Overview and Principal Ownership Abacus Capital Group LLC (“ACG” or “Abacus”) is a limited liability company operating under the laws of the state of Delaware and was formed in 2004 to provide real estate investment management services. ACG’s principal owner is AMG Symmetry Acquisition LLC (“AMG Symmetry”), which holds a majority equity interest in ACG. The remaining interest in the firm is owned by the individual partners in the firm. ACG is managed by its management committee, which is currently comprised of senior management of ACG. AMG Symmetry is wholly owned by Affiliated Managers Group, Inc. (“AMG”), a publicly-listed asset management company (NYSE: AMG) with equity investments in boutique investment management firms. In addition to its indirect equity interest in ACG, AMG also holds equity interests in other investment management firms (collectively the “AMG Affiliates”). Each of the AMG Affiliates, including ACG, operates autonomously and independently, except as described in this Brochure. As set forth more fully below, ACG provides a variety of real estate investment management services based on the specific needs of the client and on the nature of the assets that are being acquired on the client’s behalf. Background of ACG and its Clients ACG primarily provides real estate investment management services to institutional and individual investors through privately offered pooled investment funds (“Private Funds” or “Funds”). Each Fund is exempt from registration as an investment company pursuant to either Section 3(c)(7) or Section 3(c)(1) of the Investment Company Act of 1940, as amended (the “Investment Company Act”), as applicable to each Fund. The Private Funds may issue interests that may be structured in various forms including equity, preferred equity, mezzanine debt or any other financial structure that is consistent with the particular Fund’s investment objectives. Abacus will, through a management agreement, provide acquisition, asset management and administrative services to the Funds. For purposes of this Brochure, the Funds, and not the Funds’ investors, are considered Abacus’s clients. The general partners of the Funds (the “General Partners”), each of which is an affiliate of Abacus, have broad discretion under the Funds’ respective limited partnership agreements to manage the affairs of the Funds. Pursuant to such discretion, each of the General Partners has engaged ACG to provide asset management, acquisition, origination, and administrative services on behalf of the respective Funds. In addition, ACG is responsible for establishing an investment committee for each Fund (collectively, the “Investment Committees”), which is responsible for reviewing and approving any investments recommended by ACG. The members of the Investment Committees are all supervised persons of ACG. In addition, ACG may in the future provide real estate investment management services with respect to individual properties that are owned through joint venture arrangements (the “Joint Venture Clients”). The Joint Venture Clients grant non-discretionary investment authority to ACG within certain limitations that are negotiated for each particular joint venture transaction. As of the date of this filing, ACG has not established any agreements with

Joint Venture Clients. ACG has, and may in the future, establish investment advisory agreements with institutional investment managers regarding direct or indirect interests in real property. ACG shall seek out real property investment opportunities and submit proposals and negotiate the terms for the disposition of such properties on behalf of the institutional investment manager. In such instances, the investment manager retains complete and absolute discretion with respect to its acquisition or disposition of real properties and the making of qualified investments or liquidating of managed properties. ACG may also perform asset management services with respect to the real property. As of the date of this filing, ACG has not made any recommendations and does not manage any assets with respect to such arrangements. Description of Services ACG primarily advises on investments in the direct equity of multifamily real estate. For example, ACG is involved in acquiring, redeveloping, developing, managing and disposing of multifamily properties throughout the United States. ACG seeks to capitalize on the dislocation in the multifamily markets through its direct sourcing capabilities and to create value through its asset management and asset repositioning expertise. ACG may also formulate strategies for investments in mortgage debt, mezzanine debt or publicly-traded REITs depending on the specific needs of the client. Additionally, strategies for investments in non-multifamily real estate (e.g., office, retail, etc.) may be considered. ACG typically provides real estate investment management services throughout the life-cycle of an investment. That may include sourcing an investment opportunity, formulating investment guidelines and preparing investment plans for the structuring and implementation of potential investments, sourcing the debt and equity capital, performing due diligence, executing a tailored business strategy, asset management and financial reporting, developing exit strategies, managing sales marketing campaigns, and executing on asset sales. Alternatively, depending on the needs of the client, ACG may provide advisory services only through the time of property acquisition. Different fee arrangements may be negotiated in these situations. In addition, ACG’s advisory agreements may include limitations on the allocation of funds to certain investments (i.e., less than 25% in brand new development). For more detail on the strategy formulations, please see Item 8, Investment Strategies and Risk of Loss, below. General Partner Commitment The General Partners of the Private Funds, each of which is wholly-owned by the principals of ACG, have committed to invest a specified amount of its capital in each Private Fund as set forth in the respective Private Fund’s governing documents (the “General Partner Commitment”). The General Partner Commitment is discussed further in Sections 5 and 11, below. Wrap Fee Programs ACG does not participate in any “wrap fee” programs. Assets Under Management As of December 31, 2023, ACG had $5,398,777,766 in regulatory assets under management, including unfunded commitments of the Private Funds. $5,398,777,766 was managed on a discretionary basis and $0 was managed on a non-discretionary basis.