of declining interest rates. In considering such financings and/or refinancings, Castlelake will face actual or apparent conflicts of interest, in particular in respect of the pricing and terms thereof, its incentives to source other more attractive financing opportunities for the benefit of the Funds and/or the enforcement of any rights or remedies in connection with any defaults thereunder. The pricing and terms of any of the foregoing transactions are expected, from time to time, to be established by Castlelake without the involvement of an independent third-party and could be above or below then current market expectations and the pricing and terms related to the prior financing. Brookfield could ultimately benefit from (or Castlelake could be harmed by) the refinancing, and Brookfield and/or Brookfield Accounts could consequently profit (including in relation to their incentive allocation calculations), or the Funds may realize losses as a consequence thereof. Any default by the refinancing party could also create a misalignment of interests between Brookfield and Castlelake. Brookfield Fees. Brookfield may be engaged as a Service Provider to, or engage in activities in respect of, the Funds, its portfolio investments and issuers. Such services and activities may include syndication, arranging, structuring, solicitation, underwriting, agency, origination, sourcing, placement, debt advisory and similar services or activities, including in respect of coinvestments with co-investors or other persons in transactions or investments participated in by

the Funds. Any transaction fees, investment banking fees, structuring and/or syndication fees, commitment fees, breakup fees, broken-deal fees, monitoring fees, consulting fees, directors’ fees and/or any other similar fees or reimbursements, whether in the form of cash, securities or otherwise, which are paid to Brookfield or its partners, members or employees shall not be deemed a “transaction fee” for purposes of the management fee offset provisions contained in the governing agreements of the Funds. Because fees generated to Brookfield from a Fund’s investments will not offset the management fee, Brookfield may be incentivized to seek to cause Castlelake to pursue investments which generate such fees to Brookfield, even if such investments may be disadvantageous to the Funds. Castlelake may also seek to rely on Brookfield affiliated registered broker-dealers to engage in certain types of securities transactions or otherwise engaging in transactions requiring a broker-dealer registration. Further, subject to any limitations or requirements under the Advisers Act, Brookfield may warehouse investments on behalf of Castlelake and/or the Funds, and charge interest for warehousing such investment. Alternatively, Brookfield may provide financing or refinancing to Castlelake and/or the Funds, and any such financing arrangement may create potential conflicts of interest, as described above. Brookfield Private Advisors LLC, a firm controlled by Brookfield which focuses on wealth management activities for high-net-worth individuals, has entered into a distribution assistance agreement with Castlelake with respect to certain Funds, and such firm and/or its affiliates may also act as placement agent for additional Funds in the future. Any compensation generated by the foregoing entities or by any other Brookfield affiliated placement agents utilized in connection with the fundraising of a Fund will not be shared with Castlelake or any Funds. For additional risks and conflicts of interest relating to the use of placement agents please refer to “Placement Agents” above and Item 14 below. Allocation of Co-Investment Opportunities. Conflicts of interest may arise in the allocation of co investment opportunities to Brookfield. It is expected that Brookfield and/or Brookfield Accounts, in respect of any investor commitment made by them to a Fund (to the extent still in its investment period), and subject to any Advisers Act or other regulatory considerations, would generally have the right to participate in any co-investment opportunities with respect to a Fund that are offered to other similar-sized limited partners in such Fund on the same basis as such other similar-sized limited partners. Such allocation may detract from potential co-investment opportunities available to other individual limited partners of a Fund. Brookfield may also have economic or business interests or goals which are inconsistent with those of such Fund, or may exercise its Voting Interests in a manner contrary to such Fund’s investment objectives, or seek to influence decision-making with respect to the timing, allocation amount or syndication price of co-investment opportunities to Brookfield. The allocation of co-investment opportunities to Brookfield may also coincide with a benefit to Castlelake including, without limitation, fees (e.g., management fees, advisory fees, priority profit share, servicing fees and one-time funding fees) or Carried Interest from the coinvestment opportunity. Further, co-investors (including, in such case, Brookfield) generally will not share in broken-deal expenses, irrespective of whether any such co-investor had been identified or selected or had committed to participate in such investment, and such expenses attributable to potential co-investments will typically be borne by the relevant Funds.

Further, for strategic or other reasons, a co-investment vehicle (or co-investor, including a Brookfield Account) could purchase a portion of an investment from the Funds after such Fund has consummated its investment in the portfolio investment, which generally will have been funded through limited partner capital contributions and/or use of a Fund credit facility. Any such purchase from the Funds by a co-investment vehicle (or such co-investor) is generally expected to occur shortly after the Fund’s completion of the investment to avoid any material changes in valuation of the investment but in certain instances could be well after the relevant Fund’s initial purchase. Please refer to “Co-Investment Opportunities” above for more information on the allocation of co-investment opportunities.

Item 11. Code of ethics, participation in client transactions and personal trading

Code of Ethics and Personal Trading Policy. Castlelake has adopted a Code of Ethics and Conflicts of Interest Policy for all employees of the firm describing its commitment to a high standard of business conduct, and fiduciary duty to its Funds. These policies require that all of Castlelake’s employees and partners act in a professional and ethical manner. Persons subject to these policies are subject to, among other things, various restrictions relating to their purchase or sale of securities.

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These restrictions include pre-clearance and disclosure requirements, and general prohibitions on transactions in securities in certain circumstances, including when in possession of material non-public information; transactions in securities of issuers on Castlelake’s restricted list; and acquisition of securities in initial public offerings. There are also restrictions on the acquisition by persons subject to these policies in private placements, which acquisitions require the prior approval of Castlelake’s Compliance personnel and the satisfaction of certain conditions. A copy of Castlelake’s Code of Ethics will be provided upon request by investors in a Fund. However, Castlelake reserves the right to refine and modify the Code and its other policies and procedures over time. No investor or prospective investor should invest with Castlelake on the basis of, or otherwise rely on, the provisions thereof, and any such refinements or modifications have the potential materially to affect the investments available to the Funds or the expenses borne thereby. The Code of Ethics also addresses the fiduciary duties expected of the persons subject to the Code, including confidentiality obligations, gift and entertainment policies, and restrictions on outside business activities. Castlelake employees are, in certain instances, permitted to trade for their own accounts in securities which are recommended to and/or purchased for the Funds. Because Castlelake permits such personal trading, this creates the conflict that employees could use their knowledge of pending client transactions in an attempt to benefit their own personal transactions. For example, if an employee owns a security the employee knows Castlelake will be selling out of client accounts, the employee could sell the personal holding ahead of time in an effort to obtain a higher price than might exist when Fund holdings are sold. To address certain conflicts related to personal trading, the Code of Ethics requires pre-approval of many types of personal securities transactions. Because Castlelake does not prohibit employees from investing in the same securities in which Funds invest, Castlelake’s Compliance personnel monitor the periodic personal securities transactions and holdings reports in an effort to ensure that employees do not personally benefit from, or try to take advantage of, their knowledge of upcoming buys and sells by the Funds. In general, given the nature of the Funds’ investments and the monitoring by the compliance team of

the limited personal securities activities of our employees, Castlelake does not believe as a practical matter that employees will be able to benefit personally from such knowledge. Gifts. Castlelake personnel from time to time receive or give certain gifts and gratuities from or to broker-dealers, Service Providers, asset managers, counterparties or other persons with whom Castlelake, its affiliates or Funds do business (including portfolio brokers). Receipt of such gifts and gratuities might be viewed as causing a conflict of interest for Castlelake in selecting brokers and dealers and other Service Providers. It is a violation of Castlelake’s Code of Ethics for employees to offer or accept inappropriate gifts, favors, entertainment, special accommodations, or other things that could be viewed as excessive and could influence their decision-making. To address certain conflicts related to the receipt or giving of gifts, the Code of Ethics requires preapproval of non-branded gifts of more than a de minimis ($250) value. Branded items should not exceed $450 absent an exemption from the Chief Compliance Officer via a preclearance request. Time and Attention of Principals. The Principals generally intend to devote substantially all of their business time and attention to Castlelake, which primarily includes the management and servicing of the various Accounts. However, the Principals also expect to spend time to organize, sponsor, manage and operate additional investment funds and related investment and business activities (subject to any limitations described in the relevant Offering Documents). The Principals are also permitted to pursue certain other business activities outside of the Accounts, as well as charitable, professional and industry activities and personal investing.

Item 12. Brokerage practices

Selection of Brokers. Account transactions in publicly traded securities are executed by brokers selected by Castlelake in its sole discretion. In making such selections, Castlelake will take into account certain factors, including, but not limited to: the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); the level of trading expertise for the particular type of investment at hand; the operational efficiency with which transactions are affected, taking into account the size of order and difficulty of execution; the financial strength, integrity and stability of the broker. Soft Dollars.

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As a practical matter, the receipt of research from the broker-dealers that execute Castlelake’s transactions is not a material factor in the selection of such brokers. To the extent consistent with Castlelake’s obligation to seek best execution, and all other considerations being equal, Castlelake may place trades with broker-dealers who provide Castlelake with their own research (“proprietary research”). This determination is informal and is subject to the discretion of Castlelake’s head trader. There are no formal or informal commission targets for the broker-dealers that provide Castlelake with research. Castlelake receives the following types of proprietary research: reports and commentary on companies, industries and the economy; and access to broker-dealer research analysts to discuss companies. Castlelake believes this research benefits all of the client Accounts and does not seek to allocate the research proportionately to the specific accounts whose trades are with the broker-dealer that provides the research. Obtaining this research benefits Castlelake because it does not have to produce or pay for the research itself. As a result, Castlelake has an incentive to select or recommend a broker-dealer based on Castlelake’s interest in receiving the research, rather than on the Accounts’ interest in receiving most favorable execution. However, as noted above, Castlelake does not believe that its receipt of

proprietary research is a significant consideration in its selection of broker-dealers to execute transactions. Best Execution. Castlelake seeks best execution of transactions for client Accounts in such a manner that it believes is the most favorable under the circumstances. Although Castlelake generally seeks competitive commission rates, it will not necessarily pay the lowest commission. Given the differences in market structures or the characteristics of financial instruments, it is not possible to identify and apply a uniform standard of, and procedure for, best execution that would be valid and effective for all types of instruments. With the understanding that certain other factors, such as liquidity and complexity of the instrument, the Funds have given the discretionary mandate that the best possible price available may not always represent best execution. Furthermore, in some circumstances there will only be a limited number of venues through which the transaction can be executed. In such cases best execution is generally demonstrated through achieving the desired transaction at a price deemed appropriate by Castlelake. Transaction Costs. Because the Funds’ investments will be actively managed and generally have complex structures, purchases and sales of investments may be frequent and may result in higher transaction costs to the Funds. In addition, a Fund will bear the costs of structuring and ongoing administration and maintenance of any subsidiaries or other vehicles utilized in connection with such Fund’s investment program, and such costs can be material. Aggregation of Trades. When attempting to execute transactions in marketable securities, as applicable, Castlelake will attempt to place orders for all eligible Funds on a combined basis so that each participating Fund experiences the same average price for the trade. If all such orders are not filled at the same price, they will be filled for each client at the average price. If it is not possible under prevailing market conditions to fill the entire order for all relevant Funds at the same price that would be obtainable if an order were placed for only one client, Castlelake will generally allocate the trade among such Funds with transaction costs being shared pro rata, or otherwise on a basis that it considers in good faith to be equitable. Cross Trades. Transactions between Funds, with or without the involvement of a broker, are generally permitted provided they are conducted on an arms-length basis and Castlelake does not receive any brokerage compensation in connection with the transaction which is settled at then existing market prices. In addition, any such transactions would be conducted in accordance with Castlelake’s internal policies and controls. Execution Risk and Investment Manager Errors. The execution of the trading and investment strategies employed by Castlelake can involve complex transactions, difficult to execute trades and use of negotiated terms with counterparties such as in the use of derivatives. In each case, Castlelake seeks best execution and has trained execution and operations professionals devoted to executing, settling and clearing such trades. However, in light of the complexity and global diversity involved, some slippage, errors and miscommunications with brokers and counterparties are inevitable and may result in losses to Funds. Castlelake will evaluate the merits of potential claims for damage against brokers and counterparties who are at fault, and to the extent practicable may seek to recover losses from those parties. Castlelake may choose to forego pursuing claims against brokers and counterparties on behalf of its Funds for any reason including, but not limited to, the cost of pursuing claims relative to the likely amount of any recovery and the

maintenance of its business relationships with brokers and counterparties and the overall market. In addition, Castlelake’s own investment and operations professionals may be solely or partly responsible for errors in placing, processing, and settling investments. Castlelake is not liable to the Funds for losses caused by brokers or counterparties or by Castlelake’s own negligence or contributory negligence. Losses resulting from such errors will, to the greatest extent permitted under applicable law including the Advisers Act, be borne by the Funds so long as such persons met the standard of care set forth in the Offering Documents.

Item 13. Review of accounts

Investments are reviewed regularly by Castlelake’s investment professionals and operations team. In addition, each client portfolio is reviewed regularly by the applicable Castlelake Principals and applicable internal governance structure. Compliance (or Legal) personnel also review all or a portion of a Fund’s portfolio to provide oversight and review of the investing activity. An independent auditor annually audits each Fund’s financial statements. Statements are prepared and sent to Account investors on either a monthly basis or quarterly basis respectively. The respective statements include but are not limited to an investor’s beginning account balance, contributions, distributions, periodic net income and ending balance.

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Additionally, investors in Accounts receive monthly or quarterly written updates that highlight the Fund’s activity and performance. The managing agents of the Vehicles prepare and deliver monthly, quarterly and annual reports and other statements and reports as required under the indentures governing the Vehicles. On an annual basis, investors in Funds received audited financial statements. Also, investors in Funds have their income reported to them on Schedule K-1s, Schedule 1042s or a combination of the two. In addition to general Fund reporting, Castlelake expects to provide certain investors with additional or more frequent information that other investors will not receive (e.g., under a Side Letter or in response to diligence or other requests).

Item 14. Client referrals and other compensation

In connection with the offering of interests in some of its Funds, Castlelake may enter into agreements with a number of registered broker-dealers or similar parties in non-US jurisdictions pursuant to which the broker-dealer acted or is acting as a placement agent for the relevant Fund. For this service, the placement agent was or will be paid a fee that will generally be offset against management fees that Castlelake does or will earn for that Fund, subject to the terms of the Offering Documents.

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The practice of bearing such fees over time through offset provides a benefit to Castlelake in that it generally results in prompt payment to the relevant placement agent without requiring Castlelake immediately to fund such amounts, in addition to an expected tax benefit related to the deductible payment of expenses, and investors will not receive interest or other compensation for the time period between placement agent payment and the later date of offset of the relevant amounts against the relevant management fees.

Such placement agents do not act as investment advisers, municipal advisors, or fiduciaries to potential purchasers in connection investments into the Funds. The placement agents may also seek to do business with and earn fees or commissions from affiliates of Castlelake and portfolio activity of the Funds, as well as with other third-party fund sponsors that may have similar or different investment objectives than the Funds. Examples of such business may include, without limitation: provision of financing or investment banking services; lending or arranging credit; provision of prime brokerage; and placement services. Accordingly, a placement agent may be influenced by its interest in such current or future fees and commissions, including differentials in the placement fees that are offered by other third-party fund sponsors for which the placement agent acts as placement agent. Certain affiliates or employees of the placement agent might invest in a Fund on their own behalf and/or on behalf of their clients.

Item 15. Custody

Castlelake does not serve as the qualified custodian of any of the assets owned by the Accounts. However, Castlelake is deemed under Advisers Act Rule 206(4)-2 to have constructive custody of the assets of each Fund due to its affiliation with the General Partners, managing members or similar parties of such entities. Castlelake satisfies the applicable regulatory requirements related to custody by, among other things, ensuring that each Fund’s assets are maintained with a qualified custodian, that each Fund is subject to an annual audit by an independent accounting firm that is registered and examined by the Public Company Accounting Oversight Board, and that audited financial statements for each Fund are provided to its investors within 120 days of the applicable Fund’s fiscal year- end.

Item 16. Investment discretion

Castlelake exercises broad investment discretion over many of the Funds. This discretion is established in and subject to the terms of the Offering Documents. As a general practice, and except as provided in the Offering Documents, Castlelake does not allow clients to place limitations on this authority. Pursuant to the terms of the Offering Documents, however, and as noted under “Conflicts of Interest - Side Letters” above, Castlelake and/or its affiliates enter into Side Letters with certain investors whereby the terms applicable to such investor’s investment in a Fund may be altered or varied, including, in some cases, the right to opt-out of certain investments for legal, tax, regulatory or other similar reasons.

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Investors in the Accounts endorse Castlelake’s discretionary authority by executing the subscription documents related to their investment and accepting the terms outlined in the respective Offering Documents.

Item 17. Voting client securities

Subject to the terms and conditions of an underlying investment, Castlelake has the authority to vote proxies relating to certain of the securities held by the Funds. Castlelake’s operations team is responsible for reviewing all proxies and voting them consistent with Castlelake policies and procedures. Castlelake will endeavor to avoid material conflicts of interest in the voting of proxies. However, where material conflicts of interest arise, Castlelake is committed to resolving the conflict in the clients’ best interest. In situations where Castlelake perceives a material conflict of interest, Castlelake may defer to the voting recommendation of an independent

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third-party provider of proxy services or take such other action in good faith that it believes would protect the interest of advisory clients. Under certain circumstances, Castlelake may elect not to vote proxies for strategic reasons, may not be able to vote proxies or may find that the expected economic costs from voting outweigh the benefits associated with voting. For example, Castlelake may not vote proxies on certain foreign securities due to local restrictions or customs. Castlelake will seek to vote any proxy prudently and solely in the best long-term economic interest of its clients, considering all relevant factors and without undue influence from individuals or groups who may have had an economic interest in the outcome of the proxy vote or corporate action. A copy of Castlelake’s written proxy voting policies and procedures as well as information on how proxies were voted for the Fund in which they have invested is available to any investor upon request. If “Class Action” documents are received by Castlelake on behalf of the Funds, Castlelake will take reasonable action for the Funds to either participate in, or opt out of, any class action settlements. Castlelake will determine if it is in the best interest of the Funds to attempt to recover monies from a class action settlement. The investment team covering the company in conjunction with compliance will determine the action to be taken when receiving class action notices. In the event Castlelake opts out of a class action settlement, documentation will be maintained of any cost/benefit analysis to support its decision.

Item 18. Financial information

Castlelake is aware of no financial condition that impairs its ability to meet contractual commitments to the Funds and has never been the subject of a bankruptcy proceeding.

Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.