Relative Value Partners Group, LLC (“RVP”, “Registrant” or “Firm”) is an SEC registered investment adviser providing discretionary investment management services to individuals, pension and profit-sharing plans (including pension and profit sharing plans subject to the Employee Retirement Income Security Act of 1974, as amended, “ERISA”), trusts, estates, charitable organizations, corporations and business entities. RVP, depending upon the engagement, offers its services on a fee basis which may include fees based upon assets under management. RVP also acts as a sub-adviser to third party money managers’ client accounts. FOCUS FINANCIAL PARTNERS Relative Value Partners Group, LLC (“RVP”) is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Relative Value Partners Group, LLC (“RVP”) is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because RVP is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Relative Value Partners Group, LLC. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. RVP is managed primarily by Robert H Huffman III, Maury L. Fertig, Gregory K. Neer, Catherine C. Goel, David McGranahan, and Rebecca Deaton in their capacity as executive officers of RVP pursuant to a management agreement between the registrant, RVP Management LLC and REBD, LLC. Mr. Huffman, Mr. Fertig, Mr. Neer, Ms. Goel, Mr. McGranahan and Ms. Deaton are responsible for the management, supervision, oversight and operational support of the Registrant. Discretionary Asset Management Services RVP provides discretionary portfolio management of client assets which are managed to a variety of investment strategies, most which are invested primarily in closed end funds, ETFs and mutual funds. RVP’s Durable Opportunities strategy primarily invests in alternative securities such as Business Development Companies (BDCs), preferred stock, Mortgage REITs, Mortgage Finance Securities, Timber REITs and syndicated loans. For certain financially qualified clients, we recommend private investment funds or hedge funds. Clients select the appropriate strategies or allocation following consultation with an adviser regarding the client’s financial circumstances, investment objectives and risk tolerance. Clients are permitted to impose reasonable restrictions on the management of their accounts. RVP also provides a service of offering investments in private funds to those clients for whom it believes the offering may be suitable. RVP will establish general parameters of risk tolerance, liquidity, cash flow, age and net worth in order to determine suitability. ERISA Fiduciary Services RVP is a fiduciary under the Employment Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plans and ERISA plan participants. RVP is also a fiduciary under section 4975 of the Internal Revenue Code of 1986 as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, RVP is subject to specific duties and obligations under ERISA and the IRC that include among other things, prohibited

transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a “PTE” ). As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. Non-Discretionary Management Services and Financial Counseling Similar to its discretionary services, RVP provides non-discretionary asset management services. In that regard, RVP offers portfolio management to clients but requires pre- approval from the client prior to trading in an account. This service may also include advice on assets not managed by RVP or held away from RVP. Beyond asset management of client accounts by RVP, RVP also provides clients with financial counseling services. These include determination of financial investment objectives, identification of financial obstacles, cash flow analysis, insurance review, education funding, retirement planning and estate counseling. This also includes investment consulting services, which for certain clients include advice and reporting on held away or non-RVP managed assets. Both services are provided for one fee, charged as either a fixed fee or percentage-based fee, as described more completely in Item 5, Fees. Sub Advisor Services RVP provides investment subadvisor services to certain clients of Strategic Wealth Partners Group, LLC (“SWP”). RVP is an affiliate of SWP by virtue of being under common control. Please see Items 5 and 10 of this Brochure for further details. Selection of Third-Party Managers RVP also selects third party money managers for certain client assets. Clients of RVP will enter into direct advisory contract with the recommended third-party money manager and be charged a fee directly from that manager. RVP receives no compensation from the selected money manager. Advisory Services to Wrap Fee Program RVP participates in Stifel Nicolaus’ Connect Dual Contract wrap fee program. RVP receives a portion of the wrap fee to manage the accounts. There are no differences in the way RVP manages accounts in a wrap fee program versus those not in a wrap fee program. RVP may receive slightly lower fees through the wrap fee program. All RVP clients are advised to properly notify RVP if there are ever any changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon RVP's management services. UPTIQ Treasury & Credit Solutions, LLC We offer clients the option of obtaining certain financial solutions from unaffiliated third- party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. Focus Risk Solutions, LLC We help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of this service and other important information. Assets under Management As of December 31, 2023, RVP managed $2,568,654,265 of client assets on a discretionary and nondiscretionary basis. Of that $2,292,846,330 was in accounts managed on a discretionary basis, and $275,807,935 was managed in accounts on a non-discretionary basis. Assets under Advisement In addition to the asset under management described above, the RVP also advises on asset that are not under firm management. As of December 31, 2023, the firm had assets under advisement of $472,346,810.