PLFA is a Delaware limited liability company that began operations on May 1, 2007. PLFA is a SEC registered investment adviser and also is registered with the Commodity Futures Trading Commission as a commodity pool operator and is a member of the National Futures Association. PLFA is a direct subsidiary of Pacific Life Insurance Company (“Pacific Life”) and an indirect, wholly owned subsidiary of Pacific Mutual Holding Company, the ultimate parent company of the Pacific Life group of companies. PLFA provides discretionary investment advisory services to various products and/or investment vehicles as described below. Assets Under Management. As of December 31, 2023, PLFA had $39,897,306,252 in assets under management. All assets were managed on a discretionary basis. Types of Advisory Services: PLFA’s advisory services are offered to the following types of products and/or investment vehicles:
• U.S. open-ended mutual funds (“Mutual Funds”) registered under the Investment Company Act of 1940 (the “Investment Company Act”); and
• A private investment fund that is being offered pursuant to Regulation D of the Securities Act of 1933 and excluded from the investment company definition under Sections 3(c)(5) and/or 3(c)(7) of the Investment Company Act (the “Private Fund”) (Mutual Funds and the Private Fund may be referred to collectively herein as “Pooled Funds”). PLFA is engaged in the business of managing or advising certain affiliated and non-affiliated Pooled Funds. In certain circumstances, PLFA provides both investment advisory services and administrative services to Pooled Funds. Investment advisory services typically include the selection of securities, the placement of orders for the purchase and sale of securities, and/or the engagement and monitoring of one or more affiliated or unaffiliated sub-adviser(s). Complete information concerning each Pooled Fund that PLFA advises, including fees, and risks and conflicts, is disclosed in the offering materials for the applicable Pooled Fund. In its role as investment

adviser, PLFA generally has discretionary authority to determine which investments are bought and sold and the amounts of such investments that are appropriate for each client. PLFA, subject to the review and/or approval of a Mutual Fund’s Board of Trustees (“Board”) or the Private Fund’s General Partner, could either (1) directly manage an affiliated Pooled Fund itself; (2) delegate investment discretion of all or a part of an affiliated Pooled Fund to other investment management firms as sub-advisers (“Sub-Advisers”) and will oversee the investment management of a Pooled Fund by a Sub- Adviser (a “manager of managers” structure); or (3) manage assets of a Pooled Fund as a Sub-Adviser to unaffiliated third-party institutions. In its role as a manager of managers to affiliated Pooled Funds, PLFA, subject to the review of the Board or General Partner, monitors the performance of these Sub-Advisers and recommends their hiring, termination and/or replacement. PLFA conducts due diligence on Sub-Advisers to evaluate their investment processes, adherence to investment styles, strategies and techniques, and other factors that may be relevant to the services provided to the Pooled Funds. PLFA also provides services related to, among others, the valuation of Pooled Fund securities, compliance, risk management and oversight of trade execution. In its role of oversight of the investment program of the Pooled Funds, PLFA furnishes to the Board or General Partner (which has overall responsibility for the business and affairs of a Mutual Fund or the Private Fund, respectively) periodic reports on the investment performance of each Pooled Fund. The Private Fund that PLFA advises generally employs a manager of managers structure such that PLFA typically does not directly transact in or offer advice on specific investments to the Private Fund. PLFA may develop new advisory services in the future that could differ materially from those described in this Brochure, in which case PLFA will amend this Brochure to provide the applicable information and disclosures.