A. BACKGROUND ROMARK CREDIT ADVISORS LP (“RCA”) is a Delaware limited partnership that was formed in 2016 and registered with the SEC on October 29, 2018. RCA is registered with the SEC as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Registration with the SEC does not imply a certain level of skill or training. RCA is under common control with Shenkman Capital Management, Inc. (“Shenkman”), an SEC-registered global investment advisory firm founded by Mark R. Shenkman in 1985. Prior to its registration as an investment adviser with the SEC, RCA was a relying adviser of Shenkman. Mark R. Shenkman, through Romark Trust LLC and Romark Credit Advisors GP LLC, is the controlling owner of RCA. Romark CLO Advisors LLC (“RCLO”) is a Delaware limited liability company that was formed in 2017. RCLO is a relying adviser of RCA. Prior to the registration of RCA, RCLO was a relying adviser of Shenkman. RCLO is under common control with RCA. Romark CLO Ventures LLC (“RV”), a Delaware limited liability company formed in 2017, is the managing member of RCLO. RCA is the controlling owner of RV. As used herein, the term “Romark” will include RCLO and RCA, as the case may be. The terms “Shenkman Group”, “we” “us”, and “our” shall mean Shenkman, Romark and their affiliates. An advisory client of Romark (as discussed in Section B. below) shall be referred to as a “Romark Client” and collectively as “Romark Clients.” References to an advisory client of the Shenkman Group shall be referred to as a “Shenkman Group Client” and collectively as “Shenkman Group Clients.” References to Romark Clients and Shenkman Group Clients shall include Romark CLOs and the Romark CBOs (as each are defined in Section B. below). For the avoidance of doubt, Shenkman does not provide any advisory services to Romark Clients. While certain Shenkman shareholders, officers, and/or employees are shareholders, officers, and/or employees of RCA, and in some instances, are shareholders, officers, and/or employees of all three of Shenkman, RCA, and RCLO. When such shareholders, officers, and/or employees are acting on behalf of Romark Clients, they are doing so in their capacity as Romark shareholders, officers, and/or employees and not in their capacity as Shenkman shareholders, officers, and/or employees. All policies and procedures described herein apply to the Shenkman Group. Shenkman refers to its employees or other supervised persons as “team members” and any team member that may perform services for the Shenkman Group is subject to the Shenkman Group’s compliance policies and procedures. Please refer to “Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading” for additional information. B. OUR SERVICES Romark’s primary business is to sponsor and provide investment advisory services as a collateral manager to collateralized loan obligations (“Romark CLOs”), collateralized bond obligations (“Romark CBOs”), and other securitized vehicles. Currently, RCA is collateral manager to two (2) Romark CBOs and RCLO is collateral manager to seven (7) Romark CLOs. The Romark CLOs invest primarily in leveraged loans. The Romark CBOs invest primarily in a mix of high-yield bonds and leveraged loans. Romark also implements and manages warehouse or similar facilities established in anticipation of the launch of a Romark Client. Romark has, and expects that it may in the future, employ leverage through total return swap facilities, cash flow financing, or other facilities either directly, through special purpose vehicles, or in Romark Clients. Romark in the future may manage or subadvise accounts or funds that are not CLOs, CBOs, or securities vehicles. These accounts or funds may invest in instruments issued by Romark Clients or

be established for the express purpose of investing in Romark Clients. Romark manages each Romark Client subject to the powers, duties, and limitations described in the collateral management agreement entered into between Romark and the Romark Client and the indentures governing the Romark Client. Potential investors in Romark Clients should review the relevant offering document, indenture, and other constituent documents (together, the “Constituent Documents”) pertaining to the particular Romark Client for additional information. As of December 31, 2023, Romark served as investment adviser to seven (7) CLOs and two (2) CBOs and had regulatory assets under management of approximately $3,143,869,600, all of which are managed on a discretionary basis. Romark does not sponsor or participate in any wrap fee programs. RCA has entered into an agreement (the “Intercompany Services Agreement”) with Shenkman pursuant to which Shenkman provides to RCA, for a fee, among other things, credit research and analysis, shared team members and systems, and assistance and advice on certain support services, including, but not limited to, compliance, operations, finance, information technology and development, and human resources. To facilitate the provision of its services to Romark Clients, RCLO and RCA have entered into an agreement (the "Staff and Services Agreement") whereby RCA provides (or arranges for the provision of) to RCLO, for a fee, certain personnel, facilities and systems that may assist RCLO with various middle and back-office services, including (without limitation): (i) administrative services under the Constituent Documents of each Romark CLO, (ii) compliance support and general risk analysis, (iii) advice relating to the appointment of valuation providers, (iv) assistance in the preparation of reports, (v) credit research, (vi) information technology infrastructure and (vii) physical facilities. Romark has entered, and in the future may enter into, arrangements with certain investors in Romark Clients that grant such investors special or more favorable rights that are not available to all investors. Such special or more favorable rights may include, but are not limited to: (i) different fee arrangements, which may include fee sharing arrangements; (ii) additional reporting and/or greater access to certain information; (iii) opportunities to meet or speak with Romark’s investment team; and (iv) key-person, material litigation, and similar notifications rights. The descriptions set forth herein and elsewhere in this document of specific advisory services offered to Romark Clients and investment strategies pursued and investments made on behalf of Romark Clients, should not be understood to limit in any way Romark’s investment activities. Romark may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that Romark considers appropriate, subject to each Romark Client’s Constituent Documents. Persons reviewing this Brochure should not consider it an offer to sell or any solicitation to buy securities of any CLO, CBO, securitized vehicle, investment fund or account managed by Romark or any other member of the Shenkman Group. Such an offer will only be made by means of an offering document delivered to eligible qualified investors. The offering document and other constituent documents will detail the types of investments that may be purchased/sold. The investment strategies pursued by the Shenkman Group are speculative and entail substantial risks. Shenkman Group Clients should be prepared to bear a substantial or total loss of capital. There can be no assurance that the investment objectives of any Shenkman Group Client will be achieved.