A. Description of advisory firm and principal owners. Hudson Realty Capital LLC, a Delaware limited liability company, also referred to in this brochure as “Hudson Realty”, is a real estate investment advisory firm, which commenced operations in 2003. The principal owners of Hudson Realty are David Loo and Richard Ortiz. B. Advisory services offered. Hudson Realty provides investment advisory services to various private partnerships and other private investment vehicles, including co-investment and separate account vehicles (each, a “Fund” or a “Client” and, collectively, the “Funds” or “Clients”) each of which focuses on a broad range of real estate-related debt and opportunistic equity investments across multiple property types in the United States. Interests in the Funds are only offered to qualified investors through private offerings. Hudson Realty has affiliated entities that serve as the general partners to each of the Funds (each, a “General Partner” and, collectively, the “General Partners”) and each of the Funds is controlled by its respective General Partner. Occasionally, Hudson Realty and Hudson Realty’s principals, officers, partners, directors, employees, or other persons occupying a similar status or performing similar functions for the Firm (“Employees”) and their respective friends and families will co-invest collectively and, in certain instances, with third parties. Those deals are structured as strategic joint ventures (“Strategic JVs”) where decision making may be retained by the third-party investor or may be shared by the co-investors. Although certain Strategic JVs compensate Hudson Realty for performing origination, underwriting, servicing, reporting or other ministerial or administrative functions, Hudson Realty does not provide investment advice and consequently does not consider those principals, Employees, friends, family or co- investors to be Funds or Clients with respect to these Strategic JVs. Occasionally, these Strategic JVs are invested and structured in transactions on a side-by-side basis with Hudson Realty’s Funds or Clients. The Strategic JVs and co-investment opportunities are only pursued if Hudson Realty has determined that the potential investment is not appropriate for an existing Fund or Client, or alternatively, if such opportunity may be appropriate for an existing Fund or Client then the applicable Fund or Client has specifically elected not to invest in the opportunity. In addition, Hudson Realty provides non-discretionary advisory services to a separately managed account (“Managed Account”). Hudson Realty’s investment strategy is to make consistent and disciplined investments in, and the asset management of, a broad range of real estate-related debt and opportunistic investments throughout the United States, targeting middle-market investments. The types of assets held by the Funds include, but are not limited to, first mortgages, subordinated debt, preferred equity and direct equity in real estate. As discussed further in Item 8 of this brochure,

Hudson Realty generally concentrates its investment activity in middle market transactions, targeting investments in office, industrial, retail, and single- and multi-family residential properties. Hudson and its affiliates are engaged in various real estate related activities, many of which fall outside the scope of the stated investment objectives/mandates of its investment advisory clients. These activities could give rise to potential conflicts of interest, specifically with respect to the allocation of investment opportunities. On a case by case basis, Hudson first assesses the suitability of each prospective new deal for its advisory clients and, if it is determined that the investment is not appropriate, the Firm or its affiliates may pursue a proprietary investment or other structure in which the funds/clients do not participate. Hudson endeavors to ensure that any investment opportunities (which are often non-regulatory real estate assets) do not create conflicts of interest or that any conflicts can be mitigated. Additionally, Hudson also engages in certain other real estate related activities (i.e. property management, loan servicing and asset underwriting assignments) which are evaluated prior to engagement to minimize potential conflicts of interest with Hudson’s asset management advisory business. Additional information regarding such relationships and activities can be found in Item 10 of this Brochure. C. Tailoring to individual Client needs. Although Hudson Realty implements a substantially similar strategy for all of the Funds, Hudson Realty tailors its advisory services to the individual needs of a particular Fund, as may be necessary. Each Fund has a set of specific guidelines that may limit the strategy, size, concentration, geography, type of security and/or terms of the Fund’s underlying investments as described in each Fund’s operating agreements and offering documents. Investment advice is provided directly to each Fund and not to the individual investors in the Funds. Although Hudson Realty does not provide tailored investment advice to the individual investors in the Funds, the General Partners and/or the Funds may enter into side letter agreements with certain investors which may modify such investors’ rights or obligations under the operating agreements or such investors’ subscription agreement for a particular Fund or otherwise provide such investor preferential treatment in connection with such agreements, but, generally only to the extent the General Partner determines that such modifications are not materially detrimental to other investors, the Fund, its assets or the operation of its business. In addition, the Managed Account is subject to different investment objectives, restrictions, terms and/or fees than those of the Funds. D. Wrap fee programs. Hudson Realty does not participate in wrap fee programs. E. Assets under management. As of December 31, 2022, Hudson Realty managed approximately $125,057,281 of regulatory assets under management on a discretionary basis and $18,614,046 on a non-discretionary basis.