Civitas Capital Management, LLC is a Texas limited liability company formed on December 8, 2008. The principal owners of our firm are Ryan Holdings Texas, LLC, a Texas limited liability company formed on April 10, 2008, and certain estate-planning vehicles associated with Daniel J. Healy, the Chief Executive Officer of our firm. This Brochure also describes the business practices of management companies affiliated with our firm which operate as a single advisory business together with Civitas Capital Management, LLC. References to “Civitas,” “we,” “our,” and “our firm” refer to Civitas Capital Management, LLC and its affiliates. Our firm provides investment portfolio management services exclusively with respect to real estate and real estate-related debt and equity investments (“Real Estate Assets”) and expect to provide such services primarily with respect to Real Estate Assets in the future. We provide investment portfolio management services to various investment vehicles (including some private funds) that make investments in Real Estate Assets (“Real Estate Funds”), including in multifamily rental apartment properties, hotels and offices. These Real Estate Funds are typically structured as limited partnerships. An affiliate of Civitas serves as the general partner of each Real Estate Fund and Civitas generally serves as the investment adviser to each Real Estate Fund. These Real Estate Funds may also be structured as limited liability companies or other entities, with an affiliate of Civitas serving as the manager, managing member or other management role analogous to a general partner, manager or managing member. Some of our Real Estate Funds include those whose investment strategies are structured to meet the requirements of the U.S. EB-5 Immigrant Investor Program (the “EB-5 Program”), through which qualified foreign investors can receive permanent residency in the United States in return for investing a minimum required amount into a United States business that creates new jobs (“EB-5 Funds”). Our firm is also the manager of eight “Regional Centers” (under the EB-5 Program) throughout the United States. Sometimes our Real Estate Funds that are not EB-5 Funds invest together with one or more EB-5 Funds in the same underlying Real Estate Assets, or may participate in differing parts of a particular Real Estate Asset’s capital structure. For any Real Estate Fund, our advisory services are tailored to meet the Real Estate Fund’s investment strategy as described in its offering documents. Our services include the evaluation and selection of investments and the structuring and monitoring of those investments. Civitas’ investment decisions and advice with respect to its Real Estate Funds are in accordance with the investment objectives and restrictions set forth in the limited partnership agreement or other applicable governing documents of each Real Estate Fund and, where applicable, any side letters that such Real Estate Fund or its general partner (or manager, managing member or similar governing body) may enter into with one or more investors in such fund. Real Estate Assets in which Civitas’ Real Estate Funds invest may take the form of or include, without limitation: 1. the acquisition of direct interests in real property; 2. the formation of joint ventures or other co-investment arrangements with third parties for investments in Real Estate Assets (including the acquisition of debt and equity interests in joint ventures); 3.

the acquisition of securities in entities that own or invest in one or more Real Estate Assets; and 4. the issuance or acquisition of mezzanine or “bridge” financing, mortgage loans and other real estate-backed indebtedness, or participation in, or ownership of, securities backed by such indebtedness. Historically, our Real Estate Funds have invested in single (or a small group of related) Real Estate Assets consisting of either direct or indirect investments in real property (an “Equity Fund”) or direct or indirect investments in one of the loans or other types of indebtedness described above ultimately secured by an interest in Real Estate Assets (a “Loan Fund”). However, certain of our Real Estate Funds are permitted to make one or more investments of both types (“Diversified Funds”) For EB-5 Funds, we tailor our advisory services to include the satisfaction of job creation requirements imposed by the EB-5 Program, among other potential objectives set forth in the applicable governing documents. Our EB-5 Funds are typically initially structured as Loan Funds, however, after certain requirements of the EB-5 Program are met, at the direction of the investors in these EB-5 Funds, these EB-5 Funds may be restructured to become Equity Funds or Diversified Funds (and/or continue as Loan Funds). To meet our EB-5 Funds’ investment needs, we provide the following: 1. Sourcing EB-5 Program-compatible investments. Our firm screens and conducts financial analysis of potential investment projects to ensure that a project would meet the EB-5 Program requirements. 2. Ongoing Project Monitoring. Our firm employees oversee investments on a continuing basis to ensure that they remain within our funds’ investment objectives. 3. Performance Reporting. We periodically provide updates to our fund investors about the status of investment projects. Civitas enters into side letter agreements or other similar agreements with certain investors in its Real Estate Funds, typically only with institutional investors, which agreements provide such investors with rights and terms (including, without limitation, with respect to management fees, carried interest, co-investment rights, access to information/reporting obligations, the ability to be charged fees associated with the engagement of placement agents, “most favored nation” provisions and rights or terms requested or necessary in light of particular investment, legal, regulatory, or public policy characteristics of an investor) that are different or in addition to the general terms of the governing documents of the applicable fund. Civitas is not obligated to offer such additional and/or different rights or terms to all investors in its Real Estate Funds. We do not participate in wrap fee programs. As of December 31, 2023, we manage approximately $437,815,679 of discretionary regulatory assets under management. Our Real Estate Funds are not currently clients, as such term is defined in the Investment Advisers Act of 1940, though we expect to have Real Estate Fund clients in the near future. Out of an abundance of caution, we have included all Real Estate Funds relying on one or more exemptions from the registration requirements of the Investment Company Act of 1940, as amended (the “Investment Company Act”), in the calculation of discretionary assets under management. As of December 31, 2023, we manage approximately $616,787,479 of total discretionary assets inclusive of our Real Estate Funds.