1505 Capital, a Delaware limited liability company, was formed in August 2018 to provide management services primarily to insurance companies but also to other institutional accounts. In addition to providing management services directly to its clients, 1505 Capital may act as a sub- advisor to other investment managers and their respective clients and expects to select and retain sub-advisors that provide 1505 Capital’s clients with in-depth expertise and access to various investments and/or investment strategies. The primary strategies that 1505 Capital utilizes or may in the future utilize on behalf of 1505 Capital’s investors are identified below (each, a “Strategy”). Each Strategy is described in further detail in Item 8 herein.  Direct Non-Owner-Occupied Mortgage Loans or Participations therein (collectively, “Mortgage Loans”). Mortgage Loans may include multi-family, commercial, and non- owner-occupied single-family properties.  Direct Asset-Based Loans or Participations therein (“Asset-Based Loans”). Asset-Based Loans may include infrastructure financing, equipment financing, private credit, and other tangible asset financings.  Broadly-Syndicated (Rated) Fixed-Income, Credit, and Asset-Backed Investments (“Syndicated Investments”). Syndicated Investments may include bonds, loans, or similar investments or securitizations of such instruments that are rated, have a CUSIP, and clear in DTC or a similar clearing system. 1505 Capital will expect to expand its mix of Strategies as opportunities arise in different investment sectors that match its clients’ objectives and/or as requested to do so by its clients. 1505 Capital will do so either directly or through additional sub-advisors with strategy-specific expertise. 1505 Capital’s client base is limited. The Registrant provides investment management services:  Directly to insurance companies and expects in the future to also provide services to other institutional accounts.  Through sub-advisors which are retained in consultation with and approval of 1505 Capital’s clients. 1505 Capital only manages assets which are the subject of its management and sub-advisory agreements and does not consider the client’s other assets and other obligations (subject to “Consulting Services” described below). 1505 Capital receives authority to supervise and direct the investment of the assets in accordance with the client’s written objectives and limitations as outlined in each individual client’s Investment Management Agreement or Sub-Advisory Agreement,

as applicable. At the time of this Brochure, all Investment Management Agreements require approval of the client to acquire an investment. 1505 Capital expects to enter into additional Investment Management Agreement(s) where it will supervise and direct the investment of the assets in accordance with the client’s written objectives and limitations on a discretionary basis. In either case, clients also impose restrictions or limitations on investing in specific securities, specific types of securities, or specific strategies. Moreover, since most of the Registrant’s accounts are with regulated entities, there are additional constraints imposed through state or federal regulation on their investments. Consulting Services 1505 Capital may provide consulting services for a fee to insurance companies, their affiliates, and other institutional clients, including, without limitation, advice on matters such as overall asset allocation and/or portfolio optimization based on: i) stated investment guidelines and/or ii) risk- based capital guidelines. 1505 Capital also intends to provide consulting services related to development and implementation of firm-wide investment policies and programs, such as derivatives use plans. 1505 Capital may also provide flat-fee consulting services to clients including, without limitation, providing advice on matters related to financing arrangements, financial modeling, and documentation. Ownership and Principals 1505 Capital is 100% owned by Midwest Holding Inc., a publicly held company. Michael Minnich is CEO and CIO and Georgette Nicholas is President of 1505 Capital. Wrap Fee Programs 1505 Capital does not participate in wrap fee programs. Assets Under Management As of December 31, 2022, 1505 Capital has $1,097,491,279 of assets under management, $85,499,317 of which are on a non-discretionary basis and $1,011,991,962 of which are on a discretionary basis. Other Matters At any specific point in time, depending on perceived or anticipated market conditions or events, (there being no guarantee that such anticipated market conditions or events will occur), 1505 Capital (on behalf of its client(s)) may maintain cash positions for defensive purposes. All cash positions, including investments in money market funds, shall generally be included as part of assets under management for purposes of calculating 1505 Capital’s management fees. 1505 Capital provides a copy of ADV Part 2 to every client and a copy will be provided to any prospective client upon request.