Introduction ACM, a Delaware limited partnership founded in 2006, is an SEC‐registered investment adviser located in New York, New York. The principal owner of ACM is Ivan Q. Zinn. Mr. Zinn also serves as the Firm’s Chief Investment Officer. The Firm provides investment advisory services to certain pooled investment vehicles and “funds of one” (the “Atalaya Funds”), separately managed accounts (the “Atalaya Managed Accounts”) and may provide investment advisory services to co‐investment vehicles to the Atalaya Funds (“Atalaya Co‐Investments” and, collectively with the Atalaya Funds and the Atalaya Managed Accounts (as discussed below), the “Atalaya Clients” or the “Clients”). In July 2017, ACM sold a minority stake in the Firm to Dyal Capital Partners, at the time a division of Neuberger Berman Group (“Dyal”) that acquires passive, minority equity interests in alternative asset management businesses. The interests in ACM held by Dyal are permanent capital interests that, from time to time, require Dyal to make additional capital investments. Dyal does not participate in ACM’s day‐ to‐day operations or have any involvement in ACM’s investment decision‐making. Throughout the existence of its investment advisory business, Atalaya has focused primarily on investing in credit opportunities and special situations, including, without limitation, secondary loan acquisitions and primary loan originations. Affiliates of Atalaya generally serve as the general partner or managing member, as applicable (individually, a “General Partner” and, collectively, the “General Partners”) as well as collateral manager or collateral servicer to the Atalaya Funds. Any investment advisory activities of the General Partners are subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and the rules thereunder, and Atalaya and the General Partners are subject to examination by the SEC. The General Partners and all of their employees and persons acting on their behalf are subject to the Firm’s supervision and control with respect to any investment advisory activities. In March 2021, Atalaya closed its first Atalaya Special Purpose Investment Fund, with outside capital, which focuses on SPAC investing. SPAC investing is generally investing in public securities but may also include various Sponsor Investing and PIPEs). Neither ACM nor any Atalaya Fund, even when involved in Sponsor Investing or PIPEs, is responsible for any governance of the SPAC, although there may be economic consequences for failing to vote in favor of a business combination proposed by the SPACs management team. (see Item 8 for defined terms and further risks related to Atalaya’s SPAC investment strategy). Atalaya Clients Atalaya provides discretionary investment advisory services to the Atalaya Funds. Atalaya has discretion to invest and trade the Atalaya Funds’ assets pursuant to its investment or collateral management agreement with, and the governing documents of, each Atalaya Fund. Any applicable limitations or restrictions on Atalaya’s investment discretion (if any) are set forth in the governing documents of the applicable Atalaya Fund. Atalaya typically seeks to generate attractive risk‐adjusted returns by acquiring and/or originating a relatively diversified portfolio of opportunistic credit and special situations investments. Atalaya’s primary (but not exclusive) investment focus is on the opportunistic purchase of loans in the secondary market from distressed or otherwise motivated sellers, as well as the origination of credit to small and mid‐sized companies and/or credit secured by real estate, consumer finance, commercial finance or specialty finance related assets; provided that Atalaya may alter its investment focus in response to changing market conditions or other applicable factors. Notwithstanding the foregoing, with respect to certain Atalaya Funds that are “funds of one”, Atalaya may have non‐ discretionary authority with respect to such Atalaya Funds, with investment recommendations being subject to the consent or approval of the relevant investor. Atalaya generally manages each Atalaya Fund pursuant to the objectives specified in the materials (generally including, a private placement memorandum and applicable governing documents, made available to prospective

investors) by which each Atalaya Fund offers its ownership interests to investors and pursuant to the restrictions or limitations (if any) set forth therein. The Atalaya Funds’ investors generally do not have the right to restrict or influence the Atalaya Funds’ investment objectives or any investment or trading decisions. Atalaya may tailor the advisory services it provides to certain Atalaya Funds to the extent that certain investments cannot be held by certain Atalaya Funds for legal, regulatory and/or tax reasons and pursuant to its general portfolio management discretion, with respect to the investment activity of the Atalaya Funds. Atalaya Co‐Investments (if any) are generally special purpose vehicles and/or “funds of one” created for the Firm and one or more Atalaya Fund investors (and/or third parties) to invest directly in a company or credit‐related transaction or other special situations investment. Occasionally, Atalaya Co-Investments or Atalaya Managed Accounts are used to invest in a company or credit‐related transaction or other special situations investment that Atalaya has recommended to another Client. This generally occurs only when an applicable Client (typically, an Atalaya Fund) that invested in the company or credit‐related transaction or other special situations investment reaches its “threshold limit” regarding the amount of that investment such Client can (or should, as determined by Atalaya) hold in its portfolio. For purposes of ensuring a diversified portfolio, each Atalaya Fund typically has a limit on the percentage of capital that may be invested in a single investment or issuer, and Atalaya may separately determine that a lower threshold is appropriate, pursuant to its discretionary investment authority. Atalaya Co‐Investments (if any) and/or Atalaya Managed Accounts may also be applicable with respect to prospective investments that do not meet the investment objectives of any Atalaya Fund then open for new investment activity. With respect to co‐investment opportunities or other types of investment opportunities, Atalaya will be acting as an investment adviser to a co‐investor or third party only if Atalaya and the co‐investor or third party explicitly agree to such a relationship in writing. While Atalaya occasionally receives compensation in connection with providing investment structuring, investment underwriting, or other related services, or in connection with making one or more potential third parties aware of an investment or co‐investment opportunity, in the absence of a written agreement to create an advisory relationship and to provide advisory services to a current or prospective co‐investor or third party, Atalaya will be presumed not to be acting as an investment adviser in such instances. Unless explicitly agreed by Atalaya in writing, current and prospective participants in co‐investments and third parties with respect to other investment opportunities are responsible for independently evaluating all such investment opportunities. Atalaya generally has discretionary authority to make all trading and investment decisions for any Atalaya Co‐Investments, subject to any investment restrictions or limitations that an investor in an Atalaya Co- Investment may negotiate with Atalaya (which may limit Atalaya’s ability to make any other or separate investments). With respect to the Atalaya Managed Accounts, either (i) Atalaya may have discretionary authority to make all trading and investment decisions for the Atalaya Managed Accounts, subject to any investment restrictions or limitations that an investor in an Atalaya Co‐Investment may negotiate with Atalaya, or (ii) Atalaya may have non‐discretionary authority with respect to such Atalaya Managed Accounts, with investment recommendations being subject to the consent or approval of the managed account‐holder(s). As a general matter, Atalaya Clients may be permitted to impose reasonable restrictions on investing in certain securities or transactions or types of securities or transactions in an Atalaya Co‐Investment or Atalaya Managed Account. As of December 31, 2023, the Atalaya Clients had regulatory assets under management of approximately $9,338,563,411, of which Atalaya had discretion over approximately $9,111,483,439 of such assets, with the remaining approximately $227,079,972 of such assets being non‐discretionary.