BlackRock Capital Investment Advisors, LLC: investment adviser

Item 11 questions answered Yes

These questions cover the firm and its advisory affiliates.

• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have made a false statement or omission?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: entered an order against you or any advisory affiliate in connection with investment-related activity?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?
• Has any self-regulatory organization or commodities exchange ever: found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)?
• G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C.,
• (1) Has any domestic or foreign court: ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority?
• (1) Has any domestic or foreign court: Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?

Actions about the firm (1)

1. Dec 20, 2021
   Regulatory Action: SEC FinalSanctions: Cease and Desist; Censure and civil penalty · Fine: $4.5M · Begun Dec 20, 2021 · Resolved Dec 20, 2021 · Settled · Docket 3-20683

   According to the SEC order, gim (I) did not offset from applicable management fees eligible fees paid to it by a fund portfolio company, (II) did not offset from applicable management fees the full amount it owed a fund's limited partners in connection with eligible fees it collected from a fund portfolio company and (III) included inconsistent provisions concerning the management fee calculation methodology in the offering and governing documents for two funds. In addition, the SEC order found that gim did not adopt and implement written policies and procedures reasonably designed to prevent the above violations of the Advisers Act.

   The penalty amount of $4,500,000 was paid on December 20, 2021.

   The SEC administrative order is final. The civil penalty was paid within 10 days of the entry of the order.

Actions about affiliates (17)

1. May 27, 2026
   Civil Judicial Action PendingAbout an affiliate: BlackRock TCP CapitalSanctions: Money Damages (Private/Civil Complaint); Corporate governance reforms, restitution, attorneys' fees and costs, and such other relief the court may deem just and proper · Begun May 27, 2026

   On May 27, 2026, a shareholder derivative action was filed in the United States district court for the central district of California. The complaint names BlackRock TCP Capital corp as a nominal defendant and certain current and former officers and directors of BlackRock TCP Capital corp as defendants. The complaints asserts claims on behalf of BlackRock TCP Capital corp for alleged violations of the Securities Exchange Act of 1934, breaches of fiduciary duty, unjust enrichment, abuse of control, gross mismanagement, and waste of corporate assets arising out of alleged wrongdoing by the defendants between November 6, 2024, and January 23, 2026, including allegedly making or causing BlackRock TCP Capital corp to make materially false and misleading statements and omissions regarding BlackRock TCP Capital corp's business, operations, and prospects.

2. May 14, 2026
   Civil Judicial Action PendingAbout an affiliate: BlackRock TCP CapitalSanctions: Money Damages (Private/Civil Complaint); Corporate governance reforms, restitution, attorneys' fees and costs, and such other relief the court may deem just and proper. · Begun May 14, 2026

   On May 14, 2026, a shareholder derivative action was filed in the United States district court for the central district of California. The complaint names BlackRock TCP Capital corp as a nominal defendant and certain current and former officers and directors of BlackRock TCP Capital corp as defendants. The complaint asserts claims on behalf of BlackRock TCP Capital corp for alleged violations of the Securities Exchange Act of 1934, breaches of fiduciary duty, unjust enrichment, abuse of control, gross mismanagement, and waste of corporate assets arising out of alleged wrongdoing by the defendants between November 6, 2024, and January 23, 2026, including allegedly making or causing BlackRock TCP Capital corp to make materially false and misleading statements and omissions regarding BlackRock TCP Capital corp's business, operations, and prospects.

3. Apr 29, 2026
   Regulatory Action: Secretary of State of the State of Mississippi FinalAbout an affiliate: BlackRock Advisors, LLCSanctions: Cease and Desist · Begun Mar 27, 2024 · Resolved Apr 29, 2026 · Vacated · Docket LS-24-6726

   On March 27, 2024, BlackRock, inc., BlackRock investments, LLC, BlackRock Advisors, LLC, BlackRock fund advisors, and iShares trust (collectively, "BlackRock") were served with a summary cease and desist order and notice of intent to impose administrative penalty from the Mississippi Secretary of state. The summary order alleges that BlackRock has made misleading statements in fund prospectuses, marketing material, public statements, and on its website regarding BlackRock's ESG practices and approach to proxy voting. The summary order, which was issued to BlackRock without any prior notice or opportunity to be heard, finds that BlackRock violated the Mississippi securities laws, and orders BlackRock to refrain from future violations of those laws. On April 25, 2024, BlackRock exercised its right under Mississippi to request an administrative hearing to contest the allegations.

   Not applicable

   On April 29, 2026, the Mississippi Secretary of state vacated the administrative order that was issued in March 2024.

4. Feb 24, 2026
   Civil Judicial Action PendingAbout an affiliate: BlackRock TCP CapitalSanctions: Money Damages (Private/Civil Complaint); Corporate governance reforms, restitution, attorneys' fees and costs, and such other relief as the court may deem just and · Begun Feb 24, 2026

   On February 24, 2026, a purported shareholder derivative action was filed in the United States district court for the central district of California. The complaint asserts claims on behalf of BlackRock TCP Capital corp for alleged breaches of fiduciary duty, unjust enrichment, abuse of control, gross mismanagement, and waste of corporate assets arising out of alleged wrongdoing by the defendants between November 6, 2024 and January 23, 2026, including allegedly making or causing BlackRock TCP Capital corp to make materially false and misleading statements and omissions regarding BlackRock TCP Capital corp's business, operations, and prospects.

5. Feb 3, 2026
   Civil Judicial Action PendingAbout an affiliate: BlackRock TCP CapitalSanctions: Money Damages (Private/Civil Complaint); Compensatory damages, interest, attorneys' fees and costs, and other relief. · Begun Feb 3, 2026

   On February 3, 2026, a putative securities class action lawsuit was filed in the United States district court for the central district of California. The complaint names BlackRock TCP Capital corp and certain of its current and former executive officers as defendants. The complaint purports to be brought on behalf of a class of persons who purchased or otherwise acquired BlackRock TCP Capital corp's securities between November 6, 2024 and January 23, 2026, and alleges violations of sections 10(b) and 20(a) of the Securities Exchange Act of 1934 and rule 10B-5 promulgated thereunder, based on alleged materially false and misleading statements and/or omissions concerning BlackRock TCP Capital corp's business, operations and financial condition.

6. Feb 17, 2025
   Civil Judicial Action FinalAbout an affiliate: BlackRock IncSanctions: Other; Please see section 14 for details relating to the settlement agreement. · Begun Dec 18, 2023 · Resolved Feb 17, 2025 · Settled

   On December 18, 2023, the Tennessee attorney general ("AG") sued BlackRock, inc. in Tennessee state court for alleged violations of Tennessee's consumer protection statute in connection with our ESG practices. The complaint generally alleges that BlackRock has made misleading statements in fund prospectuses, fact sheets, various public statements, and on its website regarding its ESG practices and its approach to proxy voting.

   Not applicable.

7. Jan 9, 2025
   Regulatory Action: ComisiÓN Nacional Bancaria Y de Valores ("CNBV") FinalAbout an affiliate: BlackRock MexicoSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $123,000 · Begun Jan 9, 2025 · Resolved Jan 9, 2025 · Settled · Docket CNBV.2S.2.211(4433)"2023"/1025/5 PTS

   On January 9, 2025, the ComisiÓN Nacional Bancaria Y de Valores ("CNBV") imposed a fine of approximately $123,000 usd (MNX $2,501,720) regarding the anti-money laundering and counter-terrorist financing program at BlackRock's mexico city office. Specifically, the CNBV found that BlackRock Mexico did not have sufficient procedures to assess whether potential transactions involving politically exposed persons were appropriate and to collect certain information about higher risk clients. Further, the CNBV identified instances where BlackRock Mexico did not maintain complete client files.

   Not applicable

   See summary provided in section 7. The findings observed by the CNBV have already been corrected, and these actions have been communicated to the CNBV. The fine imposed by the CNBV is the minimum fine permissible under the applicable law for each finding.

8. Nov 27, 2024
   Civil Judicial Action PendingAbout an affiliate: BlackRock IncSanctions: Other; Civil fine/penalty, money damages, injunction and return of fees and costs. · Begun Nov 27, 2024

   On November 27, 2024, Texas attorney general ken paxton and attorneys general from 10 other states (Alabama, Arkansas, Indiana, Iowa, Kansas, Missouri, Montana, Nebraska, West Virginia, and Wyoming) filed a complaint against BlackRock, vanguard, and state street (the "managers") alleging that the managers used their ownership stakes in coal companies to artificially reduce coal output in violation of various state and federal antitrust laws. Texas also claims BlackRock made false and deceptive statements in connection with the marketing of its non-ESG ETFS.

9. Aug 22, 2024
   Regulatory Action: State of Indiana Securities Commissioner PendingAbout an affiliate: BlackRock CapitalSanctions: Cease and Desist · Begun Aug 22, 2024 · Docket 24-0013 CD

   On August 22, 2024, the Indiana securities commissioner (the "commissioner") issued a cease and desist order (the "order") against BlackRock, inc. and several of its advisory affiliates, (collectively, "BlackRock"). The order alleges that BlackRock has made misleading statements about how we manage our non-ESG and ESG funds. With respect to non-ESG funds, the order cites to our participation in climate organizations and our statements regarding ESG integration and stewardship activities, among other things, as evidence that our non-ESG funds actually pursue an ESG strategy. With respect to ESG funds, the order asserts that BlackRock falsely claims that sustainable investing will generate better returns. The order finds that this activity violates Indiana's securities law and directs BlackRock to cease engaging in the referenced activities.

10. Jul 12, 2024
    Regulatory Action: ComisiÓN Nacional Bancaria Y de Valores ("CNBV") FinalAbout an affiliate: BlackRock MexicoSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $164,000 · Begun Jun 6, 2023 · Resolved Jul 12, 2024 · Decision · Docket 211-2B/28101798-AGCC/2023

    Failure to comply with certain regulations applicable to the management of mutual funds and the provision of investment advisory services in BlackRock's mexico city office.

    Payment of fine approximately $164,000 (MNX $2,957,150)

    On July 12, 2024, the ComisiÓN Nacional Bancaria Y de Valores ("CNBV") imposed a fine of approximately $164,000 (MNX $2,957,150) regarding the firm's compliance with certain regulations applicable to the management of mutual funds and the provision of investment advisory services in BlackRock's mexico city office. Specifically, the CNBV found that the registrations of 4 BlackRock sales representatives were associated with incorrect BlackRock entities and that BlackRock Mexico's public website did not give notice to users when users were redirected to third party websites. Payment of fine was submitted to the CNBV on August 2, 2024.

11. Oct 24, 2023
    Regulatory Action: SEC FinalAbout an affiliate: BlackRock Advisors, LLCSanctions: Other; BlackRock Advisors, LLC ("BAL") is to: a) pay a $2.5 million civil money penalty; b) cease and desist from committing or causing any · Fine: $2.5M · Begun Mar 2, 2020 · Resolved Oct 24, 2023 · Settled · Docket 3-21786

    On October 24, 2023, the SEC announced an agreement with BlackRock Advisors, LLC ("BAL") to settle findings relating to misstatements in annual and semi-annual reports of a mutual fund for which BAL serves as the registered investment adviser. The SEC found that the reports inaccurately described the interest rate and industry classification of a lending facility with a privately held entity in which the mutual fund invested. Without admitting or denying the SEC's findings, BAL agreed to the entry of an administrative order containing findings that BAL violated section 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-8 thereunder and section 34(b) of the Investment Company Act of 1940.

    On October 24, 2023, the SEC announced an agreement with BlackRock Advisors, LLC ("BAL") to settle findings relating to misstatements in annual and semi-annual reports of a mutual fund for which BAL serves as the registered investment adviser. The SEC found that the reports inaccurately described the interest rate and industry classification of a lending facility with a privately held entity in which the mutual fund invested. Without admitting or denying the SEC's findings, BAL agreed to the entry of an administrative order containing findings that BAL violated section 206(4) of the Investment Advisers Act of 1940 and rule 206(4)-8 thereunder and section 34(8) of the Investment Company Act of 1940. BAL paid the $2.5 million civil money penalty on October 30, 2023. BAL does not expect the resolution of this matter to have a material adverse effect on its financial results or operations.

12. Apr 22, 2022
    Regulatory Action: The Swiss Federal Department of Finance ("Swiss FDF") FinalAbout an affiliate: BlackRock, IncSanctions: Other; Settlement sum · Fine: $50,000 · Begun Jul 19, 2021 · Resolved Apr 22, 2022 · Settled

    On dates in 2017 and in 2018, BlackRock, Inc. was late in making certain threshold filings with the swiss regulator. These late filings were caused by two separate issues: (1) incorrect share issue information provided to BlackRock by its third party vendor; and, (2) BlackRock's outgoing email quarantine system incorrectly quarantining threshold information emails from BlackRock to the swiss regulator.

    The swiss federal department of finance imposed a settlement sum of CHF 50,000. BlackRock, Inc. paid the fee on April 22, 2022.

    BlackRock, Inc. paid settlement sum of CHF 50,000 on April 22, 2022.

13. Jul 28, 2021
    Regulatory Action: Chicago Board of Trade FinalAbout an affiliate: BlackRock, Inc.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Disgorgement · Fine: $119,606 · Begun Jan 22, 2021 · Resolved Jul 28, 2021 · Settled · Docket CBOT 19-1230-BC

    The CME concluded that BlackRock violated Chicago Board of Trade (CBOT) rule 562, which prohibits firms from holding positions on the CME larger than the limits proscribed by CME rules.

    In accordance with the settlement offer, the panel ordered BlackRock to pay a fine in the amount of $20,000 and ordered disgorgement in the amount of $99,605.60 which BlackRock paid on July 29TH, 2021.

    Pursuant to an offer of settlement in which BlackRock inc. neither admitted nor denied the rule violation upon which the penalty is based, on July 26, 2021, a PANEL of the Chicago Board of Trade ("CBOT") business conduct committee ("PANEL") found that on November 12, 2019, and November 13, 2019, BlackRock-managed accounts held an all months combined CBOT soybean meal position that exceeded the all months position limit on an end of day and intraday basis. Specifically, BlackRock-managed accounts held an aggregate position of 6,919 contracts long on November 12, and 6,920 contracts long on November 13, 2019. This exceeded the all months combined position limit for soybean meal by 419 contracts, or 6.45%, on November 12, and by 420 contracts, or 6.46%, on November 13. BlackRock recognized the overage on November 13, and attempted to reduce its position via an exchange for risk ("EFR") transaction, but was unable to execute the trade on that day. However, on the morning of November 14, 2019, BlackRock executed the EFR and brought the accounts' positions into compliance, which resulted in a total monetary benefit of $99,605.60 to the accounts. The PANEL concluded that BlackRock thereby violated CBOT rule 562. In accordance with the settlement offer, the PANEL ordered BlackRock to pay a fine in the amount of $20,000 and ordered disgorgement in the amount of $99,605.60 which BlackRock paid on July 29TH, 2021.

14. May 11, 2020
    Regulatory Action: Federal Financial Supervisory Authority ("BAFIN") FinalAbout an affiliate: BlackRock,IncSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $801,000 · Begun Apr 20, 2020 · Resolved May 11, 2020 · Decision

    BAFIN (the german financial regulator) reached a decision against bim UK for approximately 180 incorrect thresholds filings between August 2018 and October 2018 following brexit restructuring.

    Decision to impose a 744.000 euro ($801,000 usd) sanction against BlackRock investment management (UK) limited which was paid on May 11, 2020.

    On April 20, 2020 BAFIN (the german financial regulator) reached a decision to impose a sanction of 744.000 euro ($801,000 usd) against BlackRock investment management (UK) limited for approximately 180 incorrect thresholds filings between August 2018 and October 2018 following brexit restructuring. Threshold information eported at the aggregate BlackRock, inc. level was correct, and the market was not misled. The sanction was paid on May 11, 2020.

15. Sep 20, 2018
    Regulatory Action: Finansinspektionen - Swedish Financial Services Authority ("Sfsa") FinalAbout an affiliate: BlackRock,IncSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2,020 · Begun May 31, 2018 · Resolved Sep 20, 2018 · Decision

    BlackRock investment management (UK) limited ("bim UK") is required to report to the swedish financial services authority ("SFSA"), within a specified time period, its holdings in listed issuers where those holdings cross a certain threshold ("notifications"). On May 5, 2017, an external vendor was unable to provide accurate data resulting in approximately a 5 minute delay in bim UK's submission of certain short selling notifications to the SFSA. The SFSA was informed in advance of the filing deadline of the likelihood of a delay to the submission of certain short selling notifications. In September 2017, bim UK responded to an inquiry from the SFSA regarding the late submission on May 5, 2017 of short selling notifications for three listed issuers (I.E., byggmax group ab, JM ab and mycronic ab). That response explained the circumstances and noted that the issue arose as a result of inaccurate data received from an external data vendor. The swedish FSA took a strict approach to the interpretation of the requirement to submit the notifications on time and imposed a special fee on bim UK for each of the three late notifications.

    On May 31, 2018, bim UK limited received three letters imposing a special fee for each of the late short selling notifications. Invoice(s) totaling 17,300 sek (approximately $2020 usd) were received on August 21, 2018 for the special fee(s).

    Bim UK paid the special fee to the sfsa on September 20, 2018.

16. Apr 28, 2017
    Regulatory Action: SEC FinalAbout an affiliate: BlackRock,IncSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.5M · Begun Apr 25, 2017 · Resolved Apr 28, 2017 · Order · Docket 3-17942

    "The order specifically concerns the iShares msci russia capped ETF (""russia fund ETF""), managed by BlackRock fund advisors (""bfa"") and whether it was covered by existing exemptive relief granted by Securities and Exchange Commission (""SEC""). In 2010, the russia fund ETF began selling its shares as the only series of shares of iShares msci russia capped ETF, inc. (""russia fund company""). The russia fund company did not have the required exemptive relief until January 2015. Accordingly, by operating the russia fund ETF from December 2010 to January 2015, bfa caused the russia fund company to violate the Investment Company Act."

    A civil monetary penalty in the amount of $1,500,000 was paid on April 28, 2017"

    "On April 25, 2017, bfa reached an agreement with the SEC resolving the matter regarding the russia fund ETF. Bfa, which did not admit or deny any of the SEC's findings, agreed to resolve the matter for a civil monetary penalty of $1,500,000."

17. Jan 25, 2017
    Regulatory Action: SEC FinalAbout an affiliate: BlackRock, Inc.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist undertaking · Fine: $340,000 · Begun Jan 17, 2017 · Resolved Jan 25, 2017 · Order · Docket 3-17786

    The U.S. Securities and Exchange Commission (""SEC"") found that a historic version of BlackRock inc.'s (""BlackRock"") form employee separation and release agreement (""agreement"") violated dodd frank's whistleblower provisions, (rule 21F-17 under the securities and Exchange Act of 1934). The agreement, which was in use between October 2011 and March 2016, did not prohibit former employees from reporting alleged wrongdoing to the SEC. however, employees who accepted a voluntary separation payment from BlackRock waived their right to recover a monetary reward from the SEC in connection with its whistleblowing program. BlackRock stopped using the agreement at issue before being contacted by the SEC and the SEC was unaware of any instances in which former BlackRock employees were prevented from communicating with the SEC.

    BlackRock paid the $340,000 civil monetary penalty on January 25, 2017.

    On January 17, 2017, BlackRock inc. reached an agreement with the SEC to resolve allegations that a historic version of BlackRock's form employee separation and release agreement ("agreement") violated dodd frank's whistleblower provisions, (rule 21F-17 under the securities and Exchange Act of 1934). The settlement with the SEC included a $340,000 payment, which was paid on January 25, 2017. BlackRock also agreed to notify former employees who signed an agreement to advise them that BlackRock does not prevent former employees from collecting a monetary award for reporting information to the SEC under its whistleblower program.

Disclosures filed elsewhere

The firm's Form ADV names these and the kind of action only; the details are on the named firm's own filing.

• 1 regulatory action disclosure about BlackRock Advisors, LLC

Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.