General Panagram offers investment advisory services to institutional clients, primarily focusing on structured credit, including the debt and equity tranches of collateralized loan obligations (“CLOs”), as well as asset-backed securities (“ABS”). It may also offer investment advice on commercial real estate (“CRE”), including commercial mortgage-backed securities (“CMBS”), CRE CLOs, and other loans or securities backed by CRE. Panagram is a Delaware limited liability company that was formed on November 16, 2020 and registered with the SEC as an investment adviser on June 14, 2021. Panagram is a wholly owned subsidiary of Panagram Holdings, LLC, which is ultimately owned by Eldridge Industries, LLC (“Eldridge”), a private investment firm. Todd Boehly is the Chairman, Chief Executive Officer, and controlling member of Eldridge. Panagram’s core investment team comprises members of an internal structured credit team at Eldridge that has worked together under the leadership of John E. Kim, Panagram’s Chief Executive Officer, and Chief Investment Officer, since 2014. Since then, the team has managed ABS and CLO investments for Eldridge and its affiliates. In addition, the team has established securitization programs on behalf of Eldridge businesses. Drawing on this expertise, Eldridge launched Panagram with this team to offer structured credit investment advisory services to Eldridge and its affiliates, third-party institutional clients, and high net worth clients. Clients Panagram provides or expects to provide investment advisory services to (i) separately managed accounts (the “SMAs”), (ii) private pooled investment vehicles (the “Private Funds”), (iii) investment companies that are registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”) (the “Registered Funds” and, collectively with the Private Funds, the “Funds”), and (iv) third-party investment managers (such managers, together with the SMAs and the Funds, the “Clients”).
• SMAs: Panagram provides advisory services to affiliated and third-party Clients pursuant to separately negotiated investment management or similar agreements.
• Private Funds: Panagram expects to provide advisory services to one or more Private Funds, which generally are expected to be structured as limited partnerships or limited liability companies. The general partner or equivalent of each Private Fund (“General Partner”) will delegate investment management authority for the applicable Private Fund to Panagram under each Private Fund’s operating agreement or other governing document. Such investment management services will be provided directly to the Private Funds and not individually to the Private Funds’ investors (each, an “Investor”). The Private Funds will be organized to be exempt from registration under the Investment Company Act and their securities or interests are expected to be exempt from registration under the Securities Act of 1933, as amended (the “Securities Act”).
• Registered Funds: Panagram previously provided investment advisory services to PGRM, a closed-end management investment company registered under the Investment Company Act. Effective

July 2023, PGRM entered into a new investment advisory agreement with PCCA, a newly formed, affiliated registered investment adviser.
• Third-Party Investment Managers: Panagram expects to provide, through a sub-advisory agreement with the applicable third-party manager, advisory services for funds that such third-party manager raises and manages. Currently, Panagram provides investment advisory services to (a) affiliated entities (including an employee fund), (b) third-party Clients pursuant to separately negotiated investment management agreements, and (c) two actively managed exchange-traded funds, Panagram BBB-B CLO ETF (“CLOZ”) and Panagram AAA CLO ETF (CLOX”). Panagram does not participate in, nor is it a sponsor of, any wrap fee programs. Client Documentation Additional information about each Fund can be found in the relevant Fund’s governing documents, such as private placement memorandums, operating agreements, investment management or advisory agreements, and certain other documents, such as registration statements and other public filings for the Registered Funds (the “Fund Documentation”). Documentation for SMAs generally will consist of an investment management or advisory agreement, which will contain, among other things, guidelines, and restrictions regarding the types of investments and overall composition of a Client’s portfolio, as well as Panagram’s role and authority with respect to the portfolio (“SMA Documentation”). The documentation for third-party managers generally will consist of a sub- advisory or sub-management agreement, which would also include guidelines, restrictions, and terms relating to Panagram’s role and authority with respect to the portfolio Panagram has been retained to sub-advise (“Sub-Adviser Documentation,” and together, with the Fund Documentation and the SMA Documentation, the “Client Documentation”). With respect to Private Funds, Panagram may enter into side letter agreements or other similar agreements with certain Investors (which may include affiliates of Panagram) in a Private Fund that have the effect of establishing rights under or altering or supplementing the terms of Client Documentation with respect to such Investors. Such different or supplemental terms may include, but are not limited to, information rights, excuse or “opt out” rights with respect to certain investments, reduced management fees and/or carried interest/performance fees, and most favored nations clauses. Additional information with respect to side letter or other arrangements will be found in Client Documentation. Panagram, in its sole discretion, may offer more favorable terms (e.g., lower investment minimums, reduced or eliminated fees) to its personnel, related persons, or others, including with respect to dedicated vehicles that invest in or alongside a Private Fund. Similarly, SMAs or Private Funds managed by Panagram may have different terms, including different fee arrangements and/or terms like those described above, than other similarly situated Funds or SMAs. Regulatory Assets Under Management As of December 31, 2023, Panagram managed $15,475,666,080 in total Regulatory Assets Under Management, all on a discretionary basis.