Background and Ownership Structure Trinitas Capital Management, LLC (“TCM”) is a Delaware limited liability company organized on July 27, 2015. TCM has its principal place of business at 200 Crescent Court, Suite 1175, Dallas, Texas 75201. TCM was formed to provide investment advisory services, initially as a collateral manager for pooled investment vehicles that are collateralized loan obligation funds (“CLOs”). The beneficial owners of TCM consist of multiple persons with no person owning greater than twenty-five percent (25%) of Trinitas. Trinitas is managed by a board of directors and its officers include Gibran Mahmud (CEO), Philip Braner (COO), Mark Murray (CFO). The CLOs managed by TCM are generally organized in the Cayman Islands, Bermuda or Ireland that rely on Section 3(c)(7) of the Investment Company Act of 1940 (the “1940 Act”), or other applicable exceptions or exemptions under the 1940 Act, as the basis for their exemption from the registration requirements of the 1940 Act. The investment management relationship between TCM and each CLO will be governed by a collateral management or similar agreement between TCM and the CLO and the constituent documents of the CLO. The CLOs for which TCM will perform investment advisory services will invest primarily in senior secured bank loans. In assessing senior secured bank loan assets for the CLO, TCM employs an underwriting discipline based on a fundamental and technical analytical strategy, subject to the relevant criteria set forth in the constituent document for each CLO. TCM’s objective in managing the investment portfolio of each CLO is to achieve preservation of principal, diversification by company and industry, and above average current income. TCM contracts for mid- and back- office services associated with its asset management business, including trading, portfolio analysis, credit review and monitoring, asset valuation, and risk and compliance management. These services are currently provided by WhiteStar Asset Management, LLC (“WhiteStar”), also a registered investment adviser, under an agreement between WhiteStar and TCM, though TCM may engage other investment advisers or

other entities to provide such services in the future. Certain investment professionals and other employees or officers of TCM are also investment professionals or employees of other investment advisers. TCM’s investment committee is currently comprised of individuals who are also investment professionals of both TCM and WhiteStar. Such individuals serve at the discretion and subject to the control and direction of TCM’s board of managers, who are elected by its members. A majority of TCM’s board of managers consists of individuals who are not affiliated with WhiteStar. TCM’s relationship with WhiteStar, and the policies and procedures TCM has put in place to address potential conflicts resulting from such relationships, are described in more detail in Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. The offering documents for each CLO will describe the terms and conditions of the CLO, including fees and risk factors, and should be read carefully prior to investment. No offer to sell interests in the CLOs is made by the descriptions in this Brochure, and CLOs are available only to investors that are properly qualified. TCM may also, in the future, provide additional types of investment advisory services. The addition of any such investment advisory services will be set forth in an amendment to this Brochure. Wrap Fee Programs TCM does not participate in or sponsor any wrap fee programs. Regulatory Assets Under Management As of December 31, 2023, TCM managed $12,916,804,762 of advisory assets, of which all were on a discretionary basis and none were on a non-discretionary basis. The SEC has adopted a uniform method for advisers to calculate assets under management for regulatory purposes which it refers to as an adviser’s “regulatory assets under management.” Regulatory assets under management are generally an adviser’s gross assets, i.e., assets under management without deduction for outstanding indebtedness or other accrued but unpaid liabilities. TCM reports its regulatory assets under management in Item 5 of Part 1 of Form ADV which you can find at www.adviserinfo.sec.gov.