Advisory Business A. General Description of Advisory Firm Perini Capital LLC (referred to as “Perini Capital” or the “Firm”) is a New Mexico limited liability company founded in 2011 that has its principal place of business in Scottsdale, Arizona. Perini Capital is registered as an investment adviser with the SEC and serves as the investment manager to private fund clients and separately managed accounts. Perini Capital is wholly owned by Michael D. Perini, CFA. As President and Chief Executive Officer of the Firm, Mr. Perini is primarily responsible for the portfolio management of Perini Capital’s clients. B. Description of Advisory Services This Brochure generally includes information about Perini Capital and Perini Capital’s relationships with its clients. While much of this Brochure applies to all such clients, certain information included herein applies to specific clients only. Perini Capital serves as the investment adviser, with discretionary trading authority, to private fund clients, the securities of which are offered to investors on a private placement basis (each a “Fund Client” and collectively, the “Fund Clients”). The Fund Clients include
• Perini Capital Structured Credit Opportunity Fund, LLC, a Delaware limited liability company (the “Structured Credit Fund”);
• Perini Capital Phoenix Fund, LLC, a Delaware limited liability company (the “Phoenix Fund”); and
• Perini Capital Special Opportunity I, LLC, a Delaware limited liability company (the “Special Opportunity Fund”). Perini Capital Partners, LLC, an affiliate of the Firm, acts as the managing member of the Fund Clients. In addition to the investment advisory services provided to the Fund Clients, Perini Capital provides investment advisory services on a discretionary basis to separately managed accounts (“SMAs”) pursuant to a strategy similar to that of the Structured Credit Fund. In providing services to the Fund Clients and the SMAs, Perini Capital seeks to maximize total return by pursuing strategies focused primarily on opportunities in non-investment grade, non- agency mortgage-backed securities, other mortgage industry related securities, and credit-driven special situations (including primarily investments in domestic common and preferred equity securities and, to a lesser extent, corporate bonds). Please see “Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss” for a description of Perini Capital’s investment strategies and certain related risks. Perini Capital also provides sub-advisory services on a non-discretionary basis to certain private fund clients established and operated by Stonecrest Investment Management, LLC, a third-party investment manager (each a “Sub-Advised Fund” and collectively, the “Sub-Advised Funds). The Sub-Advised Funds include:

• Stonecrest Equity Fund I, LLC, a Puerto Rico limited liability company;
• SIM SJYS Funding LLC, a Puerto Rico limited liability company;
• SIM Rock Funding, LLC, a Puerto Rico limited liability company; and
• SIM Energy Funding, LLC, a Puerto Rico limited liability company. The Sub-Advised Funds primarily invests in equity investments in operating companies, including real estate development companies that are mostly organized and actively engaged in trade or business in Puerto Rico and the United States. As a sub-advisor to the Sub-Advised Funds, Perini Capital provides investment research, advice and supervision of the assets of the Sub-Advised Funds and furnishes an investment program for the Sub-Advised Funds. Perini Capital may, in the future, advise other clients and private investment funds, including additional separately managed accounts, special purpose vehicles, co-investment funds, and similar investment vehicles. As used herein, the term “Client” generally refers to each Fund Client and SMA and to any other client that Perini Capital may advise in the future. The securities of certain Clients are offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933 and other applicable state, federal or non-U.S. laws. Investors in the Clients must meet the qualifications set forth in the applicable offering documents. Persons reviewing this Brochure should not construe this as an offer to sell or solicitation of an offer to buy the securities of any of the Clients described herein. Any such offer or solicitation will be made only by means of a confidential private placement memorandum. C. Tailored Advisory Services for Client Accounts Perini Capital manages assets in accordance with the stated investment objectives of each Client, as described in any relevant investment management agreement, sub-advisory agreement or similar agreement (an “IMA”) or in an offering memorandum or a Client’s organizational documents (together with the IMA and the offering memorandum, the “Offering Documents”). Perini Capital does not tailor its advisory services to the individual needs of investors in the Fund Clients (“Fund Investors”) and generally does not accept Fund Investor-imposed investment restrictions. Perini Capital’s SMA clients may be subject to investment objectives, guidelines and restrictions, fee arrangements and other terms individually negotiated with each such separate account holder. D. Wrap Fee Programs Perini Capital does not currently participate in wrap fee programs. E. Assets Under Management As of December 31, 2023, Perini Capital had approximately $114,137,945 of regulatory assets under management managed on a discretionary basis and approximately $42,847,341 of regulatory assets under management managed on a non-discretionary basis.