BrightSpire Capital BrightSpire Capital Advisors, LLC (“BrightSpire Capital Advisors” or “Manager”) is a Delaware limited liability company that was formed in 2019 as CLNC Advisors, LLC. BrightSpire Capital Advisors is a controlled subsidiary of BrightSpire Capital, Inc. (NYSE: BRSP) (“BrightSpire Capital”), a commercial real estate credit real estate investment trust (“REIT”) focused on originating, acquiring, financing and managing a diversified portfolio of commercial real estate debt and net lease real estate investments predominantly in the United States. Commercial real estate debt investments primarily consist of senior mortgage loans, which BrightSpire Capital expects to be the primary investment strategy. BrightSpire Capital is organized as a Maryland corporation and taxed as a REIT under the U.S. Internal Revenue Code of 1986, as amended. BrightSpire Capital is a public company registered with the SEC under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended. BrightSpire Capital is subject to certain investment restrictions for the purpose of preserving (i) its treatment as a REIT for federal income tax purposes and (ii) its exemption from registration under the Investment Company Act of 1940, as amended (the “Investment Company Act”). BrightSpire Capital is publicly traded on the New York Stock Exchange under ticker symbol “BRSP”. BrightSpire Capital’s Investment Management Business The Manager The Manager is a controlled subsidiary of BrightSpire Capital, whose advisory business primarily consists of advising CLNC 2019-FL1, Ltd. (“CLNC 2019-FL1”) and BRSP 2021-FL1, Ltd. (“BRSP 2021-FL1” and, with CLNC 2019-FL1, “Clients” or “CLOs”), and will likely in the future sponsor, co-sponsor and/or advise other Clients. As of the date hereof, the Manager does not advise any Clients other than the CLOs. The primary business objective of the Manager is to serve as collateral manager and provide collateral management services to the CLOs, which includes reviewing and approving orders for new investment transactions until the end of each such CLO’s reinvestment period, unless such reinvestment period is earlier terminated in accordance with the collateral management agreement. As of December 31, 2023, the Manager managed $1,210,000,971 of Client assets on a discretionary basis and $0 in Client assets on a non-discretionary basis. A Note about Client Disclosures Investors and other recipients of this Brochure should be aware that while this Brochure may include information about a Client or BrightSpire Capital, as necessary or appropriate, the Brochure should not be considered to represent a complete discussion of the features, risks or conflicts associated with any Client or BrightSpire Capital. More complete information about a Client is included in the respective Client’s Governing Documents and/or BrightSpire Capital’s public filings or may be provided to current and eligible prospective investors only by a Client, BrightSpire Capital or another authorized party. In no event should this Brochure be considered to be an

offer of interests in BrightSpire Capital or any Client or relied upon in any determination to invest in BrightSpire Capital or any Client. It is also not an offer of, or agreement to provide, advisory services directly to any recipient of the Brochure. Rather, this Brochure is designed to provide information about Manager for the purpose of compliance with Manager’s obligations under the Advisers Act. Accordingly, the Brochure responds to relevant regulatory requirements under the Advisers Act, which may differ from the information provided in any Client’s Governing Documents. To the extent that there is any conflict between discussions herein and similar or related discussions in any Governing Document, the relevant Governing Document shall govern. Item 5: Fees and Compensation Fees are separately determined for each Client. As a general matter, the Manager and its affiliates are entitled to receive management fees pursuant to advisory contracts and other agreements with clients, as described in more detail below. Management Fees The respective collateral management agreement between the Manager and each CLO provides for a collateral manager fee, payable monthly in arrears on each payment date, equal to 0.10% per annum of the sum of the net outstanding portfolio balance as of such payment date; provided, however, that the Manager has agreed to waive its entitlement to such collateral manager fee for so long as the Manager (or an affiliate thereof) is the collateral manager. There can be no assurance that any non-affiliated replacement collateral manager will also waive the right to receive such collateral manager fee. Other Fees and Expense Reimbursements Expense Reimbursements The Manager will be responsible for its own overhead and expenses incurred in the course of performing its obligations under the collateral management agreement for each Client; provided that the Manager will be entitled to reimbursement for certain out-of-pocket expenses, including, without limitation, expenses and costs incurred in effecting or directing purchases and sales of commercial real estate (“CRE”) loans and eligible investments, negotiating with borrowers under the CRE loans as to proposed modifications or waivers, taking action or advising the trustee with respect to its Clients’ exercise of any rights or remedies in connection with such CRE loans or eligible investments, participating in committees or other groups formed by creditors of the borrower under a CRE loan, consulting with and providing rating agencies with any information in connection with its maintenance of the ratings of the issued notes, expenses related to the provision of information in order to render the issued notes eligible for resale pursuant to Rule 144A, reasonable travel expenses (airfare, meals, lodging and other transportation) undertaken in connection with the Manager’s duties pursuant to the collateral management agreement and for an allocable share of the cost of certain credit databases utilized by the Manager in providing services to the CLOs under the collateral management agreement.