Pacific Oak Capital Advisors, LLC (“Pacific Oak”) began its operation in 2018. Pacific Oak serves as the exclusive external advisor to a publicly registered, non-traded real estate investment trust named Pacific Oak Strategic Opportunity REIT, Inc. (the “SOR REIT”). Also, Pacific Oak serves as external manager to certain subsidiaries of Keppel Pacific Oak US REIT (the “Keppel REIT” and, together with the SOR REIT, the “REITs”) which is listed on the Singapore stock exchange.
Pacific Oak also provides advisory and management services to other real estate investment trusts, collective investment vehicles and accounts. As used in this brochure, the term “client” refers to each of Pacific Oak’s investment advisory clients (e.g., the REITs) and not to the investors in any of the REITs or collective investment vehicles.
Pacific Oak previously served as the exclusive external advisor to a publicly registered, non-traded real estate investment trust named Pacific Oak Strategic Opportunity REIT II, Inc. (“SOR II REIT”). On October 5, 2020, SOR II REIT merged with an indirect subsidiary of the SOR REIT and each issued and outstanding share of SOR II REIT’s common stock converted into common stock of the SOR REIT.
As the external advisor to the REITs, Pacific Oak manages the day-to-day operations of the REITs’ portfolios of real estate properties and real estate-related assets (including real estate-related securities) and is primarily responsible for the identification, analysis and acquisition of real estate properties and real estate-related investments. Generally, proposed investments by a REIT are required to be approved by at least a majority of such REIT’s board of directors (and in certain situations, a majority of the conflicts or other similar committee of the board). As such, Pacific Oak generally functions in a non-discretionary capacity.
However, subject to the limitations in each REIT’s charter and the oversight of its board of directors, Pacific Oak may exercise limited discretionary authority to make certain securities investments on behalf of the REITs. Please refer to the respective REIT’s prospectus for a further description of Pacific Oak’s investment authority with respect to such REIT.
Pacific Oak is controlled and indirectly owned by the following individuals: Peter McMillan III; Born 1957 Education: Clark University, 1979, B.A. (with honors) – Economics; Wharton Graduate School of Business at the University of Pennsylvania, 1982 – MBA (Finance) Business Background: Member of the board of directors of TCW Funds, Inc. and TCW Strategic Income Fund, Inc., and is a member of the board of trustees of Metropolitan West Funds; Co-founder and Principal of KBS Capital Advisors, LLC formed in 2006; Co- founder and Managing Partner of Willowbrook Capital Group, LLC; prior to forming Willowbrook in 2000, Executive Vice President and Chief Investment Officer of SunAmerica Investments, Inc.; before joining SunAmerica in 1989, Assistant

Vice President for Aetna Life Insurance andAnnuity Company.
Keith D. Hall; Born 1958 Education: California State University, Sacramento, 1981, B.A. (with honors) – Finance Business Background: Co-founder and Principal of KBS Capital Advisors, LLC formed in 2006; Co-founder of Willowbrook Capital Group, LLC; prior to forming Willowbrook in 2000, Managing Director at CS First Boston with responsibilities for Mezzanine Lending and Commercial Real Estate Development; prior to joining CS First Boston in 1996, Director in the Real Estate Products Group at Nomura Securities; during the 1980s, Senior Vice President in the High Yield Department of Drexel Burnham Lambert.
Both of Pacific Oak’s principal owners are actively involved in Pacific Oak’s management and operations. The primary responsibility for the investment recommendations made by Pacific Oak to its clients, including the selection of real estate properties and real estate-related investments, and the negotiation of the terms of these investments, resides ultimately with Pacific Oak’s principals, Messrs. McMillan and Hall.
Pacific Oak provides investment advisory services to the REITs in accordance with the investment policies and objectives adopted by the REITs’ boards of directors. Consistent with the REITs’ investment objectives and strategies, the securities advisory services that Pacific Oak provides generally are limited to certain real estate-related securities. The individual needs of the investors in the REITs are not considered when making investment recommendations or providing other advisory services. Instead, Pacific Oak provides advice directly to the REITs and not individually to the investors in the REITs. While the majority of Pacific Oak’s investment recommendations are approved by the REITs’ boards of directors, Pacific Oak may exercise limited discretionary authority with respect to certain real-estate securities investments within certain parameters set by the REITs’ boards of directors. Pacific Oak also provides advisory and management services to certain subsidiaries of the Keppel REIT pursuant to a services agreement with the manager of the Keppel REIT and certain other affiliates of the Keppel REIT.
Pacific Oak provides advisory and management services to each of the REITs pursuant to the terms of an advisory agreement executed with each REIT.
In addition to managing the day-to-day operations of the REITs’ portfolios of real estate properties and real estate-related assets (including real estate-related securities) and providing real estate investment recommendations to the REITs, Pacific Oak also may provide asset management, capital management, marketing, investor relations, compliance and other administrative services to the REITs.
Affiliates of Pacific Oak provide non-securities related investment management services to other real estate investment vehicles as described in Item 10.
As of December 31, 2023, Pacific Oak managed client assets of approximately $3,481,073,537.