Firm Description Keelan Capital L.L.C. (“Keelan Capital” or the “Firm”) is an SEC registered investment advisor. Keelan Capital was founded in June 2022. The Principal Owner and Chief Compliance Officer of Keelan Capital is Brendan Keelan. Types of Advisory Services The Firm offers a large variety of services, including portfolio management and investment analysis. The Firm offers these services to clients or potential clients (“clients”). Financial planning is offered as a complimentary service to portfolio management clients. Investment Advisory Services Portfolio Management As part of our Portfolio Management service, a portfolio is created based on an individualized financial plan created for the client. We consider our financial planning services part of our Portfolio Management services and do not charge an additional fee for such service. The portfolio may consist of individual stocks, bonds, exchange traded funds (“ETFs”), independent managers, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. In addition, we may also recommend that certain eligible clients invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). Any and all trades are made in the best interest of the client as part of Keelan Capital’s fiduciary duty. However, risk is inherent to any investing strategy and model. Therefore, Keelan Capital does not guarantee any results or returns. Keelan Capital is an asset-based fee investment management firm. The firm does not receive commissions for purchasing or selling stocks, bonds, mutual funds, real estate investment trusts, or other commissioned products for clients. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. Private Placement Investments When suitable for clients, typically accredited investors, qualified clients, and/or qualified purchasers (as those terms are defined by the Securities and Exchange Commission) with limited liquidity needs only, we may recommend and assist clients in making investments in private funds. Any private investments will be conducted exclusively via private funds offered and overseen by a reputable manager with recognizable institutional expertise in the targeted investment area. These funds are chosen when we believe they may offer some combination of:
• exposure to assets or investment strategies that may be uncorrelated, or less correlated, to the broad publicly traded equity and debt markets
• attractive sources of return from the assets or trading strategy that may be otherwise inaccessible or heavily constrained when offered in public investment vehicles To evaluate the relative attractiveness between private investments and publicly traded alternatives after considering the added risk factors and implementation issues inherent in private investments, we will typically complete some or all of the following analysis before making any initial investment recommendation, and during the ongoing period that we hold exposure to that investment:
• Initial and ongoing due diligence of the manager and the investment offering that may include: ▪ Review of fund subscription materials, audited financials, historical tax reporting samples, historical investment commentary and other reporting furnished by fund manager or sponsor ▪ In-person or remote attendance at fund manager or sponsor update calls, webinars, or meetings ▪ Fund performance reviews: monthly,

quarterly, semi-annual, or annual ▪ Discussion with other investors and review of third-party due diligence sources for the manager and the fund
• Coordinating tax document delivery and ongoing tax planning related to the fund with client CPAs to monitor any unique income character and ancillary filing requirements resulting from the private structure itself or the underlying investment activity
• Evaluation and integration of applicable fund liquidity opportunities within the context of, but not limited to, client goals, objectives, tax situation, need for liquidity, and estate planning
• Facilitate management and handling of all intervening private fund cash flows – including but not limited to - initial commitments, ongoing capital calls, income/capital distributions, voluntary/involuntary redemption activity, sequential commitment structuring, target illiquidity maintenance at the portfolio level
• Awareness and integration of any unique return/risk attributes for each individual fund and the private fund commitment as a whole with the consolidated portfolio construction and expected interaction between other client investments
• Ongoing performance/valuation reporting maintenance for all individual private investments and the private fund commitment as a whole – fully integrated into the client’s consolidated performance/risk reporting which covers all public and private investments across the portfolio. Sub-Advisor Keelan Capital may act as a sub-advisor for other financial institutions. The Firm will manage fixed income portfolios designed to meet the needs of institutions. Each portfolio is tailored to the circumstances, risk tolerance, time horizon, and other variables of each client. Use of Independent Managers Keelan Capital may select certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Keelan Capital evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves, and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance, and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Keelan Capital also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. Keelan Capital continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Keelan Capital seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Services Tailored to Clients’ Needs Services are provided based on a client’s specific needs of the client and their stated objectives, guidelines and restrictions on the account. We will rely upon information provided by the client or by an intermediary on behalf of the client. Clients are urged to notify Keelan Capital of any changes to their financial situation, goals, and risk tolerances as they occur. Wrap Fee Program versus Portfolio Management Program Keelan Capital does not offer a Wrap Fee Program. Assets Under Management As of December 31, 2023, The Firm has the following assets under management: Discretionary assets: $663,491,509 Non-discretionary assets: $0