Penn Capital Management Company, LLC (“Penn Capital”), is based in Philadelphia, Pennsylvania. Penn Capital has been an investment adviser registered with the SEC since 1988. Interest in Penn Capital is held by 525 Holding Company, Inc., Penn Capital employees, and Spouting Rock Asset Management, LLC (“SRAM”). In the near future there will be a transaction transferring ownership from SRAM to another entity. Since its inception, Penn Capital has followed its core belief that understanding a company’s entire capital structure is the best way to identify investment opportunities with the most value. In fact, the portfolio managers and research analysts (the “Investment Team”) have found that managing fixed income portfolios makes Penn Capital a better equity manager and managing equity portfolios makes Penn Capital a better fixed income manager. Integrating credit and equity research allows Penn Capital’s team to construct a more comprehensive mosaic and identify inefficient security pricing. This process is called Complete Capital Structure Analysis®. Penn Capital’s Complete Capital Structure Analysis® is executed by the Investment Team, which is comprised of capital structure generalists, responsible for understanding the entire capital structure of the companies they follow. All ideas are vetted through Penn Capital’s Investment Committees and investment decisions are made by senior investment professionals. Penn Capital seeks to select for its portfolios those securities with the greatest potential to provide the risk-adjusted returns that clients expect. As of December 31, 2023, Penn Capital managed approximately $1.7 billion in regulatory assets under management, of which approximately $1.4 billion was managed on a discretionary basis, and approximately $261 million was managed on a non-discretionary basis. Investment Strategies: Penn Capital’s investment strategies focus on micro-to mid-capitalization equity securities, fixed income and high yield securities. The investment strategies are: Micro Cap Equity Small to Micro Cap Equity (SMICRO) Small Cap Equity Small Cap Value Equity Small to Mid Cap Equity (SMID) Mid Cap Equity Ultra-Short Duration Corporate Income Defensive Short Duration High Income Defensive High Yield Fixed Income Opportunistic High Yield Fixed Income Penn Capital provides investment advisory services primarily through the following investment vehicles: registered mutual funds, separately managed accounts, and investment advisory programs offered through wrap fee programs or model portfolio distribution channels. Each of these is described in more detail below. Registered Mutual Funds: Penn Capital serves as a discretionary investment adviser to affiliated mutual funds and subadvises through a model delivery program, non- affiliated mutual funds registered under the Investment Company Act of 1940, as amended (“Investment Company Act”). Penn Capital also provides non-discretionary sub- advisory services to non-affiliated registered mutual funds. Whether acting as investment adviser or sub- adviser, it is Penn Capital’s responsibility to manage mutual fund investments in accordance with the investment strategy described in each mutual fund’s prospectus and statement of additional information. Penn Capital does not perform any sales, custodial, or administrative functions on behalf of the non- affiliated mutual funds Penn Capital sub-advises. Penn Capital is the discretionary investment adviser to four mutual funds within (“funds”) the RBB Funds Trust (the “Trust”), an investment company registered under the Investment Company Act. Penn subadvises the funds via a model-delivery program. Penn Capital will recommend the funds as an investment option for its clients. Penn Capital has an incentive and inherent conflict of interest to recommend and favor the funds because the firm receives advisory fees from the funds. These fees are described in Item 5—Fees and Compensation below and are detailed in each fund’s prospectus. Increases in the funds’ assets will result in increases in the advisory fees paid to Penn Capital. Collective Investment Trust (“CIT”) Funds: Penn Capital serves as the investment adviser to a CIT that is available only to certain retirement plans, as permitted under the U.S. Treasury Department’s guidance for such a group trust. The CIT’s independent trustee manages the CIT and is responsible for CIT-related disclosures and ensuring that each participating retirement plan’s independent plan fiduciary receives the CIT’s Offering Memorandum and executes a Participation Agreement (including a Fee Schedule) with the trustee. Separately Managed Accounts (“SMAs”): SMAs are primarily available to: corporate retirement, pension, and profit-sharing plans; Taft-Hartley plans; registered mutual funds; US and international pooled investment vehicles and private investment funds; insurance companies; charitable institutions; foundations; endowments; municipalities; banking or thrift institutions; corporations; non-US funds; and other institutions, investment advisers, institutional investors, individuals, and high net-worth individuals. Penn Capital is an approved SMA manager on various banking and brokerage platforms. The minimum account size for Penn Capital strategies, typically, is $250,000 for equity and fixed income/bond portfolios. Penn Capital reserves the right to waive the account size minimums. SMA clients have the option to negotiate individualized investment guidelines or directives. If agreed to in advance, some SMA clients also are permitted to impose allocation and/or security-specific restrictions to either individual securities, asset classes, industries, or types of securities. Certain SMA clients also can engage Penn Capital to provide non-discretionary investment advisory services. Wrap Fee Program Accounts: Penn Capital serves as the investment adviser to wrap fee programs that are sponsored by unaffiliated third parties, typically, broker-dealers (“Wrap Fee Accounts”). Wrap fee programs are advisory programs in which the underlying clients pay a single fee to the wrap fee program sponsor for access to the investment advisory services of multiple investment advisers such as Penn Capital. Wrap Fee Account clients typically are high net worth individuals. The sponsors of wrap fee programs have the primary responsibility for the underlying clients’ servicing, communications, custody, and conduct some (or all, depending upon the program) of the trading for client accounts. Wrap Fee Account clients enter into agreements either directly with both the sponsor and Penn Capital (“dual contract” agreements) or solely with the wrap fee program sponsor (“single contract” agreements). Typically, underlying Wrap Fee Account clients do not pay Penn Capital directly for investment advisory services. Instead, Penn Capital receives a (separately negotiated) portion of the wrap fee program sponsor’s fee for managing those Wrap Fee Account assets that are invested in a Penn Capital investment strategy. For single contract agreements, Penn Capital makes no determination of the suitability of the sponsor’s wrap fee program product for such sponsor’s underlying clients. Penn Capital is responsible only for managing the Wrap Fee Account client’s assets in the specified investment strategy. Unless specific program or account restrictions are imposed, Penn Capital manages Wrap Fee Accounts in a similar manner as Penn Capital’s other clients in the same investment strategy. On a limited basis, Penn Capital

permits Wrap Fee Account clients and/or the wrap fee program sponsor to impose restrictions or limits on certain individual securities or types of securities. Any restrictions or limits imposed by these Wrap Fee Account clients and/or the wrap fee program sponsors would likely affect the performance of those accounts (e.g., it could be either higher or lower) than the performance received by Penn Capital’s other clients invested in the same strategy. Also, Wrap Fee Accounts are excluded from participating in initial public offerings (IPOs) because securities for these accounts are purchased through either the wrap fee program sponsor’s or a step out broker’s desk, neither of which meet the conditions described in Item 12 - Brokerage Practices under the heading IPO Allocations required for Penn Capital’s trading desk to purchase IPOs shares. To the extent that Penn Capital’s discretionary clients participate in IPOs, such participation likely will result in better performance than that of the Wrap Fee Accounts that did not participate in the IPO. Penn Capital is not responsible for overseeing the provision of services by a wrap fee program sponsor and cannot assure the quality of such services. Wrap Fee Account clients should review all materials relating to their program (including the program brochure) regarding the wrap fee program sponsor’s terms, conditions and fees, and consider the advantages, disadvantages and overall appropriateness of the program in light of the client’s particular circumstances. Model Delivery Accounts: Penn Capital provides non-discretionary investment advisory services to certain clients who in turn offer Penn Capital’s investment strategies to their own underlying clients (“Model Accounts”). Penn Capital provides model portfolios to several Model Accounts, including, but not limited to, unified management account sponsors (“UMA”), SMA clients, and unaffiliated registered mutual funds. Penn Capital provides its Model Account clients with a model portfolio for the applicable investment strategy, subject to negotiated fees. Penn Capital constructs the model portfolio for the applicable strategy once the model portfolio’s allocations, investments and weightings have been established, which typically occurs at the end of each trading day. Once completed, the model portfolio is provided to Model Accounts prior to the next day’s market open unless a Model Account client requests an alternative delivery schedule for the model portfolio (e.g., weekly, rather than daily). For Model Accounts, Penn Capital provides only the model portfolio, but does not assume responsibility for executing trades, performing recordkeeping, accessing performance data, or providing underlying client reporting. Model Accounts clients, in their sole discretion, choose to act or to not act upon any or all of Penn Capital’s model portfolio recommendations. The recommendations in the model portfolios reflect the recommendations made to Penn Capital’s discretionary accounts. Penn Capital typically delivers the model portfolios to the Model Accounts through the various proprietary systems of each Model Account. The availability of such proprietary systems is beyond the control of Penn Capital. To the extent such system is unavailable, Penn Capital likely would be unable to deliver the model portfolio to such Model Account timely. Since Penn Capital provides Model Accounts with the relevant model portfolios prior to the next day’s market open (or at such time as has been separately negotiated), Penn Capital will have already traded on its recommendations during the prior trading day, which trading was used to establish the model portfolio’s actual weightings and holdings that are then communicated to the Model Accounts prior to the next day’s market open (or at such time as has been separately negotiated). In the instances where the Model Accounts choose to act upon Penn Capital’s model portfolio recommendations, Penn Capital will likely be trading in the same securities for its discretionary client accounts before, concurrently, or after the Model Accounts determine to act on Penn Capital’s recommendations. In this way, and because of intra-day price movements, particularly with large orders or thinly traded securities, timing delays, or other operational factors associated with the implementation of trades, the trades executed by Model Accounts could result in the Model Accounts’ underlying clients receiving prices that are materially different (i.e., at prices that are either higher or lower) than the prices obtained by Penn Capital’s discretionary account clients. Because it does not execute trades on behalf of Model Accounts, Penn Capital cannot seek to manage through its trading strategy the market impact (including such factors as liquidity and price) of securities transactions for Model Accounts in the same way that it seeks to manage market impact for its discretionary client accounts on whose behalf Penn Capital trades. Since Model Accounts are unable to participate in initial public offerings (IPOs) so to the extent that Penn Capital’s discretionary clients participate in IPOs, such participation likely will result in better performance than that of the Model Accounts that did not participate in the IPO. Because Model Accounts exercise investment and trading discretion, the investment performance experienced by the underlying clients of Model Accounts could be higher or lower than the investment performance experienced by Penn Capital’s discretionary clients with the same or similar investment mandates. Penn Capital generally has no direct advisory relationship with any underlying clients of the Model Accounts. Penn Capital is not responsible for the underlying client accounts as part of the investment programs operated by Model Accounts for which Penn Capital provides model portfolios and therefore cannot assess or guarantee the quality of those services or the investment performance experienced by such underlying clients of Model Accounts. Since Penn Capital does not have investment discretion, Penn Capital does not consider itself to have an advisory relationship with underlying clients of the Model Accounts or the sponsor programs of Model Accounts. To the extent that this Brochure is delivered to the underlying clients of Model Accounts with whom Penn Capital has no such advisory relationship, or under circumstances where it is not legally required to be delivered, this Brochure is provided solely for informational purposes. Furthermore, because Model Accounts either directly or through an overlay manager generally exercise investment discretion and, in many cases, brokerage discretion, any performance or other information relating to Penn Capital’s services for which it exercises investment and/or brokerage discretion should be considered to have been provided for informational purposes only, and likely would not be representative of any Model Account’s underlying clients’ results or experience. Penn Capital is not responsible for overseeing the provision by Model Accounts of brokerage or client services to their underlying clients and therefore Penn Capital cannot ensure the quality of such services. Underlying clients of Model Accounts should review all materials relating to their Model Account program (including the relevant program brochure or other documentation) regarding the Model Account program’s terms, conditions and fees, and consider the advantages, disadvantages, and overall appropriateness of the Model Account in light of the client’s particular circumstances.