a) Background Vibrant Capital Partners, Inc. (“VCP”) is an asset management firm specialized in structured and alternative credit products. VCP was founded in 2006 and is headquartered in New York. Since inception, VCP has been focused on structured and alternative credit markets, providing discretionary and non-discretionary portfolio management and investment advisory services to investors such as insurance companies, pension funds, banks, private investment funds, family offices, and fund-of-funds, mainly in the form of pooled investment vehicles and separate accounts (the “Separate Accounts”). In 2011, VCP expanded into the portfolio management of leveraged loans, launching its Syndicated Credit Division. Since then, VCP has issued fifteen collateralized loan obligation (“CLO”) vehicles, of which three CLOs (Vibrant CLO, Ltd. and Vibrant CLO II, Ltd., and Vibrant CLO V, Ltd.) have been successfully called. Ten CLOs are in their reinvestment periods, while two CLOs, Vibrant CLO VI, Ltd. and Vibrant CLO VII, Ltd.are in their post-reinvestment periods. Vibrant CLO VI, Ltd., Vibrant CLO VII, Ltd., and Vibrant CLO XI, Ltd. are EU risk retention compliant and managed by VCP’s relying adviser, Vibrant Credit Partners, LLC, with VCP acting as a sub-adviser. Additionally, VCP currently has two CLO warehouses open for its upcoming CLO transaction, Vibrant CLO XVI, Ltd. and Vibrant CLO XVIII. VCP also manages four open-ended investment funds (the “Funds”), including the SENTE Fund, the SENTE Strategic Fund, the Vibrant Opportunity Fund, , and the Vibrant Ambar Fund, as well as eleven separately managed accounts (the “Separate Accounts”), which predominantly focus on capturing opportunities in the CLO debt tranche markets. VCP further may provide arms-length risk advisory and consulting services focused on structured credit portfolios for certain institutional investors. Unless clearly suggested otherwise, the Funds, the CLOs and Separate Accounts are collectively referred to herein as the “Clients”. b) Advisory Services VCP provides investment advisory and consulting services geared towards the structured and alternative credit markets. Additionally, VCP may be hired

as a consultant to provide risk advisory solutions to meet a variety of objectives, including, but not limited to, risk monitoring and/or valuation of portfolios of complex credit assets, and consulting on deal structuring and documentation, quantitative modeling as well as for general business development consulting. c) Tailored Advice and Client-Imposed Restrictions VCP offers each of its Clients tailored advice to suit its investment objectives, strategies and restrictions within the expertise of VCP’s offerings. Certain VCP services focus on a narrow investment strategy while others may pursue a broader investment strategy. In general, VCP prepares offering materials with respect to each Client that contain more detailed information, including a description of the investment objective and strategy or strategies employed and related restrictions. These serve as a limitation on VCP’s management. Clients can also impose restrictions on VCP’s management through documents defining the investment program for the Client. An investment in a VCP Fund does not create a client-adviser relationship between VCP and an investor. Clients and Investors must consider whether a particular VCP advisory relationship is appropriate to their own circumstances based on all relevant factors including, but not limited to, the Client’s own investment objectives, liquidity requirements, tax situation and risk tolerance. Prospective Clients are strongly encouraged to undertake appropriate due diligence, including, but not limited to, a review of documents relating to the proposed investment program for the Funds, Separate Account, or CLOs and to investigate additional details about VCP’s investment strategies, operations, methods of analysis, and related risks (see also Item 8 of this Brochure), before making an investment decision or committing to a service provided by VCP. d) Wrap Fee Disclosure Not applicable. e) Assets Under Management As of December 31, 2022, VCP managed approximately $7,703,794,971 in assets under management (“AUM”) on a discretionary basis and approximately $141,512,265 in AUM on a non-discretionary basis.