A. Description of Advisory Firm This Brochure relates to the investment advisory services offered by Security Capital Research & Management Incorporated (“Security Capital” or the “Adviser”). Security Capital is registered with the United States Securities and Exchange Commission (“SEC”) as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Security Capital, together with 55I, LLC, Bear Stearns Asset Management Inc., Campbell Global, LLC, Highbridge Capital Management, LLC, J.P. Morgan Alternative Asset Management, Inc., J.P. Morgan Investment Management Inc., JPMorgan Asset Management (Asia Pacific) Limited, JPMorgan Asset Management (UK) Limited, JPMorgan Funds Limited, each an SEC registered investment adviser, various affiliated foreign investment advisers and the asset management division of JPMorgan Chase Bank, N.A. comprise the Asset Management ("AM") business of J.P. Morgan Asset & Wealth Management ("JPMAWM"). J.P. Morgan Asset Management ("JPMAM") is the marketing name for the AM businesses of JPMorgan Chase & Co. and its affiliates worldwide (“JPMC”). JPMC is a publicly traded global financial services firm.
JPMorgan Asset Management Holdings Inc., which is a subsidiary of JPMC, owns all the common stock of Security Capital. Security Capital was incorporated in Delaware on December 30, 1996.
B. Description of Advisory Services Security Capital is a boutique investment management company with an exclusive focus on investments in publicly traded real estate securities. Security Capital's three-member Portfolio Management Team (“PMT”) makes all investment decisions. The PMT evaluates all real estate research, company specific analysis and recommendations presented by the Research & Analysis, and Portfolio Analytics & Execution teams in order to identify investments that present the greatest opportunity to achieve the objectives of the specific strategy. The PMT members, Anthony R. Manno Jr., Kevin W. Bedell, and Nathan J. Gear, together have a combined average of over 36 years of real estate and capital markets experience.
The Adviser’s advisory services are offered on both a discretionary and non-discretionary basis through a variety of investment vehicles and arrangements, depending on the strategy, as further described below.
Separately Managed Accounts The Adviser offers investment advisory services to institutional and high net worth clients through separately managed accounts ("SMAs"). Clients typically retain the Adviser pursuant to an investment advisory agreement between the Adviser and the client. The Adviser offers SMAs in many of its investment strategies. When the Adviser contracts with a client for a discretionary SMA, the Adviser generally has the authority to

execute trades for the client's account. A client typically consults with the Adviser during the negotiation of the investment advisory agreement, prior to funding its account, to create investment guidelines for the client's account. Investment guidelines for SMAs are typically customized to each specific client account and such guidelines may vary significantly among SMAs within the same strategy or with the same investment objective.
Sub-Advisory Accounts Sub-advisory services are offered to institutional clients (including third party mutual funds) where the Adviser contracts with an affiliated or unaffiliated investment adviser to provide investment advice on a discretionary basis. Other Pooled Investment Vehicles The Adviser offers investment advisory services to other pooled investment vehicles across its various strategies. These other pooled investment vehicles include private funds. Investors generally invest directly in a pooled investment vehicle via a subscription agreement but, in certain instances, will contract with the Adviser for an investment. Pooled investment vehicles managed by the Adviser are managed in accordance with each vehicle's investment guidelines and restrictions and are generally not tailored to the individual needs of any particular investor.
C. Availability of Customized Services for Individual Clients Security Capital typically makes investments for clients in accordance with written investment guidelines or other investment specific documentation for each advisory mandate. Investment services may be tailored for each client’s specific needs and objectives, and typically include restrictions or limits on investments in certain securities or types of securities. Security Capital has procedures and controls to monitor compliance with each client’s investment guidelines.
Where Security Capital is the investment adviser to a pooled investment vehicle, investment objectives, guidelines and any investment restrictions generally are not tailored to the needs of individual investors in those vehicles, but rather are described in the prospectus or other relevant offering document for the vehicle.
D. Wrap Fee Programs Security Capital's investment advisory services are currently not offered through any wrap fee programs.
E. Assets Under Management As of December 31, 2023, Security Capital had assets under management in the amounts set forth below: Assets Under ManagementU.S. Dollar Amount Assets Managed on a Discretionary Basis$3,967,990,785 Assets Managed on a Non-Discretionary Basis$0 Total Regulatory Assets Under Management$3,967,990,785 Other Advisory Assets not included in Regulatory Assets Under Management$0 Total Assets Under Management$3,967,990,785