Company Background, Overview and Principals Pagaya US Holding Company LLC (formerly known as Pagaya Investments US LLC) (“Pagaya HoldCo”) was formed on July 3, 2017 and became registered as an investment adviser firm on May 3, 2021. On November 1, 2021, Pagaya Technologies Ltd. (“Pagaya Tech”) and its subsidiaries underwent an internal corporate restructuring, whereby Pagaya HoldCo transferred all of the assets and liabilities of its investment advisory business to the Adviser. Effective November 1, 2021, the Adviser succeeded to Pagaya HoldCo’s registration as a registered investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) by completing a succession by amendment to Pagaya HoldCo’s Form ADV. The Adviser was formed on October 12, 2021 and is a direct wholly-owned subsidiary of Pagaya HoldCo and an indirect wholly-owned subsidiary of Pagaya Tech, an Israeli domiciled financial technology (fintech) company founded in 2016 by Gal Krubiner, Chief Executive Officer, Avital Pardo, Deputy Chief Executive Officer and Chief Technology Officer, and Yahav Yulzari, Chief Revenue Officer.Pagaya Tech provides Pagaya, pursuant to a services agreement among Pagaya, Pagaya Tech and Pagaya Holdco, with general corporate support for accounting, finance, operations, legal, technology and client advisory services. Pagaya Tech’s other subsidiaries include direct and indirect entities engaged in a variety of businesses, as discussed further below under Item 10 “Other Financial Industry Activities and Affiliations”.
Pagaya Tech, the indirect parent company of Pagaya, merged with EJF Acquisition Corp., a publicly traded special purpose acquisition company, on June 22, 2022, with Pagaya Tech continuing to exist as the surviving entity.
Pagaya currently provides investment advisory services on a discretionary basis to its clients, which are privately offered investment funds (the “Funds”). Pagaya may in the future manage separate accounts for clients.
The information provided in this brochure about the investment advisory services provided by Pagaya to each Fund is qualified in its entirety by reference to the relevant Fund’s governing documents and offering materials. The offering documents for each Fund should be read carefully prior to investment. No offer to sell interests in the Funds is made by the descriptions in this brochure, and the Funds are available only to investors that are properly qualified.
Types of Services Pagaya

relies primarily on proprietary technology1(the “Proprietary Technology”), developed and owned by Pagaya Tech and provided as a service to Pagaya to inform the investment management of the Funds. Specifically, Pagaya utilizes proprietary credit technology, deployed through machine learning technology that seeks to assess the credit quality of borrowers underlying loans originated and sold by banking institutions, consumer lending platforms, point of sale lenders and other intermediaries (together with the entities that service such loans, collectively, the “Partners”).Currently, this Proprietary Technology is primarily deployed through integration with the credit and/or origination processes of certain Partners with which Pagaya has established relationships. In addition, the Proprietary Technology is utilized by Pagaya to inform the acquisition of real estate assets. The Proprietary Technology was created and continues to be developed, utilized and deployed for a variety of purposes and businesses by Pagaya Tech and for a variety of actual and potential uses by Pagaya Tech, Pagaya and their affiliates.Please see Item 8 below for additional information regarding the Proprietary Technology and how it is utilized to inform the investment management of the Funds. The offering materials for each Fund also provide additional information regarding how the Proprietary Technology is utilized to inform the investment management of each Fund.
Tailoring Advisory Services and Restrictions Pagaya has full discretionary authority with respect to the investment decisions of the Funds in accordance with the investment objectives and guidelines set forth in each Fund’s governing documents and investment guidelines.
Wrap Fee Programs Pagaya does not participate in any wrap fee programs.
1Pagaya Tech’s proprietary technology uses “machine learning” models as a subset of artificial intelligence that go through extensive testing, validation and governance processes before they are used or further modified. The models are static and do not have the ability to self-correct, self-improve and/or learn over time. Any change to the models requires human intervention, testing, validation, and governance approvals before a change can be made.
Client Assets As of December 31, 2023, Pagaya had total regulatory assets under management of $2,132,493,346 on a discretionary basis.Pagaya does not manage any assets on a non-discretionary basis.