ACIM’s Business A. ACIM and its Principal Owners Atlantic Creek (sometimes referred to herein as “ACIM”) is a Delaware limited liability company with its principal place of business in New York, New York, and with an additional office in Palm Beach, Florida. Atlantic Creek was established in 2010 by its owners, BlueGate Partners, LLC (“BlueGate”) and Atlantic Capital Property Investments Corp. BlueGate is a real estate advisor and broker and is owned by Florida Crystals Corporation (“FCC”), Daniel Sachs, Eric Bylin and Mark DeLillo (see Item 11 below). Atlantic Capital Property Investments Corp. is wholly owned by FCC, which is majority owned by Fanjul Corp. BlueGate and Atlantic Capital Property Investments Corp. also jointly own the ACRE General Partners, which serve as the general partners and managing members to the ACRE Funds. B. Advisory Services All descriptions of the ACRE Funds in this Brochure, including, but not limited to, their investments, the strategies used in managing those entities, the fees and other costs associated with an investment in those entities, and conflicts of interest faced by ACIM in connection with management of those entities are qualified in their entirety by reference to the ACRE Funds’ Documentation. ACIM provides discretionary advisory services to the ACRE Funds, in each case based on the particular investment objectives and strategies described in the applicable ACRE Funds’ Documentation and any side letters entered into between ACIM on behalf of the ACRE Funds and ACRE Fund investors. The ACRE Funds seek to make (and/or have made) investments in commercial real estate and related assets, as described further in Item 8 below. The ACRE Funds (and their respective general partners and managing members) are as follows:
• Atlantic Creek Real Estate Fund II, L.P., a Delaware limited partnership (“ACRE Fund II Master”) (its general partner is Atlantic Creek Partners II, LLC);
• Atlantic Creek Real Estate Fund II Feeder, LLC, a Delaware limited liability company (“ACRE Fund II Feeder”) (its managing member is Atlantic Creek Partners II, LLC);
• Atlantic Creek Real Estate Fund III, L.P., a Delaware limited partnership (“ACRE Fund III Master”) (its general partner is Atlantic Creek Partners III, LLC);
• Atlantic Creek Real Estate Fund III Feeder, LLC, a Delaware limited liability company (“ACRE Fund III Feeder”) (its managing member is Atlantic Creek Partners III, LLC);
• Atlantic Creek Real Estate Fund IV, L.P., a Delaware limited partnership (“ACRE Fund IV Master”) (its general partner is Atlantic Creek Partners IV, LLC)
• Atlantic Creek Real Estate Fund IV Feeder, LLC, a Delaware limited liability company (“ACRE Fund IV Feeder”) (its managing member is Atlantic Creek Partners IV, LLC);

and
• Atlantic Creek Real Estate Fund IV Offshore, L.P., a Cayman Islands exempted limited partnership (“ACRE Fund IV Offshore”) (its general partner is Atlantic Creek Partners IV, LLC). As of December 31, 2021, ACRE Fund II Master and ACRE Fund II Feeder have been liquidated and, as of December 31, 2023, each contained only an immaterial cash position. As of January 31, 2024, ACRE Fund II Master and ACRE Fund II Feeder have been fully liquidated. ACRE Fund III Feeder invests substantially all its assets in ACRE Fund III Master. ACRE Fund IV Feeder and ACRE Fund IV Offshore invest substantially all their assets in ACRE Fund IV Master. Investors have invested in either the offshore fund, feeder funds or the master funds, depending on their respective tax statuses. Atlantic Creek will subject the ACRE General Partners, their employees (if any) and persons acting on their behalf to Atlantic Creek’s supervision and control and, therefore, the ACRE General Partners, all of their employees (if any) and any persons acting on their behalf are “persons associated with” Atlantic Creek (as defined in section 202(a)(17) of the Advisers Act). Unless otherwise provided, references to “ACIM” in this Brochure will include Atlantic Creek and the ACRE General Partners collectively. C. Tailoring of Advisory Services ACIM’s investment decisions and advice are subject to each ACRE Fund’s investment objectives, limitations, and guidelines, as set forth in the relevant ACRE Funds’ Documentation. Limitations and guidelines include the maximum level of borrowings. In addition, subject to the terms of the ACRE Funds’ Documentation, as described below, ACIM has entered into agreements (such as side letters) with, and/or offered co-investment opportunities to, certain ACRE Fund limited partners, and may enter into these agreements and/or offer co-investment opportunities to certain ACRE Fund limited partners in the future, in each case without the approval of any other limited partners. Side letters and co-investment opportunities may be granted to, among other reasons, incentivize or permit limited partners to invest with ACIM, invest certain amounts or invest with ACIM in the future. Side letters or other similar agreements have the effect of establishing rights under, altering or supplementing the terms of the relevant ACRE Funds’ Documentation with respect to one or more such limited partners in a manner that could be more favorable to such limited partners than those applicable to other limited partners. For example, the side letters or other similar agreements may reduce or waive certain of the fees applicable to limited partners. D. Wrap Fee Programs ACIM does not participate in wrap fee programs. E. Assets Under Management As of December 31, 2023, ACIM managed approximately $520,050,000, all on a discretionary basis.