ADVISORY BUSINESS General Description of Advisory Firm Easterly provides discretionary and non-discretionary investment advice and/or management services according to the stated investment objectives, restrictions, and policies of each Easterly investment advisory client. Easterly’s clients consist of separately managed accounts (“Separately Managed Accounts”) structured as dual contract accounts or single contract accounts (wrap fee programs), model portfolios/ unified managed accounts (“Model Portfolios”), funds that are registered investment companies under the Investment Company Act of 1940 (the “Investment Company Act”) in some cases that are sponsored by another manager (the “Registered Funds,” “Mutual Funds” or the “Sub-Advised Funds”), and a private fund (“the Private Fund”) (each, a “Client” of Easterly and together, “Clients” of Easterly). Easterly enters into a written investment management agreement with each of its Clients. Easterly maintains full-power and authority to supervise and may make investment decisions on behalf of each Separately Managed Account, Sub-Advised Fund and the Private Fund (each sometimes also referred to as a “Managed Account” or collectively as, “Managed Accounts”) with and without prior consultation with the Client. Easterly also manages open-end Registered Funds and foreign investment advisory relationships on an advisory and sub-advisory basis, and the accounts of certain family members and employees of Easterly personnel on a discretionary basis. In connection with providing investment management services for each of the above-described Clients, Easterly has been granted discretionary trading authorization (other than Model Portfolios) and also may be granted proxy voting authorization. This Brochure generally includes information about Easterly and its relationships with its Clients and affiliates. While much of this Brochure applies to all such Clients and affiliates, certain information included herein applies to specific Clients or affiliates only. Brief History Easterly, a Delaware limited liability company, was formed in October 2018 to engage in the transaction (the “Transaction”) pursuant to an asset purchase agreement under which Easterly acquired certain assets and assumed certain liabilities from Levin Capital Strategies, L.P. (“Levin Capital”). The Transaction closed on March 29, 2019, and Easterly acquired Levin Capital’s institutional asset management business and related operations, including, the investment advisory accounts serviced by that business and associated assets, liabilities and employees. The strategies and accounts transferred to Easterly are the institutional / “long-only” strategies directly managed by Jack Murphy and an event driven strategy managed by Sam Hendel. In connection with this transfer, analysts that support these strategies moved with Mr. Murphy (the “Murphy Team”)

to Easterly. In addition to the up-front consideration, John Levin, an affiliate of Levin Capital, is entitled to a portion of the revenues generated by Easterly. The revenue participation is allocated through a specific equity interest in Easterly. On July 1, 2021, Easterly acquired Snow Capital Management LLC’s (“SCM”) asset management business including all strategies and accounts managed by Richard Snow. In connection with this acquisition, analysts and other team members that support these strategies moved to Easterly (the “Snow Team”). On March 15, 2024, Easterly’s indirect parent company completed the acquisition of 100% of the outstanding ownership units of Easterly Funds LLC, an SEC-registered investment adviser, and Easterly Funds LLC’s investment advisory business and operations were transferred to Easterly. Accordingly, effective March 15, 2024, Easterly is the investment adviser to all of the mutual funds in the “Easterly” family of mutual funds. Easterly is wholly owned by LE Partners Holdings LLC, a Delaware limited liability company, which is principally owned and controlled indirectly by Darrell Crate. The descriptions set forth in this Brochure of specific advisory services that Easterly offers to Clients, and investment strategies pursued, and investments made by Easterly on behalf of its Clients, should not be understood to limit in any way Easterly’s investment activities. Easterly may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that Easterly considers appropriate, subject to each Client’s investment objectives and guidelines. The investment strategies Easterly pursues are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any Client account(s) will be achieved. Easterly’s investment decisions and advice with respect to each Client are subject to each Client’s investment objectives and guidelines, as set forth in the Client’s investment management agreement, as well as any written or verbal instructions provided by the Client to Easterly. Management of Client Assets Easterly manages Client assets on a discretionary basis and makes recommendations for investments for Model Portfolios on a non-discretionary basis. As of March 27, 2024, Easterly’s Regulatory Assets Under Management was $2,104,574,194 in discretionary assets. In addition to the RAUM figure, Easterly has $710,391,884 in non-discretionary assets under advisement in Model Portfolios. As of 3/15/2024, Easterly Funds held $959,031,422 in Regulatory Assets Under Management on a discretionary basis, which was subsequently transferred to Easterly Investment Partners LLC and is incorporated in the discretionary assets above. Updated information is available from Easterly upon request.