Description of Advisory Services: SRAC was formed in 2021 and is based in Darien, Connecticut. SRAC is organized as a limited liability company under the laws of the State of Delaware. SRAC is a successor to Old Hill Partners Inc., which assigned its clients to SRAC in 2021 in connection with SRAC becoming a relying adviser of Spouting Rock Asset Management, LLC (“Spouting Rock”). SRAC is in the process of spinning-off from Spouting Rock, and SRAC became an independently registered investment adviser with the SEC on February 20, 2024. For the avoidance of doubt, neither Spouting Rock nor its affiliated persons or owners have provided any investment advisory services or operational support to SRAC since February 20, 2024. SRAC is a boutique investment management firm that manages private funds that offer individuals and institutions exposure to investments in illiquid private credit alternative products. The advisory services offered by SRAC generally include investment management services rendered to the Credit Funds (as defined below) or separately managed accounts. SRAC is sometimes referred to herein collectively as “SRAC”, “we” or “us.” Fund Management Services We offer discretionary and non-discretionary investment advisory and portfolio management services to private funds (each, a “Credit Fund”, and together the “Credit Funds”) and separately managed accounts (“SMA”s, together with the Credit Funds, the “Funds”, and each, a “Fund”). Private Credit Strategies. SRAC offers private credit investment strategies focused on senior-secured term and revolving loans to middle and lower middle market companies. These strategies are focused on capital preservation and income distribution during the life of the Credit Funds and SMAs under SRAC’s management. The SRAC Strategy. The SRAC Strategy is a private credit strategy that focuses on generating yield for investors by executing senior secured asset-based lending transactions focused on deals from $10mm to $50mm with a maturity of 1-5 years. The SRAC Strategy provides discretionary investment advisory services including, but not limited to, managing and directing the investment and reinvestment of assets for the following four (4) private investment funds:
• PFM Credit Recovery Fund I, LLC, a Delaware limited liability company (the “PFM Credit Fund”);
• OHP II LP, a Delaware limited partnership;
• OHPLTD, LLC, a Delaware limited liability company; and
• OHPC LP, a Delaware limited partnership. The terms for each Credit Fund are disclosed in detail in each Credit Fund’s offering documents that are provided to prospective investors prior to investment. SRAC acts as the investment manager and/or managing member to each of the Credit Funds. SRAC primarily invests its clients’ assets directly, or indirectly through a participation (as applicable), in senior secured term loans, senior secured revolving loans, direct purchases of assets or other hybrid structures that generally replicate the risk and return profile of senior secured loans. SRAC may also invest in mezzanine

or other non- senior debt structures. Additionally, SRAC may invest in indices and exchange-traded funds (“ETFs”) for hedging purposes and may also opportunistically invest in public equity securities, such as business development companies (“BDCs”), from time to time that, in SRAC’s view, provide exposure to credit markets. When deemed appropriate SRAC may establish an SMA that may tailor its investment objectives to those of the specific investor and/or be subject to different terms and/or fees than those of the Credit Funds. Such investment objectives, fee arrangements and terms are individually negotiated, and it should be noted that any such SMA relationships are generally subject to higher account minimums. Where appropriate, the Firm or its affiliates may offer co-investment opportunities to one or more (but not necessarily all) of the investors or other persons, and the Firm and its affiliates and persons or entities that it advises or sponsors also may participate in such co-investments (a “Co-Investment Opportunity”). In the event of a Co-Investment Opportunity: (i) no investor will be required to participate in such Co-Investment Opportunity unless it so chooses and (ii) the sponsor of the relevant Co-Investment Opportunity will, in its sole discretion, determine the terms of such participation and whether, and in what amounts, an investor or third-party will be permitted to participate in such Co-Investment Opportunity. Any Co-Investment Opportunity will not be part of the Credit Fund and the terms of any Co- Investment Opportunity will not be governed by the terms of the applicable governing agreement of the Credit Fund. For the avoidance of doubt, any fees received by the Firm or its affiliates will not offset or reduce the amount of the management fees otherwise payable to the Firm. Pooled Investment Vehicles SRAC provides investment advisory services, pursuant to the investment guidelines as set forth in the applicable offering memoranda of several private commingled funds, which include the Credit Funds described above. SRAC may provide investment advisory services to other private funds in the future. SRAC tailors its Portfolio Management Services to the specific needs of each particular Credit Fund by complying with the terms of each Credit Fund’s governing documents or other limitations which the Credit Fund may request. For more information about our investment strategies, please see Item 8 (Methods of Analysis, Investment Strategies and Risks of Loss). The investment strategies discussed in this Brochure may not be appropriate for all clients. We aim to only recommend those strategies that are believed to be suitable for a particular client. Wrap Fee Program We are neither a portfolio manager to nor a sponsor of any wrap fee program. Assets Under Management As of February 29, 2024, SRAC had approximately $135,714,317 of assets under management which are managed on a discretionary basis. As of February 29, 2024, SRAC had $49,935,615 of assets under management which are managed on a non-discretionary basis.