A. THE FIRM AND PRINCIPAL OWNERS Based in Westchester County, New York, Belle Haven Investments, L.P. (“Belle Haven” or the “Firm”) is an independent, employee-owned, asset manager specializing in separately managed taxable and tax-sensitive fixed income investment strategies. The Firm manages taxable and tax-sensitive accounts which invest in U.S. municipal, corporate, government, and treasury securities. The Firm acts as subadvisor to an investment company registered under the Investment Company Act of 1940, and acts as a portfolio manager for one or more wrap fee programs. While Belle Haven’s asset management dates back to 2002, the Firm can trace its history back to 1991, when founded as an institutional broker/dealer. This background in institutional trading has helped form Belle Haven’s unique approach to portfolio management. The Firm’s Chief Executive Officer and Chief Investment Officer, Matt Dalton, has been with Belle Haven since 1996 and has over 35 years of experience in the fixed income marketplace. Over the years, Matt has built a humble, dedicated, and talented team of professionals, who truly form the foundation of its success. Matt Dalton is the Firm’s principal owner. Belle Haven is registered with the Securities and Exchange Commission (“SEC”) and is a member of both the Financial Industry Regulatory Authority (“FINRA”), and the Municipal Securities Rulemaking Board (“MSRB”). Additional information about Belle Haven Investments is also available on the SEC’s website at www.adviserinfo.sec.gov. B. TYPES OF SERVICES OFFERED INVESTMENT ADVISORY SERVICES The Firm provides discretionary investment advisory services, with respect to fixed income securities, and offers several fixed income strategies to a wide variety of clients, including but not limited to, individuals, high net worth individuals and families, pension and profit-sharing plans, registered investment companies, registered investment advisors, charitable organizations, business organizations, religious organizations, hospitals, insurance companies, educational institutions, and a pooled investment fund. SUBADVISOR TO SEPARATELY MANAGED ACCOUNTS Belle Haven provides investment advisory services through subadvised relationships with other investment advisory firms, consultants, and fiduciaries, including through third-party model marketplaces maintained by wrap fee program sponsors, for their client’s separately managed account(s). Each relationship will offer all or some of Belle Haven’s fixed income investment strategies to their clients. The following subadvisory relationships define the scope in which Belle Haven may provide investment advisory services to clients: SINGLE-CONTRACT ADVISORY SERVICES In instances where the client’s primary investment advisor has discretionary authority over their client’s account(s), specifically, the ability to hire another manager to manage the account of their client, and as such would like to exercise that discretion, Belle Haven would rely on their client agreement as documentation of their authority to retain and grant discretionary authority over to Belle Haven to manage such client’s account. This is known as the “Single-Contract Advisory Services” Option. This type of investment advisory services arrangement requires the client’s primary investment advisor to sign a Subadvisory Agreement directly with Belle Haven granting Belle Haven discretionary authority to manage such advisor’s client(s) account(s). DUAL-CONTRACT ADVISORY SERVICES In instances where the client’s primary investment advisor does not have discretion to hire other managers to manage their client’s account, or prefers not to exercise such discretion, the account would be setup as a Dual-Contract Account. This is known as a “Dual-Contract Advisory Services” Option. This type of investment advisory services arrangement requires the client of such account to sign an Investment Manager Client Agreement directly with Belle Haven granting Belle Haven discretionary authority to manage such client’s account. For clients accessing Belle Haven’s investment advisory services through an intermediary such as another investment advisor or wrap fee program sponsor, Belle Haven is not typically provided with sufficient information from such intermediary to perform a suitability assessment of the Firm’s fixed income investment strategies for their client’s account(s). Belle Haven relies on the intermediaries who, within their fiduciary duty, must determine whether Belle Haven’s fixed income investment strategies are suitable for their client’s account(s). This includes any assessment of whether a particular wrap free program is appropriate for the underlying client. Irrespective of the agreement arrangements, the client’s primary investment advisor or wrap fee program sponsor, rather than the end client, is generally the primary contact for Belle Haven in handling client communications and account updates. For clients in which there is no intermediary advisor, clients will sign an Investment Management Client Agreement with Belle Haven directly, granting full discretion of their investment advisory account. BELLE HAVEN AGGRESSIVE MUNI, L.P. The Firm

provides discretionary investment advisory services to Belle Haven Aggressive Muni, L.P. (“BHAM” or the “Fund”). BHAM is a private offering of limited partnership interests with a minimum initial investment of one million dollars ($1,000,000) and minimum additional investments of one hundred thousand dollars ($100,000). Belle Haven Capital Management, Inc. (“BHCM”), an affiliated company, is the General Partner of BHAM, controlled by Matt Dalton, as the Fund’s sole general partner with complete authority to manage the Fund’s business, investing and trading activities. The principal investment objective of BHAM is to maximize returns through opportunistic investment in a diversified portfolio of high-yield municipal securities. BHAM invests primarily in tax-exempt municipal securities with, on average, lower credit quality and longer duration (duration is a way to compare how different bonds will react to interest rate changes) than securities held in the Firm’s other fixed income strategies of its separately managed accounts. From time to time, BHAM may invest in taxable securities as well as securities subject to the alternative minimum tax. In addition, BHAM has the ability to trade derivatives, closed-end funds, and high dividend paying equities to employ leverage. BHAM offers limited partnership interests to a limited number of individuals and entities that satisfy the requirements of an “Accredited Investor” within the meaning of Regulation D under the Securities Act of 1933, as amended, as well as satisfy the requirements for “Qualified Clients” within the meaning of the Advisers Act. SUBADVISOR TO REGISTERED INVESTMENT COMPANIES The Firm acts as a subadvisor to Transamerica Asset Management, Inc. (“TAM”), a registered investment advisor who provides investment management services to Transamerica Funds (the “Trust”), an open-end investment company registered under the Investment Company Act of 1940. Specifically, Belle Haven acts as the subadvisor and provides investment advisory services to the Transamerica Intermediate Muni Fund, which seeks to maximize total return through a combination of current income that is exempt from federal tax and capital appreciation, and the Transamerica High Yield Muni Fund, which seeks to maximize total return through investment in medium and lower grade municipal securities that are exempt from federal income tax, the “Mutual Funds”, which are investment portfolios of the Transamerica Funds, represented by a separate series of shares. C. LEVEL OF SERVICE OFFERED Generally, Belle Haven manages its investment advisory accounts in accordance with the investment objectives and/or guidelines of the Firm’s fixed income strategies. The Firm does allow for reasonable client-imposed investment restrictions and other guidelines in the management of its investment advisory accounts; however, the imposition of certain restrictions may have a significant impact on the timing of such client’s strategy implementation and account performance may differ from the account performance of other investment advisory accounts managed within the same fixed income strategy. For BHAM, the investment objective and set of investment policies and/or guidelines are outlined in the Fund’s Offering Memorandum (“OM”), including additional Subscription Application and Agreement. Investors may not impose any restrictions on such investment program. For the Mutual Funds, the investment objective and set of investment policies and/or guidelines are outlined in the Transamerica Funds Prospectus, as defined by TAM. Investors may not impose any restrictions on those investment programs. D. INVESTMENT ADVISORY SERVICES TO WRAP FEE PROGRAMS As a subadvisor, Belle Haven provides discretionary investment advisory services to clients participating in wrap free programs, that the Firm does not sponsor. In a wrap fee program, Belle Haven will provide investment advisory services, and the wrap-fee program sponsor will provide additional services to the client such as assisting the client to determine the client’s investment objectives and risk tolerance, identify any investment restrictions on the management of the account, and select one of the fixed income investment strategies offered by Belle Haven. Belle Haven manages wrap fee accounts in the same manner as its investment advisory accounts not under a wrap fee program. Clients in wrap fee programs typically enter into an agreement with a wrap fee program sponsor. The wrap fee program sponsor enters into a Subadvisory Agreement with Belle Haven that grants discretionary authority to Belle Haven to manage such client’s wrap fee account. Some wrap fee program sponsors may require their client to sign an Investment Management Client Agreement with Belle Haven directly. As compensation for providing investment advisory services to such client’s account, Belle Haven will receive a portion of the all-inclusive wrap program fee that is calculated by the wrap fee program sponsor and remitted to Belle Haven in accordance with such Subadvisory Agreement between Belle Haven and the wrap fee program sponsor. E. ASSETS UNDER MANAGEMENT As December 31, 2023, Belle Haven Investments, L.P. had a total of $17,670,293,947 in discretionary regulatory assets under management (“RAUM”) and $0 in non-discretionary regulatory assets under management.