Invictus, a Delaware limited partnership formed in 2008, is registered with the SEC as an investment adviser. As of December 31, 2023, it provides discretionary advice to (i) Invictus Opportunity Fund, L.P., Invictus Opportunity Fund II, L.P. and Invictus Opportunity Fund III, L.P. (the “Opportunity Onshore Funds”), Invictus Opportunity Offshore Fund, L.P., Invictus Opportunity Offshore Fund II, L.P. and Invictus Opportunity Offshore Fund III, L.P. (the “Opportunity Offshore Funds”) and Invictus Opportunity Fund III-R, L.P. (the “Rated Note Fund”, and collectively with the Opportunity Onshore Funds and the Opportunity Offshore Funds, the “Opportunity Funds”), (ii) Invictus Gladiator Fund, L.P. (the “Gladiator Fund”), (iii) Invictus Managed Account-P, L.P., a partnership designed for the benefit of a single investor (“Managed Account-P”), (iv) Invictus Alternative Credit Fund, L.P., a partnership designed for the benefit of a single investor (“IACF”), (v) Invictus Recovery Opportunity Master Fund, L.P. (“IROF”), (vi) Invictus Opportunity Fund III Co-Invest, L.P. (the “Fund III Co-Invest”), (vii) Invictus Sol Venture, LLC, a limited liability company designed for the benefit of a single investor (“ISV”), (viii) MVP1 Pooler, LLC, a limited liability company designed for the benefit of a single investor (“MVP”), (ix) Invictus Atalaya Ventures, L.P., a limited partnership designed for the benefit of a single investor (“IAV”), (x) Invictus Rex Ventures, L.P., a limited partnership designed for the benefit of a single investor (“IRV”), (xi) Invictus Bellator Ventures, LLC, a limited liability company designed for the benefit of a single investor (“IBV”), and (xii) NQM Purchaser, LLC, a limited liability company designed for the benefit of a single controlling third-party investor for which Invictus acts as advisor (“NQM” and collectively with the Opportunity Funds, the Gladiator Fund, Managed Account-P, IACF, IROF, Fund III Co-Invest, ISV, MVP, IAV, IRV and IBV, the “Funds” or the “Clients”). Each Opportunity Offshore Fund, the Rated Note Fund, Managed Account-P, IACF, IROF and the Fund III Co-Invest has one or more separate feeder funds that invests all of its capital in such fund. In turn, each Opportunity Offshore Fund and the Rated Note Fund invests all of its committed capital alongside the related Opportunity Onshore Fund. Managed Account-P invests all of its committed capital alongside Invictus Opportunity Fund, L.P. and Invictus Opportunity Offshore Fund, L.P. IACF invests all of its capital contributions in investments in accordance with its investment strategy. IROF invests all of its capital contributions, through a co-investment vehicle jointly owned by Invictus Opportunity Fund II, L.P. and Invictus Opportunity Offshore Fund II, L.P., in accordance with its investment strategy. Each of the Fund III Co-Invest and IAV invests all of its committed capital alongside Invictus Opportunity Fund III, L.P. and Invictus Opportunity Offshore Fund III, L.P. The primary focus of the Funds is to achieve attractive rates of return primarily through investments that represent interests in recently originated mortgage loans secured by residential properties and Persons (including portfolio companies or other vehicles) that originate, hold or expect to originate or hold such loans (each, an “Investment”). Investments by each of the Clients other than IACF may include (i) securities that are issued and retained in connection with a securitization of mortgage loans acquired for the benefit of the applicable Fund vehicles, (ii) interests in first-lien and second-lien mortgage loans and (iii) any

other participation or interest in mortgage related opportunities regardless of the legal form, transaction structure or when originated, including investments in loan originators and mortgage loans related to properties used for commercial purposes. Investments by IACF may include interests in recently-originated residential and commercial mortgage loans, including (i) residential transitional loans, (ii) higher yielding “jumbo loans”, (iii) non-QM loans targeted for contribution to a non-agency securitization and (iv) commercial bridge loans. The Company may also, on behalf of its Clients, opportunistically invest in other investments in the housing sector and other real estate lending markets and asset classes that share similar investment return characteristics, including business purpose loans. Invictus does not participate in any wrap fee program. The Opportunity Funds, the Gladiator Fund, IROF and the Fund III Co-Invest are not tailored to the individualized investment needs of any particular investor, and while Managed Account-P, IACF, ISV, IAV, MVP, IRV, IBV and NQM are each reasonably tailored based on the individual needs of the investor in such Fund, as agreed with Invictus and consistent with the limited nature of our advisory services, an investment in a Fund does not create a Client-adviser relationship between an investor and Invictus. The single investor in each of ISV, MVP, IRV and IBV has certain negative consent rights over investment opportunities that meet prescribed investment guidelines, and absent exercise of those rights Invictus has discretionary authority to manage the assets of such Fund. The single investor in NQM has consent rights over investment opportunities that meet prescribed investment guidelines, and Invictus does not have discretionary authority to cause such Fund to acquire assets without such investor’s consent. The offering materials for each Fund other than NQM (the “Offering Materials”) contain more detailed information, including a description of the investment objective and strategy or strategies employed and related restrictions that serve as a limitation on Invictus’s advice or management. Each investor is strongly encouraged to undertake appropriate due diligence, including but not limited to a review of relevant Offering Materials and the additional details about Invictus’s investment strategies, methods of analysis and related risks in Item 8 of this Brochure in considering whether Invictus’s advisory services or an investment in a Fund are appropriate to its own circumstances based on all relevant factors including, but not limited to, the investor’s own investment objectives, liquidity requirements, tax situation and risk tolerance before making an investment decision. Because of its role as advisor to NQM, which is itself a limited liability company controlled by a third-party investor, Invictus did not prepare offering materials for such investor; the investor has been provided with, and encouraged to review, a copy of this Brochure. With respect to NQM, references to “Offering Materials” used herein shall refer to the organizational documents of the entity. Michael Warden is the Chief Executive Officer (CEO) of Invictus. Invictus is primarily owned by Invictus Capital Partners, LP, which is managed by Mr. Warden and certain other principals of Invictus. As of December 31, 2023, Invictus had regulatory assets under management of approximately $5,524,835,863 all managed on a discretionary basis, subject to the consent rights of the sole investors in each of ISV, MVP, IRV, IBV and NQM as further described herein.