A. Describe your advisory firm, including how long you have been in business. Identify your principal owner(s). Advisory Business Collegiate Peaks Asset Management, LLC (“CPAM”), was formed in May of 2022 as a Delaware limited liability company. CPAM provides investment advice and management to a privately placed investment fund, a Cayman Islands-based limited partnership (the “Current Fund”), of which CPAM is the investment manager (collectively, and along with any yet to be created privately placed investment funds, referred to herein as the “Funds”). CPAM also serves as an investment manager for and provides discretionary advisory services to separately managed accounts, primarily for institutions (“Separate Accounts”). The Funds and Separate Accounts are collectively referred to herein as “Clients.” In the case of the Current Fund, an affiliate of CPAM serves as its general partner with authority to make investment decisions on its behalf. Principal Owners/Ownership Structure CPAM is a wholly owned subsidiary of Collegiate Peaks Investors, LLC, a Delaware limited liability company, which is owned 77.5% by Michael O’Shea, the Firm’s Chief Executive Officer and Chief Investment Officer; 22.5% owned by Charles Laarsen, the Firm’s Chief Operating Officer. B. Describe the types of advisory services you offer. If you hold yourself out as specializing in a particular type of advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that service in greater detail. If you provide investment advice only with respect to limited types of investments, explain the type of investment advice you offer, and disclose that your advice is limited to those types of investments. CPAM’s investment objective is to invest primarily in structured products assets, which may include residential mortgage-backed securities (“RMBS”), commercial mortgage-backed securities (“CMBS”), asset-backed securities (“ABS”), collateralized mortgage obligations (“CMO”), small balance commercial securities, mortgage-related derivatives, collateralized debt obligations (“CDO”), net interest margin securities (“NIM”) and other similar securities. CPAM seeks to identify, evaluate, acquire, manage, and sell structured products and other assets in order to deliver performance that is non-correlated to major indices. C. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. The advisory services provided to each Client are tailored to the investment objectives, investment strategy and investment restrictions, if any, as set forth in the Governing Documents (as defined below) for each Client. Regarding the Funds, CPAM does not

tailor its advisory services to the individual needs of investors in its Funds; CPAM’s investment advice and authority for each Fund are tailored to the investment objectives of each particular Fund. Investment advice for the Separate Accounts is tailored to each Separate Account. The objectives of each Client are described in the private placement memorandum, limited partnership agreement, subscription agreement, investment management agreement and/or other governing documents of the relevant Fund or Separate Account (collectively, “Governing Documents”). Investors determine the suitability of an investment in a Fund or in a Separate Account, based on, among other things, these Governing Documents which outline applicable investment risks. Regarding the Funds, Fund investors cannot impose restrictions on investing in certain securities or types of securities. Investors participate in the overall investment program for the applicable Fund, but can be excused from a particular investment due to legal, regulatory or other applicable constraints, pursuant to the terms of the applicable Governing Documents. In accordance with industry common practice, a Fund’s General Partner may enter into side letters or similar agreements with certain investors in the Funds that have the effect of establishing rights under, or altering or supplementing a Fund’s Governing Documents. Examples of side letter rights that could be entered into include certain fee provisions, confidentiality provisions, liquidity and withdrawal provisions, concentration limits, notification provisions and most favored nations provisions. These rights, benefits or privileges are not always made available to all investors nor in some cases are they required to be disclosed to all investors, consistent with general market practice. There can be no assurance that the side letter rights granted to one or more investors will not in certain cases disadvantage other investors. Regarding Separate Accounts, CPAM’s investment advice is focused solely on investing in structured products and is tailored to that particular Client. D. If you participate in wrap fee programs by providing portfolio management services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. CPAM does not participate in wrap-fee programs. E. If you manage client assets, disclose the amount of client assets you manage on a discretionary basis and the amount of client assets you manage on a non-discretionary basis. Disclose the date “as of” which you calculated the amounts. As of December 31, 2023, CPAM manages $344,241,480 in regulatory assets under management on a fully discretionary basis. CPAM does not anticipate managing Client assets on a non-discretionary basis.