BCM I (collectively with its affiliates, “BlackSand”), a Delaware limited liability company and a registered investment adviser, and its affiliated investment advisers provide investment advisory services to investment funds privately offered to qualified investors in the United States and elsewhere. BCM I commenced operations in May 2010. BCM I’s clients include the following (each, a “Fund,” and collectively, together with any future private investment fund to which BCM I and/or its affiliates provide investment advisory services, the “Funds”):
• BlackSand Capital Opportunity Fund I, L.P. (“BSC I”)
• BlackSand Capital Opportunity Co-Investment Fund I, L.P. (“BSC Co-Invest”) BCM I serves as general partner (the “General Partner”) to each of the Funds. BCM I is affiliated with other BlackSand investment advisers registered with the SEC, including BlackSand Capital, LLC (“BlackSand Capital”). BlackSand Capital is separately registered with the SEC as an investment adviser. This Brochure also describes the business practices of BlackSand Capital and its affiliated investment advisers, which operate as a single advisory business together with BCM I (BlackSand Capital, BCM I and their affiliated advisory entities are each referred to herein as an “Adviser,” and collectively, the “Advisers”). The Funds invest through negotiated transactions primarily in Hawaii-based real estate and real estate-related assets, generally referred to herein as “portfolio companies” or “portfolio investments.” The Advisers’ investment advisory services to the Funds consist of identifying and evaluating investment opportunities, negotiating the terms of investments, managing and monitoring investments and achieving dispositions for such investments. Where such investments consist of operating entities, the senior principals or other personnel of the Advisers or their affiliates generally serve on such operating entities’ respective boards of directors (or equivalent governing body) or otherwise act to influence control over management of operating entities and other assets in which the Funds have invested. The Advisers’ advisory services to the Funds are detailed in the relevant private placement memoranda or other offering documents (each, a “Memorandum”), limited partnership or other operating agreements or governing documents of the Funds (each, a “Partnership Agreement,” and together with any relevant Memorandum, the “Governing Documents”) and are further described below under “Methods of Analysis, Investment Strategies and Risk of Loss.” Investors in the Funds (generally referred to herein as “investors,” “limited partners” or “partners”) participate in the overall investment program for the applicable Fund, but in certain circumstances are excused from a particular investment due to legal, regulatory or other agreed-upon circumstances pursuant to the Governing Documents; for the avoidance of doubt, such arrangements generally do not

and will not create an adviser-client relationship between any Adviser and any investor. The Funds or the General Partner have entered, and expect in the future to enter, into side letters or other similar agreements (“Side Letters”) with certain investors that have the effect of establishing rights under, or altering or supplementing the terms (including economic or other terms) of, the Governing Documents with respect to such investors. Additionally, as permitted by the Governing Documents, the Advisers expect to provide (or agree to provide) co-investment opportunities (including the opportunity to participate in co- invest vehicles) to certain current or prospective investors or other persons, including other sponsors, market participants, finders, consultants and other service providers, portfolio investment management or personnel, the Advisers’ personnel and/or certain other persons associated with or related to the Advisers and/or their affiliates (e.g., a vehicle formed by the Adviser and/or Adviser personnel to co-invest alongside one or more Fund transactions). Such co- investments typically involve investment and disposal of interests in the applicable portfolio investment at substantially the same time and on substantially the same terms as the Fund making the investment. However, for strategic and other reasons, a co-investor or co-invest vehicle (including a co-investing Fund) purchases a portion of an investment from one or more Funds after such Funds have consummated their investment (also known as a post-closing sell-down or transfer), which generally will have been funded through Fund investor capital contributions and/or the use of a Fund credit facility. Any such purchase from a Fund by a co-investor or co- invest vehicle generally occurs shortly after the Fund’s completion of the investment to avoid any changes in valuation of the investment, but in certain instances could be well after the Fund’s initial purchase. Where appropriate, and in the applicable Adviser’s sole discretion, the Adviser reserves the right to charge interest on the purchase to the co-investor or co-invest vehicle (or otherwise equitably to adjust the purchase price under certain conditions), and to seek reimbursement to the relevant Fund for related costs. However, to the extent any such amounts are not so charged or reimbursed (including charges or reimbursements required pursuant to applicable law), they generally will be borne by the relevant Fund. As of December 31, 2023, BCM I managed approximately $39,863,177 in client assets on a discretionary basis. BCM I is principally owned and controlled by Bert A. Kobayashi, Jr. and Ian MacNaughton (together, the “Principals”). While Mr. MacNaughton remains a Principal owner and control person of BCM I, he has delegated day-to-day management responsibilities and the authority to make investment decisions to Mr. Kobayashi, who serves as Chairman and Chief Executive Officer of BlackSand.