40|86 Advisors, Inc., a Delaware corporation (“40|86”), is a wholly owned subsidiary of CNO Financial Group, Inc. (NYSE: CNO), a publicly traded company (“CNO”). 40|86 was founded in 1981 and provides portfolio management services primarily to affiliated insurance companies (“Insurance Company Clients”). 40|86 also serves as sub-adviser or support services provider to CreekSource LLC (“CreekSource”) in connection with its management of entities that are structured as issuers of collateralized loan obligations (“CLOs”). 40|86 also provides investment advisory services to limited non-affiliated separate account clients. 40|86 has been registered as an investment adviser since 1982. 40|86 specializes in providing fully integrated fixed income portfolio management services. 40|86’s clients’ assets are primarily invested in multiple classes of fixed income securities and investments, including residential mortgage- backed securities, commercial mortgage-backed securities, consumer asset-backed securities, bank loans, investment grade corporate bonds, credit tenant loans, high yield corporate bonds, commercial mortgage loans, residential mortgage loans, alternatives, municipal bonds and U.S. Treasury securities and other government securities. In addition, 40|86 provides certain administrative services to Insurance Company Client accounts managed by third parties, including maintaining communication with third party managers with respect to the management of assets in such accounts. Generally, 40|86 has full discretion to make purchases and sales for a client’s account without requiring 40|86 to obtain consent or approval prior to each transaction, to select the type and amount of securities that 40|86 buys or sells for the account, the dealer 40|86 uses to effect such transactions and the mark-ups/mark-downs 40|86 pays to dealers for client transactions, in each case, in accordance with each client’s investment objectives and guidelines and, with respect to CreekSource’s

clients, in accordance with the applicable collateral management agreement and indenture of each CLO. Each client may impose certain restrictions or investment parameters for its account. For example, a client may specify minimum quality standards and/or restrict or prohibit transactions in securities of a specific type of issuer or sector. In addition, Insurance Company Client accounts are managed in accordance with applicable insurance regulations on permissible investments. CreekSource, a Delaware multi-series limited liability company, was formed in December 2014 to serve as the collateral manager to CLO issuer Clear Creek CLO, Ltd., a Cayman Islands exempted company (“Clear Creek”). In addition to serving as collateral manager to Clear Creek, CreekSource serves as collateral manager to the following issuers of CLOs: Silver Creek CLO, Ltd., a Cayman Islands exempted company (“Silver Creek”); Bean Creek CLO Ltd., a Cayman Islands exempted company (“Bean Creek”); and Deer Creek CLO, Ltd., a Cayman Islands exempted company (“Deer Creek,” which, together with Clear Creek, Silver Creek and Bean Creek are referred to collectively herein as “CLO Issuers”). In the future, CreekSource may serve as collateral manager to other issuers of CLOs. CreekSource is wholly owned by affiliates of CNO. 40|86 serves as sub-adviser or support services provider to CreekSource in connection with the management of the CLO Issuers and, in the future, may serve in such capacity with respect to other CLO issuers. Each CLO Issuer is exempt from registration as an investment company pursuant to Section 3(c)(7) of the Investment Company Act of 1940, as amended. You are receiving this Part 2A of Form ADV from 40|86 for itself (as “filing adviser”) and on behalf of CreekSource (as a “relying adviser”). 40|86 and CreekSource are referred to herein collectively as the “Advisers.” As of December 31, 2023, the Advisers managed approximately $26.678 billion in client assets on a discretionary basis.