Keystone National Group, LLC (“we” or “Keystone”) is a private markets investment manager providing diversified investment products and strategies with a focus on current income, contractual cash flows and strong downside protection. We are dedicated to providing our clients with a wide array of alternative investment management and supervisory services. We specialize in providing alternative investment solutions and expertise to investors and their advisors in the areas of alternative investment selection and access, due diligence, and investment management. Our firm is a limited liability company governed by the laws of the State of Delaware. We have been in business as an investment advisor since 2006 and are principally owned by Brandon R. Nielson and John W. Earl.1 As of December 31, 2023, we managed approximately $2,130,000,279 on a discretionary basis. We seek to provide our Firm Clients with access to attractive risk-adjusted returns and emphasize continuous and regular supervision on investment advisory services to our clients. By combining in-depth research and industry relationships, we provide our clients with access to attractive and difficult-to-access private credit, real estate, equity, energy and other alternative investment opportunities. Our team has broad private markets and alternative investment experience, with particular expertise in private credit, equity, real estate and energy. We carefully evaluate risk through rigorous due diligence to understand the risk parameters of each investment. We believe that the combination of extensive due diligence, appropriate sector allocation and diversification, our deep network of relationships and first-class reporting and administration provide highly attractive private market alternative investment opportunities for our clients and their advisors. We primarily sponsor and provide investment advisory services to our affiliated private credit, private real estate, equity, energy, and other pooled investment fund clients (collectively, our “Fund Clients”), and other separately managed accounts, and a closed-end registered investment company (“RIC”) (together with our Fund Clients, our “Firm Clients”). The majority of our investment advisory services involve providing advice to Firm Clients on direct private credit, real estate and equity investments along with investments in privately-held funds or other investment vehicles that acquire the debt, equity and/or other assets of predominantly privately-held companies, publicly-held companies, real estate, energy or other investment opportunities (hereafter “Private Funds”), secondary investments in Private Funds, co- investments alongside fund managers and other direct investments in private credit, real estate, equity, energy and other investment opportunities. Keystone Private Funds are classified by the types of investments they make and include private credit, real estate, energy, buyout funds, mezzanine and other credit strategies, distressed credit funds and other funds that enable us to capitalize on alternative opportunities in the marketplace. For separately managed accounts, we provide advice on all types of investment securities and other assets, but primarily in the areas of alternative investments, private markets, real estate, private energy, and cash management. Our Firm Clients are pooled investment partnerships, separately managed accounts, a closed-end RIC, and other private market investment vehicles. These investment vehicles, with the exception of the RIC, are exempt from the requirement to register as an investment company under Section 3(c)(1), Section 3(c)5,

or 3(c)7 of the Investment Company Act of 1940. All investors are required either to be “accredited investors” (as defined in Regulation D promulgated under the Securities Act of 1933, as amended) or “qualified purchasers” (as defined in Section (2)(a)(51) of the Investment Company Act) or otherwise be permitted to invest in private placements under applicable federal and state securities laws, 1 Please note that for purposes of this item, our principal owners include the persons we list as owning 25% or more of our firm on Schedule A of Part 1A of Form ADV. rules, and regulations. The RIC will be offered to accredited investors and qualified clients only under a private placement memorandum. We also have discretionary sub-advised management relationships with various registered investment advisors and other investors by which Keystone provides primary investment management services, including the identification of private credit opportunities, due diligence on investments, monitoring, reporting services, identification, review and benchmarking of Private Funds and other investment opportunities, evaluation of portfolio or investment risk, negotiation and other related services. Sub-advisory services by other managers include, without limitation, investment review, investor relations and other related services. Monitoring and reporting services by Keystone include, without limitation, portfolio tracking, analysis and monitoring, compilation of performance data, review of various legal documentation, general research and education. We offer individualized investment advice to our Firm Clients utilizing our alternative investment solutions. We conduct extensive due diligence on each investment opportunity and strive to identify the general and specific risks inherent with each alternative investment made by our Firm Clients. The combination of extensive due diligence, evaluation of risk and appropriate industry, sector and company allocation and diversification allow us to offer Firm Clients with what we believe is the proper portfolio of alternative investments to suit their needs and desired level of risk, which targeted investment characteristics are generally set forth and agreed to at the time we are formally engaged by the client to provide such investment advisory services. Keystone only tailors its investment advisory and management services to the extent of the listed investment objectives and restrictions of each of its Firm Clients pursuant to the investment guidelines and restrictions set forth in a Client’s investment advisory or management agreement and other governing documents as well as through ongoing discussions with each client. Separate account clients have the ability to impose restrictions on investing in certain securities depending on the targeted investment characteristics and nature of our advisory relationship. There can be no assurance that any investment objectives stated in the account governing documents will be achieved. Those affiliated entities that serve as general partners and managers of the Fund Clients and that are listed in Schedule R of our Form ADV Part 1A (the “Keystone Relying Advisers”) are relying on Keystone National Group, LLC’s registration under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and are not registering themselves separately. Unless otherwise provided or the context otherwise requires, references to “we” and “Keystone” in this Brochure will include Keystone National Group, LLC and the Keystone Relying Advisers, collectively. Additional information regarding the RIC is found in the RIC offering documents.