Broyhill Asset Management, LLC ("BAM") provides various investment services to individuals, trusts, foundations and other institutions on a discretionary basis. BAM manages $191,671,633 of assets, comprised of $191,159,248 of discretionary assets and $512,385 of non-discretionary assets, as of December 31, 2023. BAM does not participate in any wrap programs. BAM was founded in June 1998 as Broyhill Wakin Capital Advisers, LLC and changed its name to Broyhill Asset Management, LLC on July 1, 2008. The business, solely owned by M. Hunt Broyhill from 2008-2022, originated as a way for a small group of close clients to invest alongside the Broyhill Family Office. In 2022, Broyhill Asset Management began transitioning to a multi-family office and added Christopher R. Pavese, President & CIO, as the primary owner, alongside M. Hunt Broyhill, who retains a key beneficial ownership stake.
Investment Services The President and Chief Investment Officer of BAM is Christopher R. Pavese, CFA. BAM offers asset management services on a discretionary and non-discretionary basis. Discretionary accounts are managed in accordance with BAM's value-oriented investment philosophy, which includes investing in securities of issuers identified by BAM through fundamental analysis in addition to investments in external managers through mutual funds, exchange traded funds, or other vehicles. However, BAM may offer any advisory service, engage in any investment strategy and make any investment, including any not described in this Brochure, that BAM considers appropriate, subject to each client's agreement with BAM or other agreed-upon restrictions. When you enter into non-discretionary arrangements with our firm, either you will be responsible for the execution of the recommended advice or we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.
Subadviser Services BAM may also act as a subadviser to advisers unaffiliated with BAM. These third-party advisers would outsource portfolio management services to BAM. This relationship will be memorialized in each contract between BAM and the third-party advisor.
Private Funds - BAM Credit Opportunities Fund and Broyhill Partners Fund BAM serves as the Sponsor of the BAM Credit Opportunities Fund, while its affiliate through common ownership and control, Broyhill Partners GP, LLC, is the general

partner of the Broyhill Partners Fund (each a "Fund," and collectively, the "Funds"). As Sponsor and general partner, respectively, BAM and Broyhill Partners GP, LLC will have exclusive control over day-to-day operations of the Funds. In addition, BAM will serve as the investment manager of the Funds and provide discretionary investment advisory and portfolio management services to the Funds.
Private funds are available for investment only by institutional investors and other sophisticated, high- net-worth investors, who meet the eligibility requirements of the applicable fund set forth in its Governing Documents. Each such Fund is exempt from registration as an investment company under the Investment Company Act of 1940, as amended (the "Investment Company Act"), under Section 3(c) (7) thereof.
4 IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.