Morgan Stanley Eaton Vance CLO Manager LLC (formerly “MS 522 CLO Manager LLC”), a Delaware limited liability company organized in 2020, is an indirect, wholly-owned subsidiary of Morgan Stanley, a publicly held company (“Morgan Stanley”). Morgan Stanley Eaton Vance CLO CM LLC (formerly MS 522 CLO CM LLC, which was formerly “Assurant CLO Management, LLC”), a “relying adviser” of the Adviser, was organized in 2017 by Assurant, Inc. (“Assurant”). In 2020, Morgan Stanley acquired and, as of the date of this Brochure, indirectly owns all of the voting interests in the Relying Adviser. Assurant, the former owner of the Relying Adviser, continues to indirectly own other interests in the Relying Adviser. The Adviser and the Relying Adviser share common personnel, policies and procedures. Except where stated or where the context requires otherwise: (i) references to ‘we’ or ‘us’ throughout this Brochure apply to the Adviser and the Relying Adviser collectively and (ii) references to “affiliates” throughout do not include Assurant entities that might be deemed to be affiliated with the Relying Adviser based on continued ownership by Assurant of certain indirect, non-voting interests in the Relying Adviser. Certain affiliates of Morgan Stanley, including Morgan Stanley Investment Management Inc. (“MSIM Inc.”), Eaton Vance Management (“EVM”) and its advisory affiliates (which represent the investment management division of Morgan Stanley), provide us with personnel, facilities and resources and perform certain back-office, credit analysis and reporting functions, among other services, which we require in order to carry out our business. Overview We act as collateral manager (whether on an advisory or sub-advisory basis) to issuers of collateralized loan obligation securities and to special purpose vehicles entering into short-term and long-term warehouse, repurchase or other credit facilities to finance the preliminary accumulation and “ramp-up” of loans comprising all or a portion of the initial pool of collateral for any such issuer (each a “CLO” or “Client”). Each CLO invests substantially all of its assets in, and its loans, notes and other securities, as applicable, are backed by, loans and other assets permitted to be held by the CLO under the applicable CLO Documents (collectively, “Assets”). In general, after its warehouse phase, a CLO is a pooled investment vehicle that has a tiered capital structure, issuing senior and mezzanine notes that are rated by one or more rating agencies (the “Rated Notes”) and unrated subordinated notes or other economic equity interests (the “Equity” and, together with the

Rated Notes, the “CLO Securities”). Each Client is described in, governed by and/or otherwise subject to a variety of documents (collectively, the “CLO Documents”), including: (i) the Client’s organizational documents; (ii) during the warehouse phase, the relevant warehouse collateral management agreement, credit and security agreement, securities account control agreement and other warehouse transaction documents; and (iii) upon the issuance of its CLO Securities, an offering circular, indenture, collateral management agreement, collateral administration agreement, conditional sale agreement, purchase agreement, subscription agreements, and other transaction documents. The CLO Documents describe the roles of various persons involved in the Client, establish our authority to perform certain investment management functions, including, without limitation, supervise and direct the investment and reinvestment of the collateral obligations and eligible investments and perform administrative and advisory functions as the collateral manager on behalf of the Client in accordance with the applicable provisions under the collateral management agreement, collateral administration agreement and indenture and set forth detailed eligibility criteria, specifications and requirements regarding the types of investments and describe the overall composition of the Client’s portfolio (including by imposing, as applicable, diversification, ratings and concentration tests). While, in many cases, certain prospective investors in the CLO Securities will influence the investment criteria, guidelines, and other terms set forth in the final CLO Documents, it is generally the case that our investment advice to each CLO will primarily be limited to selecting and managing loans. Our affiliates, and certain private funds and portfolios that our affiliates advise, can hold interests in our Clients, including in risk retention, other Equity or first loss positions, or in any tranche of a Client’s Rated Notes. Any such investments will result in our affiliates’ clients bearing certain expenses and create conflicts of interest. See Item 5, Fees and FORM ADV, PART 2A BROCHURE MORGAN STANLEY | EATON VANCE CLO MANAGER LLC AND EATON VANCE CLO CM LLC5 Compensation, and Item 11, Code of Ethics, Participation or Interests in Client Transactions and Personal Trading, below, for further discussion. Assets Under Management As of December 31, 2023, we had $ 5,728,756,924 in assets under management, all on a discretionary basis.
FORM ADV, PART 2A BROCHURE MORGAN STANLEY | EATON VANCE CLO MANAGER LLC AND EATON VANCE CLO CM LLC6