Advisory Business Roc360 Advisors LLC (the "Adviser"), a U.S. Securities and Exchange Commission ("SEC") registered investment adviser, is one of several affiliated entities in the Roc Capital Holdings LLC family of compa- nies. At the time of filing of this brochure, the Adviser is a registered investment advisor with registration effective from June 21, 2023. The Adviser's indirect principals and executive officers are also principals or executive officers of certain other limited partnerships or limited liability companies that serve, directly or indirectly, as general partner or managing member of certain entities affiliated with the Adviser. Please see "Other Financial Industry Activities and Affiliations" below for a further discussion of entities affiliated with the Adviser. The Adviser has been in business since 2023 and is owned primarily by Arvind Raghunathan, indirectly through his ownership interest in Roc Capital Holdings LLC ("RCH"). Types of Advisory Services Offered The Adviser provides investment management services to Roc360 Real Estate Income Trust, Inc. (the "REIT" or the "Client"), a Maryland corporation, that has elected to be treated as a real estate investment trust for tax purposes. The REIT is focused on investments in the residential mortgage markets. The Client is currently the sole client of the Adviser. The investment advisory services provided by the Adviser to the Client focus on, but are not explicitly limited to, investments in residential mortgage loans. The principal focus of the Adviser is on acquiring and managing a portfolio of US business purpose loans, including bridge loans and term loans, and secu- ritizations backed by such loans on behalf of the Client and adjacent opportunities in residential credit. All of the loans purchased by the Client as of December 31, 2023 were originated and are serviced by two affiliates of the Adviser: Loan Funder LLC and Loan Servicer LLC. It is possible that the Client may purchase loans originated and/or serviced by other parties in the future. As discussed below, the Adviser has entered into a management agreement with the Client that governs the

activities of the Adviser. The management agreement includes a set of investment guidelines that outline the type of eligible assets that the Adviser will identify for purchase by the Client. These guidelines are subject to periodical change by the Client. The Adviser will utilize its experience and knowledge of the business purpose loan market to identify suitable loans and investment opportunities for the Client. Please see "Methods of analysis, investment strategies and risk of loss" below for further detail. Client Assets Under Management The Adviser provides discretionary investment advisory services to the Client and has discretionary man- agement authority and responsibility over the Client’s assets, subject to the terms of the management agree- ment signed between the parties. The Adviser had approximately $495,766,538 in regulatory assets under management as of December 31, 2023, including committed but uncalled capital, and excluding any associated indebtedness. The Client’s funds are utilized to acquire business purpose loans, including bridge loans or term loans, and to invest in adjacent opportunities in residential credit. The Client has signed a master mortgage loan purchase agreement with Loan Funder LLC (an affiliate of the Adviser) that governs the terms under which the Client purchases business purpose loans from Loan Funder LLC. The Adviser will review and approve all assets purchased by the Client, including those assets purchased from Loan Funder LLC. The Adviser will provide ongoing advice and reporting to the Client’s board of directors who will periodi- cally review the Client’s investment guidelines and its portfolio of assets but will generally not be required to, and will generally not, review all of its proposed acquisitions. Each purchase from Loan Funder LLC is governed by the terms of the master mortgage loan purchase agreement signed between the Client and Loan Funder LLC. The terms of this master mortgage loan purchase agreement were unanimously ap- proved by the board of directors of the Client. In conducting any periodic reviews, the board of directors of the Client will rely primarily on information provided to them by the Adviser.