PL Capital Advisors, LLC: investment adviser

At this time, PL Capital Advisors provides investment advice to seven private investment funds, Financial Edge Fund, L.P., Financial Edge-Strategic Fund, L.P., Goodbody/PL Capital, L.P., PL Capital/Focused Fund, L.P., PL Capital Plus Fund, L.P., PL Capital / Black Maple Financial Fund, L.P., and PL Capital SPV #1, LP, all Delaware limited partnerships (the “Funds”). Each of the Funds is what is commonly referred to as a 3c-1 fund which refers to a section of the Investment Company Act of 1940, as amended (the “ICA”). Such Funds are currently open to investors who are “accredited investors” as defined in Rule 501 of Regulation D under the Securities Act of 1933, as amended (the “Securities Act”), and satisfy the “qualified client” standard of the Investment Advisers Act of 1940, as amended (the “Advisers Act”). PL Capital, LLC and Goodbody/PL Capital, LLC serve as the general partner of one or more of the Funds and are also controlled by Mr. Palmer and Mr. Lashley. PL / Black Maple GP, LLC is the general partner of PL Capital / Black Maple Financial Fund, L.P., and is controlled by Mr. Palmer, Mr. Lashley and Mr. Robert Barnard. PL Capital, LLC, Goodbody/PL Capital, LLC and PL / Black Maple GP, LLC are sometimes referred to together as (the “General Partner Entities”). PL Capital Advisors directs the investment program of the Funds on a discretionary basis based on the investment strategy as described in Item 8: Method of Analysis, Investment Strategies and Risk of Loss. PL Capital Advisors conducts its own fundamental research of a wide range of “community” and regional banks and thrifts to determine their qualification for initial and continuing investment by the Funds. As part of its investment strategy, the Funds have a broad mandate to invest and trade in a variety of securities, including equity, debt or convertible securities, options, domestic and foreign securities and non-publicly traded securities, primarily all within the banking sector. PL Capital Advisors provides portfolio advisory and management services to the Funds based on their investment objectives, not based on the criteria or investment objective of any individual investor that contributes capital to the Funds (an “Investor”). Services are provided to the Funds in accordance with the Agreement of Limited Partnership of each Fund (each a “Limited Partnership Agreement”). PL Capital Advisors does not participate in wrap fee programs. As of December 31, 2025, PL Capital Advisors managed approximately $326,545,681 in assets on a discretionary basis. PL Capital Advisors does not manage any assets on a nondiscretionary basis.

The General Partner Entities also receive a performancebased allocation from each Investor in the Funds in the amount of 20% of the net profits allocated to the Investor for the applicable time period, in certain cases after payment to the Investors of a specified preferential return (a “Preferred Return”). This performance-based allocation is more fully described in Item 6: Performance-Based Fees and Side-by-Side Management. The management fee and the performance-based allocation are fixed, but PL Capital Advisors and the General Partner Entities have the discretion to waive or reduce either of these with respect to any Investor. Under the terms of its Limited Partnership Agreement with each Fund, the General Partner deducts the Management Fees mentioned above directly from each Investor’s capital account in the Fund. No portion of the Management Fees is refundable if an Investor withdraws during a calendar quarter. Investors are not charged any redemption fees. Through each Fund, each Investor indirectly pays for its share of all costs and expenses directly related to investment transactions or to the operation of the Fund including brokerage commissions, borrowing charges on securities sold short, margin interest, custodial fees, certain database and research subscription costs, legal, accounting and audit fees and expenses, taxpreparation fees, governmental fees and taxes, bookkeeping and other professional fees, costs of Fund reporting, Fund-related compliance costs, costs of Fund governance activities (such as obtaining Limited Partner consents if and when necessary and appropriate), costs and expenses associated with negotiating and entering into contracts and arrangements in the ordinary course of the Fund’s business, costs and expenses of third party administrators retained for Fund purposes, costs and premiums of any fidelity and performance bonds and general partner liability and errors and omission insurance coverage obtained in the General Partner’s discretion, proxy contest expenses, litigation costs, and all other expenses related to the operation of the Fund and/or the purchase, sale or transmittal of Fund assets. PL Capital Advisors pays for its own direct operating expenses including rent, costs of administrative personnel, and travel and entertainment costs, without reimbursement from the Funds. In certain instances, PL Capital Advisors pays the cost for routine custodial fees for IRA accounts that are invested in a Fund. Neither PL Capital Advisors nor any of its principals, executive officers or employees accepts commissions or other compensation for the sale of interests in the Funds or in connection with the purchase or sale of any securities for the Funds.

Subject to the loss carryforward provision (commonly referred to as the “high water mark”) discussed below, if for any applicable performance period an Investor has a net profit allocated to its capital account (including net unrealized gains), a Performance-Based Allocation equal to 20% of each Investor’s share of such net profit shall be allocated from the Investor’s capital account to the General Partner’s capital account as of the end of such period, after satisfaction of the Preferred Return if applicable. In the event that an Investor withdraws (in whole or in part) at any time other than at the end of a calendar quarter, such allocation will be made with respect to such withdrawn amount on the date of the Investor’s withdrawal as though it were being made at the end of a calendar quarter. Under a loss carryforward provision contained in the Limited Partnership Agreement for each Fund, no Performance-Based Allocation from an Investor’s capital account with respect to a performance period will be made until any net loss previously allocated to the capital account of such Investor has been offset by subsequent net profits. Any such loss carryforward will be subject to reduction for withdrawals in the manner described in the Partnership Agreement. The existence of Performance Based Allocations could theoretically incentivize PL Capital Advisors to manage the Fund portfolios in a more aggressive, risky manner; however, PL Capital Advisors attempts to minimize this risk by ensuring that it is managing the accounts in accordance with the stated investment objectives of each Fund. In addition, the Performance Based Allocations received by the General Partner Entities are based on both realized and unrealized gains and losses. As a result, the Performance Based Allocations earned could be based on unrealized gains that Investors may never realize. Although PL Capital Advisors has the authority to manage the accounts of other clients and funds, it does not currently manage any accounts other than the Funds. Additionally, since each Investor (other than certain affiliates of PL Capital Advisors) is subject to a PerformanceBased Allocation in favor of the General Partner Entities, PL Capital Advisors is not subject to any conflict of interest that could otherwise be present if some accounts or Investors were charged a Performance-Based Allocation and others were not. PL Capital Advisors performs its responsibilities in accordance with its fiduciary duties and does not allow any potential conflicts to influence that performance. Allocations between accounts are generally allocated on a pro rata basis based on assets under management, available cash balances or in some other manner as PL Capital Advisors determines to be fair and equitable under the circumstances.

The following is a summary of the information that appears in more detail in the PPMs and which is generally applicable to each Fund subject to the specific matters outlined in the PPM for each Fund, which should be reviewed by all potential Investors. Introduction PL Capital Advisors’ investment objective is to achieve long term capital appreciation, relative to the risks assumed, by investing in securities of a limited number of publicly traded equity and fixed income securities issued primarily by companies in the banking industry. The investment strategy emphasizes total return, not current income. PL Capital Advisors seeks to identify investment opportunities primarily through its network of industry contacts and knowledge, supported by ongoing fundamental research. INVESTMENT STRATEGY Primary Focus: PL Capital Advisors concentrates its investments in publicly-traded bank/thrift equity securities where the principals believe that: (1) the bank/thrift stock trades at a significant discount to its underlying takeover/franchise value; (2) this discount is attributable to inefficient operations or ineffective management which has led to depressed current earnings and/or a depressed stock price; and (3) there is an opportunity for PL Capital Advisors’ principals, or their nominees, to assist management and/or the board of the bank/thrift to successfully advocate for changes in the operations, strategic direction or management of the targeted bank/thrift in order to improve earnings and/or sell the bank/thrift at a premium to its stock price, thereby eliminating the undervalued situation for the benefit of the Funds (and other shareholders of the bank/thrift). PL Capital Advisors also invests in banks and thrifts that its principals believe are well managed and which can be purchased at attractive valuations relative to their earnings capacity, earnings growth, tangible book value, dividend yield, or other fundamental factors. Shareholder Activism: PL Capital Advisors believes it has been successful in asserting the shareholder rights of its clients in the past and intends to continue this in the future. In numerous instances, PL Capital Advisors has worked with managements and boards of a bank/thrift to proactively make strategic and operational changes (when the managements/boards were willing

to accept and seek change). In other instances, however, the managements/boards were unwilling or unable to accept change. In certain of those instances, PL Capital Advisors has asserted the shareholder rights of its clients in an effort to increase the value of the clients’ investment. For example, in the past PL Capital Advisors has: (1) sought appointment or election of its nominees to a bank/thrift Board of Directors (through a proxy contest or other means); (2) through private and public communications encouraged managements and boards to make strategic/operational changes; and (3) worked with potential acquirers of the targeted bank/thrift and facilitated merger discussions. PL Capital Advisors believes it has developed a positive reputation in the banking industry, which will enable it to continue using this strategy in the future. In addition, PL Capital Advisors believes that shareholder activism is a viable strategy to use in the appropriate circumstances to increase shareholder value, although the vast majority of institutional investors are unwilling to take such responsibility and burden upon themselves. However, many of these “passive” investors have been willing to support PL Capital Advisors in the past and are likely to do so in the future. By virtue of changes to its proxy and corporate governance rules in recent years, PL Capital Advisors believes that the Securities and Exchange Commission (SEC) has also helped to facilitate shareholder democracy and activism. PL Capital Advisors, however, reserves the right to deviate from any and all elements of the foregoing strategy (and the use of any of such techniques) to the extent it deems appropriate. Research: PL Capital Advisors principally uses its network of industry contacts and knowledge, supported by ongoing fundamental research to identify and evaluate potential bank and thrift investments. While PL Capital Advisors has access to research from a variety of sources, it relies substantially on its own research and analysis including review of financial statements, regulatory filings and other data, meeting company personnel, visiting company facilities, interviewing customers and competitors, and analyzing comparable companies or securities. PL Capital Advisors employs a value-driven selection process that focuses on a bank or thrift’s fundamentals, market value, takeover/franchise value, management team, earnings potential, competitors, shareholder base and market share as well as the bank/thrift’s potential for merger or acquisition at a premium to its current market price. Investments The primary focus of PL Capital Advisors is strategic investment in a limited number of “community” banks and thrifts with total assets between $100 million and $25 billion operating in moderate to highly populated geographic markets that PL Capital Advisors believes are appropriate for consolidation, as well as larger banks and thrifts that for various reasons PL Capital Advisors believes are fundamentally undervalued. There are approximately 4,600 “community” banks and thrifts in the U.S., the majority of which are not closely followed by analysts or investors. PL Capital Advisors focuses primarily on the approximately 300 or so publicly-traded community and regional banks and thrifts which are listed on the NYSE, the NASDAQ National Market or other public market.

Consistent with the foregoing strategy, PL Capital Advisors’ portfolio may include positions acquired for various reasons, primarily (i) projected candidates for merger, sale, divestiture of assets, etc. on a near to intermediate term basis; (ii) long holdings of bank and thrift securities that PL Capital Advisors believes to be undervalued on a fundamental net asset or anticipated earnings basis; and periodically (iii) short positions of bank and thrift securities that PL Capital Advisors believes to be overvalued on a fundamental net asset or anticipated earnings basis. PL Capital Advisors, however, reserves the right to deviate from any and all elements of the foregoing strategy (and the use of any of such techniques) to the extent it deems appropriate. PL Capital Advisors may invest not only in equity securities, but also in preferred stocks, debt and so-called hybrid securities, such as convertible securities and in derivative securities such as options, rights and warrants. PL Capital Advisors typically does not invest in securities of companies that are not traded on a public market, except in limited circumstances where the valuation of the private company is attractive or a public market is expected to develop in a reasonable time frame. In addition, a substantial portion of the Fund’s publicly traded portfolio securities may not be widely traded and a Fund’s position in such securities may be substantial in relation to the public market (“float”) for such securities. PL Capital Advisors (in conjunction with its affiliates) typically seeks to own less than 9.9% of the common stock of a single bank/thrift (or its holding company) in order to avoid potential oversight and regulation by federal and state banking regulators. However, recent changes in banking regulations clarified the circumstances under which a firm such as PL Capital Advisors can own and control more than 9.9% of a single bank/thrift (or its holding company) and still avoid being deemed a regulated bank holding company or otherwise face regulatory oversight. As a result of these regulatory changes, in certain situations, PL Capital Advisors may acquire more than 9.9% of common stock of a single bank or thrift (or its holding company). For purposes of determining these ownership thresholds in any specific bank/thrift (or its holding company), PL Capital Advisors’ ownership will generally be aggregated with the entire amount owned by all Funds managed by PL Capital Advisors or affiliated with PL Capital Advisors, as defined by law or regulations. Notwithstanding the recent changes in the regulations, ownership of more than 9.9% of any single bank/thrift (or its holding company) increases the risk that PL Capital Advisors’ activities could be subject to federal and state regulation which may hamper its abilities to implement its investment strategy. Concentration PL Capital Advisors believes that good investment candidates, and the time required to exploit them successfully, are both limited, and that its clients are better served by concentrating on a smaller number of undervalued securities which it knows a great deal about, rather than owning a broader universe of less familiar securities. The portfolio of each Fund is not intended to be diversified as to companies or industries, and substantial positions are taken within a single industry and often in securities of a single issuer. PL Capital Advisors has no fixed concentration limits for its Funds although in the past it has generally not exceeded 15% of each particular Fund’s capital in any one company, measured at cost.

Risk Arbitrage PL Capital Advisors occasionally engages in risk arbitrage as part of its overall investment strategy. Risk arbitrage involves the purchase of securities which are or may be the subject of an announced takeover, or attempt, prior to the time the market price of the securities fully reflects the value offered to the shareholders, in the expectation that the securities will rise to at least the value offered to the shareholders. PL Capital Advisors generally restricts its risk arbitrage activities to merger transactions among banks and thrifts. Short Sales, Options and Derivatives Transactions PL Capital Advisors does not actively or consistently hedge the Funds’ portfolio, although it does opportunistically engage in various types of short sales, options and derivatives transactions for the Funds, for both hedging and investment purposes. Selling securities short involves selling securities which PL Capital Advisors does not own. In order to make delivery to its purchaser, PL Capital Advisors must borrow securities from a third-party lender. PL Capital Advisors subsequently returns the borrowed securities to the lender by delivering to the lender the securities it receives in the transaction or by purchasing securities in the open market. PL Capital Advisors also establishes options and derivatives positions when it believes that options or other derivative securities present more favorable risk/reward relationships than owning or shorting the underlying security. PL Capital Advisors also periodically seeks to uncover individual bank, thrift or other securities that are perceived to be fundamentally overvalued or mispriced and which provide potential for a profitable short sale transaction and/or as a hedge to mitigate potential adverse market value fluctuations of PL Capital Advisors’ “long” positions. Leverage PL Capital Advisors may incorporate the use of leverage afforded by margin borrowings in connection with the investments made by certain of the Funds. Leverage involves the use of borrowed funds, primarily margin borrowings, to increase the amount of invested capital in its securities positions. Investors should consult their own tax advisors regarding the potential effect of the Funds’ use of leverage on their individual tax situation. RISKS RELATING TO INVESTMENT STRATEGY AND TECHNIQUE Investing in the Funds involves a high degree of risk and is suitable only for investors having substantial financial resources who understand the long-term nature, the consequences, and the risks associated with the investment strategy utilized by PL Capital Advisors. Some of those investment related risks are summarized below. Prospective Investors should carefully consider all the risks, which are described in detail in the PPMs of the Funds which are distributed to all potential Investors in advance of their decision whether to invest. Prospective Investors are also advised to consult their own legal, tax and financial advisers about these risks and generally about an investment in the Funds.

PL Capital Advisors Individualistic Approach. PL Capital Advisors relies primarily upon its industry experience and contacts, research, analysis and ultimately judgment in identifying investment opportunities which, for a variety of reasons, may be ignored, misunderstood or not widely followed by the remainder of the investment community. Although not necessarily “contrarian,” PL Capital Advisors’ investment strategy for the Funds presumes that PL Capital Advisors’ own judgment will eventually prove correct, or more timely, as to a particular company or industry, as compared to that reflected in applicable market prices. As PL Capital Advisors relies primarily upon its own research, analysis and industry specific knowledge in making investment decisions, the Funds are especially dependent upon PL Capital Advisors’ investment skills and abilities, to a degree perhaps higher than that inherent in managed investment entities generally. Investors in the Funds are substantially dependent upon a highly individualistic investment strategy of PL Capital Advisors and are exposed to both the risks and rewards incident thereto. Overall Investment Risk. All securities investments risk the loss of capital. The nature of the securities to be purchased and traded by the Funds and the investment techniques and strategies to be employed by PL Capital Advisors in an effort to meet its investment objective may increase this risk. While PL Capital Advisors devotes its best efforts to the management of the Funds’ portfolios, there can be no assurance that the Funds will be profitable or that the Funds will not incur losses or that any future distribution will be made to the Partners. Fund expenses may also exceed income. Neither prior successful investment management performance, recommendations or analysis by PL Capital Advisors, the General Partner Entities or any of its principals, nor any future successful Fund performance, may be relied upon as assuring further successful performance. Many unforeseeable events, including actions by various government agencies, such as the Federal Reserve Board, and domestic and international economic and political developments, may cause sharp market fluctuations which could adversely affect the Funds. Unexpected volatility or illiquidity could impair the Funds’ profitability or result in losses. None of these factors are within the control of PL Capital Advisors or the General Partner Entities. Concentration of Investments. The investment portfolio of each Fund is generally confined to the securities of relatively few issuers and there are no defined limits regarding concentration as to companies, industries or types of investments. In fact, PL Capital Advisors invests almost exclusively in the banking sector. A substantial portion of each Fund’s investments may be concentrated in thinly-traded common stocks characterized by wide bid-asked spreads. Accordingly, by concentrating investments in one specific industry and in several, relatively large (and possibly illiquid) security positions in relation to a Fund’s capital, adverse industry developments or a loss in any major position could materially reduce a Fund’s performance and its net assets. Hedging Risks. PL Capital Advisors may employ various hedging techniques, from time to time, in an effort to reduce the risk of holding investments in securities. There remains a risk, however, that appropriate hedging techniques may not always be available, may be available but not used by PL Capital Advisors for various reasons or may be used but prove to be completely ineffective in limiting losses and in fact may even exacerbate losses. In addition, PL Capital Advisors’ strategy is not “market neutral”, and in most time periods its “long” positions will

materially exceed its “short” positions or cash holdings, if any. This may expose the Funds to a greater risk of loss (and potential gain) than a market-neutral “long/short” portfolio. Leverage; Interest Rates; Derivatives. PL Capital Advisors may borrow funds or use derivatives, where it deems appropriate, on behalf of a Fund in order to increase investment positions or to make additional investments. Consequently, fluctuations in the market value of the Funds’ portfolios will have a greater effect relative to the Funds’ capital than would be the case in the absence of leverage and the use of derivatives. Risk of loss and the magnitude of possible gains are both increased by the use of leverage and derivatives. Adverse market fluctuations, in the case of margin borrowings and derivatives, may require the untimely liquidation of one or more investment positions. In addition, the level of interest rates generally, and the rates at which the Funds can borrow in particular, will be an expense of the Funds and therefore affect the operating results of the Funds. Moreover, due to the Funds’ investment concentration in a limited number of companies in the banking industry, the level of interest rates and industry specific regulations may have a material effect on the performance of the Funds’ portfolios. Short Selling. PL Capital Advisors may also seek opportunities to sell short the securities of companies whose stock prices appear to be excessive in relation to prospective earnings growth or intrinsic value. A short sale may present greater risk than purchasing a security “long” since there is no ceiling on the possible cost of replacing the borrowed security, whereas the risk of a loss on a “long” position is limited to the purchase price of the security. Short selling may be utilized as an opportunity to profit when stocks become overpriced. Short positions may be used generally as a hedge against potential market declines or may be used opportunistically as a profit opportunity for the Funds. Proactive Investment Strategies Including Shareholder Activism. The Funds may from time to time acquire substantial positions in the securities of particular companies, which may exceed 9.9% of the outstanding equity securities of a single bank/thrift (or its holding company) (including securities positions owned by other affiliates of PL Capital Advisors and/or General Partner Entities). PL Capital Advisors may also seek to obtain representation on the Board of Directors and/or engage in dialogue with the management of certain companies in which the Funds may invest. To the extent PL Capital Advisors seeks to obtain representation on the Board of a company or to otherwise seek to engage in a dialogue with the management of a company, the Funds may incur significant legal and administrative costs (e.g., in proxy contests) with no guarantee that such efforts will be successful or profitable. In certain instances where the principals of PL Capital Advisors, or their affiliates, serve as board members of a public company, the Funds may be restricted in their ability to buy or sell securities of such company by virtue of various legal and regulatory restrictions promulgated by the SEC and/or policies of the underlying company. Various banking industry regulations may also increase the regulatory risks and costs of engaging in shareholder activism. In addition, engaging in shareholder activism in larger companies is by definition more expensive than for smaller companies, thus increasing the potential costs, and lowering potential returns, of a Fund relative to a fund that does not engage in shareholder activism or that targets smaller companies if it employs activism. Potential Illiquidity of Portfolio Investments. It is possible that some securities in which the Funds invest may be or become relatively illiquid or may cease to be traded after the Funds

invest. The Funds may also acquire substantial positions in some securities and may acquire securities in private offerings (which may not be permitted to be resold for a period of 2 or 3 years or indefinitely). In such cases, and in the event of extreme market activity, the Funds may not be able promptly to liquidate their investments if the need should arise. In addition, the Funds’ sales of thinly traded securities could depress the market value of such securities and thereby reduce the Funds’ profitability or increase their losses. Risks of Options. The Funds may engage in various types of option transactions both as an independent source of profit and as part of its hedging strategy, including covered calls, uncovered option writing, spreads and straddles. The trading of options can be highly speculative and may entail risks that are greater than investing in other securities. Prices of options are generally more volatile than prices of other securities. The Funds may speculate on market fluctuations in the value of securities and securities indices while investing only a small percentage of the value of those assets or indices underlying the option. A change in the market price of the underlying asset or index will cause a much greater change in the price of the option contract. In addition, to the extent that the Funds purchase options that they do not sell or exercise, they will suffer the loss of the premium it paid. To the extent the Funds sell options and must deliver the underlying securities at the option price, the Funds have an unlimited risk of loss if the price of the underlying security increases. To the extent the Funds must buy the underlying securities, the Funds risk the loss of the difference between the market price of the underlying securities and the option price. Any gain or loss derived from the sale or exercise of an option will be reduced or increased, respectively, by the amount of the premium paid. The expenses of option investing include commissions payable on the purchase and on the exercise or sale of an option. When the Funds write call options they generally do so on a “covered” basis which limits their opportunities to benefit from an increase in the value of the underlying security while continuing to bear the risk of decline in the value of that security. Cybersecurity Risk. With the increased use of technologies such as the Internet to conduct business, PL Capital Advisors and the Funds are susceptible to operational, information security and related risks and additional protection related costs and expenses including the potential for significant damages from any attack. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyber attacks include, but are not limited to, gaining unauthorized access to systems (e.g., through “hacking” or malicious software coding) for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cyber attacks may also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites (i.e., efforts to make network services unavailable to intended users). While PL Capital Advisors attempts to prevent the likelihood of cyber attack risks, cyber incidents could compromise our systems and the information stored there could be accessed, publicly disclosed, lost or stolen. Any such access, disclosure or other loss of information could result in legal claims or proceedings, regulatory penalties, remediation costs, disruption to our operations, reputational damage, and a material adverse effect on the Funds and investment results.

Other than as described in other sections of this Brochure, neither PL Capital Advisors, nor its principals or any executive officer believe they have any relationship or arrangement with a related person that is material to its advisory business or Investors or that could create a material conflict of interest with Investors. PL Capital Advisors and its principals are required to devote only so much of their time to the affairs of the Funds as they reasonably believe is necessary in good faith. Such persons are not prohibited from engaging in any other existing or future business or in other investment activities but these persons owe the Funds’ investors an affirmative duty of utmost good faith, undivided loyalty, full and fair disclosure of all material facts, and an affirmative obligation to employ reasonable care to avoid misleading them. PL Capital Advisors’ Code of Ethics also addresses potential conflicts of interest in cases where PL Capital Advisors’ principals or nominees serve as Directors of companies whose securities PL Capital Advisors or PL Capital Advisors’ supervised persons may purchase or sell on behalf of the Funds. Neither PL Capital Advisors nor its principals, recommend or select other investment advisers for the Fund.

204A-1 of the Advisers Act, which requires that investment advisers adopt a code of ethics setting forth standards of business conduct and compliance with federal securities laws by all employees. PL Capital Advisors’ Code of Ethics has three primary objectives, namely to ensure that PL Capital Advisors’ employees: (1) place the interests of advisory clients first; (2) avoid taking inappropriate advantage of their position in the firm; and, (3) prevent insider trading by protecting material nonpublic information. PL Capital Advisors’ employees must also avoid any personal interest outside of PL Capital Advisors which could be placed ahead of their fiduciary obligation to PL Capital Advisors and to PL Capital Advisors’ advisory clients. Conflicts may exist even when there is an appearance of a conflict and no wrongdoing. The opportunity to act improperly may be enough to create the appearance of a conflict. PL Capital Advisors recognizes and respects an employee’s right of privacy concerning personal affairs, but requires full and timely disclosure of any situation which could result in a conflict of interest or even the appearance of a conflict. Whether or not a conflict exists will be determined by the Chief Compliance Officer on a case-by-case basis. The Code of Ethics includes detailed provisions to comply with the securities laws and to address conflicts of interest. PL Capital Advisors’ employees do from time to time purchase and sell securities for their own personal accounts which they may also be recommending for the Funds, subject to PL Capital Advisors’ Code of Ethics policies. The principals and affiliates of PL Capital Advisors also serve as directors of certain companies whose securities PL Capital Advisors or PL Capital Advisors’ supervised persons may purchase or sell on behalf of the Funds and they may receive for their personal benefit any fees or other compensation and benefits earned in such capacity. Also, when PL Capital Advisors or its employees may acquire confidential information by virtue of their relationship with a company, the Funds may be restricted from initiating a transaction in which they otherwise might have engaged. PL Capital Advisors will provide a copy of its Code of Ethics upon request to the address or telephone number listed on the first page of this Brochure.

Section 28(e) of the Securities Exchange Act of 1934, as amended, is a “safe harbor” that permits an investment manager to use commissions or “soft dollars” to obtain research and brokerage services that provide lawful and appropriate assistance in the investment decisionmaking process. Except for services that would be Fund expenses, PL Capital Advisors limits the use of “soft dollars” to obtain research and brokerage services within the meaning of Section 28(e).

Research services within Section 28(e) may include, but are not limited to, research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; meetings with corporate executives; consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data and economic data); advice from brokers on order execution; and certain proxy services. Brokerage services within Section 28(e) may include, but are not limited to, services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between an investment manager and a broker-dealer and other relevant parties such as custodians); trading software operated by a brokerdealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement in connection with a trade; electronic communication of allocation instructions; routing settlement instructions; post trade matching of trade information; and services required by the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade affirmations. The use of commissions arising from the Funds’ investment transactions for services other than research and brokerage will be limited to services that would otherwise be a Fund expense. The use of commissions to obtain such other services would be outside the parameters of Section 28(e). Research and brokerage services obtained by the use of commissions arising from the Funds’ portfolio transactions may be used by PL Capital Advisors in its other investment activities and thus, the Funds may not necessarily, in any particular instance, be the direct or indirect beneficiary of the research or brokerage services provided. PL Capital Advisors periodically evaluates the quality of services received from brokerdealers. In order to satisfy PL Capital Advisors’ fiduciary obligations, PL Capital Advisors must consider the full range of factors and quality of a broker-dealer’s services, particularly with regard to: (i) the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread on commission, if any); (ii) the execution, clearance, and settlement and error-correction capabilities of the broker-dealer; (iii) the broker-dealer’s willingness to commit capital; (iv) the broker-dealer’s reliability, integrity and financial strength; (v) transaction size; (vi) availability of securities to borrow for short sales; (vii) their expertise in particular markets; (viii) the comprehensiveness and frequency of available research services considered to be of value; and (ix) the competitiveness of commission rates in comparison with other brokers satisfying PL Capital Advisors’ other selection criteria. Although PL Capital Advisors generally seeks competitive commission rates and commission equivalents, it will not necessarily pay the lowest commission or equivalent. PL Capital Advisors may place transactions with a broker or dealer that (i) provides it (or an affiliate) with the opportunity to participate in capital introduction events sponsored by the broker-dealer or (ii) refers investors to the Funds or other products advised by PL Capital Advisors (or an affiliate), if otherwise consistent with seeking best execution; provided PL Capital Advisors is not selecting the broker-dealer in recognition of the opportunity to participate in such capital introduction events or the referral of investors.

Trade Errors Although there exists no standard definition of what constitutes trading errors, examples of trade errors include the following: • • •

Purchasing securities not legally permitted for a Fund, or not within a Fund’s investment guidelines; Purchasing or selling securities for the wrong Fund; and Purchasing or selling the wrong quantity of securities for a Fund.

PL Capital Advisors has established trade processes and procedures designed to reduce the likelihood of errors and, in its sole discretion, will determine what constitutes a trade error. PL Capital Advisors’ general policy is to seek to identify and correct any trade errors promptly and in a way that mitigates any losses. Trade errors in a Fund’s account will be borne by that Fund unless an error is the result of bad faith, gross negligence, or willful misconduct by PL Capital Advisors. Lost opportunity is not a reimbursable loss. PL Capital Advisors will not be responsible for any indirect, consequential or punitive damages for purposes of this policy. PL Capital Advisors will use reasonable methods to calculate the reimbursement due to a Fund, if any. PL Capital Advisors’ process to correct trade errors may involve procedures required by applicable law, which may be complex and require coordination with multiple parties, and therefore PL Capital Advisor’s ability to correct trade errors promptly will be based on the specific circumstances of the error. Aggregation and Allocation of Orders When appropriate, PL Capital Advisors may, but is not required to, aggregate client orders to achieve more efficient execution or to provide for equitable treatment among accounts. Clients participating in aggregated trades will be allocated securities based on the average price achieved for such trades. For ease of trading and administration, PL Capital Advisors typically aggregates client orders as between the Funds. Trades are allocated as between the Funds generally on a pro rata basis based upon each Fund’s capital, giving effect to a number of other factors, such as differences in investment objective, portfolio composition and available cash. Allocation of New Issues New Issues will typically be allocated pro rata among all eligible Funds based on net assets, giving effect to a number of factors such as differences in investment objective, portfolio composition and available cash. Exceptions to such allocation may be made at the discretion of PL Capital Advisors for reasons including, but not limited to, prohibitions of law and a strict pro rata allocation would result in a Fund receiving a de minimus number of shares. PL Capital Advisors allocates New Issues or allocates the profit and loss from New Issues only to those Investors in the Funds who may, pursuant to FINRA Rules 5130 and 5131, participate in such allocations.

Cross and Principal Trades Subject to applicable restrictions under the Employee Retirement Income Security Act of 1974, as amended, as well as each Fund’s investment guidelines and restrictions, PL Capital Advisors may direct one Fund to sell securities to another Fund through a “cross trade” in which neither PL Capital Advisors nor a related person will receive compensation. Any such transaction will be effected based on the then current independent market price and consistent with valuation procedures established by PL Capital Advisors. Cross trades may be completed as a means to balance the Funds on a periodic basis. To the extent that any such cross transaction may be viewed as a principal transaction due to the ownership interest in a Fund by PL Capital Advisors and its personnel, PL Capital Advisors will comply with the requirements of Section 206(3) of the Advisers Act, including that PL Capital Advisors will notify the Funds (or independent representative of the Funds) in writing of the transaction and obtain the consent of the Funds (or an independent representative of the Funds).

Investors of the Funds generally receive the following regular reports: (i) after the end of each fiscal year of the Funds, annual audited financial statements (including a balance sheet, income statement and statement of changes in net assets) for the recently completed fiscal year; (ii) a quarterly letter reviewing the investment performance; (iii) monthly capital account statements (made available, by email, upon request to the Funds’ third party administrator); and (iv) annual tax information necessary for the completion of Investor’s US federal, state and local income tax returns, if applicable. Each of the Funds utilizes the services of an outside third party administrator, Apex Fund Services, except for PL Capital / Black Maple Financial Fund, L.P. which uses the services of NAV Consulting. Additionally, each of the Funds is subject to an annual independent audit by KPMG LLP.

Under no circumstances may PL Capital Advisors or the General Partner Entities make payments in any form to any Investor or other person having influence on the decision-making process of that Investor or person (unless

the person exercising influence is an employee of PL Capital Advisors or the General Partner Entities or has a solicitor relationship as described above) for the purpose of obtaining or retaining that Investor or person as an investor in the Fund. PL Capital Advisors may effect securities transactions through a number of broker-dealers. By virtue of it conducting business with broker-dealers, PL Capital Advisors may receive certain economic benefits from such broker-dealers which would not be received if it did not transact through the broker-dealers. These benefits may include, but are not limited to: access to an electronic communication network for order entry and account information; receipt of proprietary research; and participation in broker-dealer sponsored research and capital introduction conferences. PL Capital Advisors understands the benefits received through its relationship with the broker-dealers (including its prime brokers) generally do not depend upon the amount of transactions directed to, or amount of assets custodied by, the broker-dealers. Other than as described herein, PL Capital Advisors does not currently have any arrangements with any third parties that involve any economic benefit to PL Capital Advisors.

of the client’s investments. It is PL Capital Advisors’ policy generally to vote against any management proposals that it believes could prevent companies from realizing their maximum market value, or would insulate companies or management from accountability to shareholders or prudent regulatory compliance. PL Capital Advisors will generally support proposals to authorize standard and necessary aspects of business operations, which will not typically have a significant effect on the value of the investment, such as name changes, elections of directors and employee stock purchase or ownership plans. The proxy voting policy also contains provisions regarding the steps it will take if it identifies a conflict of interest regarding voting. Mr. John W. Palmer, a principal of PL Capital Advisors, oversees the process by which it votes proxies. PL Capital Advisors’ proxy voting policy is available upon request. A client may obtain the proxy voting policy or a record of the proxy voting for such client by contacting Mr. Dwyer at (630) 857-3003. Limited Partners have no right to participate in the proxy voting process for the Funds but they do have the right to request and obtain from PL Capital Advisors its proxy voting policies and procedures. Limited Partners may access PL Capital Advisors’ publicly available Form N-PX to ascertain how PL Capital Advisors voted proxies on behalf of the Funds. Form N-PX is required to be filed covering the period ending June 30 of each year.