Shepherd Kaplan Krochuk, LLC (Shepherd Kaplan Krochuk, SKK, or us/we) has been in business since 2001. It was formerly named GRT Capital Partners, LLC, and changed its name in November 2017 when it combined with Shepherd Kaplan LLC, a Boston-based registered investment adviser. As a result of the combination, Shepherd Kaplan LLC (SK) became a majority-owned and wholly controlled subsidiary of SKK. The Management Board of SKK is comprised of David Shepherd, David Kaplan, Timothy Krochuk, Stephen Brackett, and Brian Lockhart, who together indirectly own the company. For ease of reference these individuals may also be referred to as “Principals.” The Principals are also members of SKK Group, LLC, which serves as the managing member of the general partner or manager of a number of private investment funds sponsored and managed by SKK. Stephen Brackett is President and Co-Head of Alternative Investments at SKK, and Tim Krochuk is also Co-Head of Alternative Investments. Timothy Krochuk was also a member and founder of GRT Capital Partners, LLC. David Shepherd and David Kaplan, who were the founders of SK, remain its Co-CEOs and Co-Chief Investment Officers, and as such are primarily responsible for managing the wealth management services provided by SKK. Brian Lockhart is CEO and CIO of Peak Capital Management, LLC (PCM), an SEC-registered investment adviser based in Greenwood Village, Colorado which was acquired in February 2020 by SKK. Effective March 2023, Bayard Dodge replaced David Kaplan as Chief Compliance Officer of SKK and SK. SKK is the overarching adviser of all of the clients of the firm, including asset management clients directly advised by SKK and the wealth management clients sub-advised by SK, but excluding PCM. Readers who are primarily interested in the wealth management services provided by SK should also read SK’s separate Form ADV Part 2A brochure available at www.adviserinfo.sec.gov. Similar to the description in that brochure regarding SK’s sub-advisory services, SKK offers investment advice to clients realizing certain forms of potentially taxable income arising from their disposition of interests in Qualified Small Businesses, as that term is defined in 26 U.S.C. § 1202, et seq. While SKK does not provide tax advice, it provides investment advice concerning investments that may be of interest to investors who expect to receive proceeds of a sale of interests in a Qualified Small Business, and wish to invest in one or more successive Qualified Small Businesses, with the objective of facilitating certain tax benefits pursuant to 26 U.S.C. § 1202, et seq. Readers who are primarily interested in the asset management advisory services provided by SKK directly should read this Form ADV Part 2A brochure. Although SKK is the Managing Member and sole owner of PCM, PCM is currently operated as a separate advisory business from both SKK and SK, and this brochure does not address the services provided by PCM to its clients. Readers who are primarily interested in the investment advisory services provided by PCM

directly should read PCM’s separate Form ADV Part 2A brochure available at www.adviserinfo.sec.gov. In providing asset management services, SKK gives advice as to the investment of funds on the basis of the particular needs of its fund clients. In the case of institutional investors, unless otherwise agreed, these services are offered to the institution, such as private investment funds, pension plans, trusts, a closed-end registered investment company (“RIC”), and other institutions that are clients of SKK, and not directly to the investors, limited partners, members, participants, or clients of such institutions These accounts are generally referred to as asset management accounts in this brochure. SKK can also provide regular and continuous advisory services to high net-worth individuals, which are generally referred to as wealth management accounts in this brochure. In both asset management and wealth management accounts, SKK considers the specific investment objective and strategies, as well as guidelines and restrictions, established for each client account and tailors its advisory services accordingly. SKK normally retains full investment discretion to buy and sell securities and otherwise make investment decisions for asset management accounts, such as private funds and investment companies, that it manages directly. SKK typically provides investment advisory services to its wealth management clients on a non-discretionary basis. In either case, clients may impose restrictions on investing in certain securities or types of securities. As of December 31, 2023, SKK managed client assets of approximately $ 1,360,793,846 on a discretionary basis and $ 7,544,898,902 on a non-discretionary basis for a total of $ 8,905,692,748. In addition to the other services, SKK may, in appropriate circumstances, provide certain wealth management clients with information and/or advice regarding investments in SKK’s own sponsored, private investment funds including private equity funds and private real estate funds, as well as the RIC for which it serves as adviser. Such investments present conflicts of interest, as discussed in Item 11 of this brochure. SKK is currently winding down or has fully wound down the private investment funds and separately managed accounts it advises that employ or employed its various hedge fund strategies, including private funds and separately managed accounts that previously followed the Topaz, Value, Closed End Opportunities and Energy strategies. These strategies are no longer material to SKK’s advisory business, although certain private investment funds may still hold assets subject to that fund’s liquidation process and may still be considered advisory clients of SKK. These funds have completed their final liquidating audits and distributions. Any remaining assets in these funds have no present value and the funds have no investors other than the SKK-affiliate managing entities. SKK does not participate in “wrap fee” programs. Additional information regarding the RIC is found in the RIC offering documents.