Firm Description NewOak Asset Management LLC (“NAM”) is a Delaware limited liability company which is wholly owned by NewOak Capital LLC (“NOC”). NAM was formed in 20091 and had been substantially inactive from formation until October 1, 2014 when it became an SEC registered investment adviser. NOC, NAM’s parent, is a financial advisory and consulting firm that provides strategic, analytical and forensic consulting in the areas of risk management, valuation and credit covering multiple asset classes including residential and commercial mortgages and securities, consumer finance, municipal, and corporate securities and loans and supports and invests in early-stage ventures in fin-tech, finance, trade fiancé, and renewables and other areas. NOC has four principal operating subsidiaries in addition to NAM: NewOak Advisors LLC, which provides fundamental analyses, valuation, risk and model validation services with respect to a variety of asset classes and complex asset-backed securities; Oak Branch Advisors LLC (34.9% owned by NOC), which provides middle office and back office services regarding private debt as well as underwriting, compliance, credit rating, independent audit and quality control for mortgage loans and in connection with mortgage- backed securities litigation and secondary mortgages; NewOak Finance, Inc. (“NFI”) (90% of voting shares owned by NOC), which invests in and provides management services to early-stage fin-tech ventures including Business-to-Business-to-Consumer and financial wellness products including earned wage access and related proprietary fintech ecosystem; and NewOak Capital Markets LLC, a registered broker-dealer (member of FINRA, SIPC and MSRB). Additionally, as of December 31, 2023, NAM owned 33.33% of Acorn Trade Finance LLC (“Acorn”), an early-stage trade finance company focused on Latin America. As of the date of this Brochure NAM has acquired the remaining interests in Acorn, which is now a 100%-owned subsidiary of NAM. Principal Owners NAM is 100% owned by NOC, which in turn is 100% owned by NewOak Capital Holdings, L.P., a Delaware limited partnership. Ron D’Vari, who is the Chief Executive Officer of both NAM and NOC, owns 84.5% of the equity interest of NewOak Capital Holdings, L.P., including a controlling interest in the general partner. No other person owns more than 25% of the equity interest of NewOak Capital Holdings, L.P. Types of Advisory Services NAM focuses its investment advice to the following types of investments: asset-backed securities (“ABS”), residential mortgage loans secured by real estate located in the United States, residential mortgage backed securities (“RMBS”), mortgage servicing rights (“MSR”), pooled consumer and commercial receivables, nonpublic equity securities and derivatives, credit and interest rate swaps (solely in connection with hedging activities). 1 NAM was originally formed as “NewOak Capital Asset Management LLC”. It changed its name to NewOak Asset Management LLC in 2013. NAM provides only discretionary advisory

services. NAM provides advisory services on a discretionary basis to a private fund, NewOak SJ- MAC Trust 2020-1 (the “Trust”). The Trust is controlled by Wilmington Trust, N.A., as trustee, and is a pooled investment vehicle formed as a Delaware trust formed to liquidate the assets of the NewOak SJ-MAC Cayman Fund Ltd. (the “Cayman Fund”), a private fund advised by NAM. The Trust is not open to new investment. The Trust’s assets consist of residential mortgage loans and cash. The mortgage loans, which were originally acquired by the Cayman Fund, are large (typically $1 million to $5 million) mortgage loans made to high-net-worth individuals underwritten with consideration of alternative income sources. NAM provides substantially all required investment advisory and asset management services to the Trust in connection with the management of the Trust’s assets consistent with the Trust’s investment guidelines. Such services include:
• Collateral management services required of the Trust
• Sale of Trust assets; and
• Such other investment management activities as may be agreed to by NAM and the Trust under the Trust’s Investment Advisory Agreement. Certain of the above services will be performed for NAM by related parties. There will be no separate charge to clients for such services. Neither NAM nor any related party of NAM will provide trustee, custodian or fund administration services to, or perform loan servicing for, the Trust. Additionally, NAM has entered into asset management agreements with two fin- tech companies to provide asset management services for pools of consumer or commercial receivables. Both of these companies are controlled by NFI, an affiliate of NAM. NAM has also entered into an investment advisory agreement with NOC, its parent, pursuant to which NAM managed NOC’s investment portfolio.
Availability of Tailored Services for Individual Clients NAM provides advisory services to its clients pursuant to the agreements described below based on the specific client requirements, investment objectives and strategies described in this Brochure. NAM does not tailor advisory services to the individual needs of non- institutional clients. Clients for which NAM provides discretionary advisory services may impose restrictions on investing in certain securities or certain types of securities. Assets Under Management As of December 31, 2023, NAM had total assets under management of $36,422,953.. Types of Agreements NAM provides discretionary services to the Trust under Investment Advisory Agreements with the Trust. NAM also provides discretionary services to the two fin-tech companies mentioned above under asset management agreements with those companies. These agreements collectively are referred to as the “IAAs”. The IAAs all provide, among other things, that:
• NAM has broad discretion to manage, invest and reinvest assets of its clients, subject only to the respective clients’ investment guidelines;
• NAM is entitled to receive an investment advisory fee (as more fully described in