For purposes of this brochure, “Adviser” means BSP CLO Management L.L.C., a Delaware limited liability company established in 2019, when it was founded to serve as the investment adviser and collateral manager to one or more CLOs (as defined below). Background The Adviser is a related adviser under rule 203A-2(b) under common control with an investment adviser registered with the SEC and shares its principal office with such investment adviser. The Adviser is indirectly controlled by Benefit Street Partners (“BSP”), a subsidiary of Franklin Resources, Inc., a global investment management organization (together with its affiliated advisers (but excluding the Adviser), referred to in this section as “Franklin Templeton”). The Adviser shares employees and a unified compliance program with BSP. Please see Item 11 of this brochure for more information with respect to BSP’s compliance program. On November 1, 2022, Franklin Resources Inc. acquired Alcentra NY, LLC (“Alcentra NY”) and Alcentra Limited (“Alcentra Ltd.”). As a result of the acquisition BSP directly, and the Adviser indirectly have integrated certain of their advisory activities, and expect to integrate all of their advisory activities, which include overlapping trading and investment strategies. The Adviser and Alcentra operate under a single compliance program together with the Adviser. The Adviser and Alcentra Ltd. remain separate but closely-affiliated advisers (under common control of Franklin Templeton), with certain combined operations and some overlap in trading and investment strategies, but operate under separate and independent compliance programs. The acquisition and various integrated activities between BSP, the Adviser,

Alcentra NY and Alcentra Ltd., as well as certain other advisory affiliates of the Adviser, raises conflicts of interest. Please see Item 11 and Item 12 below for information regarding how such conflicts of interest are generally addressed by the Adviser through implementation of related policies and procedures. The Adviser provides investment management, collateral administration and supervisory services to the CLOs on a discretionary basis. The CLOs are neither registered under the Securities Act of 1933, as amended, nor registered under the Investment Company Act of 1940, as amended (“Investment Company Act”). Accordingly, interests in the CLOs are offered exclusively to investors satisfying the applicable eligibility and suitability requirements either in private placement transactions within the United States (“U.S.”) or in offshore transactions. No offer to sell interests in these CLOs is made by the descriptions in this brochure. Please see Item 7 of this brochure for more information with respect to the Adviser’s clients. Services The Adviser provides investment advisory services to investment vehicles, including to one or more collateralized loan obligation vehicles (“CLOs”), which predominantly acquire below investment grade leveraged loans. The Adviser generally expects to provide investment advisory services to CLOs under the terms of an investment management agreement, collateral management agreement and/or an indenture. Each such agreement may impose significant limitations on the types of securities and other investments that may be acquired by the relevant CLOs. As of December 31, 2022, the Adviser managed $4,222,953,879 of client assets on a discretionary basis.