WRCM is a registered investment adviser focused on distressed investments. WRCM seeks opportunities at the intersection of structured finance and small and mid-cap financial institutions. WRCM has been in business as an SEC registered investment adviser since January 15, 2009 and was formed in 2008 to capitalize on the dislocation in the credit markets. R. Davis Howe, James Wingett, Douglas Duncan, Gina Stroud, and William Renovich are the principal owners of WRCM. WRCM provides investment management services to twelve private funds, sub-advises four funds and has limited separately managed accounts. While the funds are generally WRCM’s clients, the term “client(s)” in this brochure sometimes refers to the investors in the funds. WRCM had $266,073,405 of assets under management as of January 1, 2024, all of which was managed on a discretionary basis. This Disclosure Brochure describes the business of WRCM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of WRCM’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on WRCM’s behalf and is subject to WRCM’s supervision or control. Investment Management Services WRCM provides investment management services to clients through separate accounts. For separate account clients, WRCM primarily allocates client assets among various individual debt securities. When WRCM is engaged to provide separate account investment management services, WRCM may charge a separate fee which will be agreed upon prior to rendering the services. Prior to engaging WRCM to provide services, the client will be required to enter into a written agreement with WRCM setting forth the terms and conditions under which WRCM will render its services. Management of Collective Investment Vehicles WRCM provides advisory services to several private funds, including, but not limited to, the Wolf River Partner Fund (the “Partner Fund”), the Wolf River Opportunity Fund, the Wolf River Opportunity Fund II (together the “Opportunity Funds”) and nine Fund of Funds or other investments which are the Wolf River Opportunity Series, LLCs (the “Opportunity Group” as described below). WRCM also provides subadvisory services with respect to several additional funds, including NFC Insurance Partners, LLC, NFC Partners, LLC, Wilson Family Opportunistic Fixed Income Fund, LP, and Pittco Absolute Return Portfolio LP (all advised and subadvised funds are collectively referred to as the “Funds”). Interests in the Funds are privately offered pursuant to Regulation D under the Securities Act of 1933, as amended. The Funds currently rely on an exclusion from registration under Section 3(c)(1) of the Investment Company Page 5 © MarketCounsel 2024 Act of 1940, as amended (the “Company Act”), which permits private investment companies to sell their interests, on a private placement basis, to not more than 100 persons (subject to certain look-through requirements).

WRCM will provide services to the Funds until terminated by either party pursuant to the offering partnership agreement for the Funds. All relevant information, terms and conditions relative to the Partner Fund or the Opportunity Group, including the compensation received by WRCM or an affiliate, withdrawal rights, minimum investments, qualification requirements, suitability, risk factors and potential conflicts of interest, are set forth in the partnership agreement or other offering documents for the Partner Fund, or the LLC agreement or other offering documents for the Opportunity Group, which each investor is required to receive and/or execute prior to being accepted as an investor in the Partner Fund or Opportunity Funds. A conflict of interest exists because the interests in the Partner Fund or Opportunity Funds are owned exclusively by principals, spouses of principals, trusts related to principals, and employees of WRCM, which creates an incentive for WRCM to favor the Partner Fund or Opportunity Funds when allocating investment opportunities among its clients. Nonetheless, WRCM is committed to ensuring that it acts in the best interest of all of its clients when allocating investment opportunities among its clients. Nonetheless, given the above discussion relative to the objectives, suitability, risk factors, and qualifications for participation in the Partner Fund and Opportunity Funds, WRCM may give advice or take action with respect to the Partner Fund or Opportunity Funds that differs from that for its other clients. To the extent that a particular investment is suitable for both the Partner Fund, the Opportunity Funds, and its other clients, such investments will be allocated between the Partner Fund, the Opportunity Funds and its other clients in a manner which WRCM determines is fair and equitable under the circumstances to all of its clients. WRCM serves as the discretionary investment manager for the Opportunity Group, which are comprised of The Wolf River Opportunity Fund, LLC and the Wolf River Opportunity Fund II, LLC and the Wolf River Opportunity Series, LLCs. These investment vehicles seek to achieve risk-adjusted returns by capitalizing on opportunities in the credit markets. The Opportunity Funds are exempt from registration under the Investment Company Act of 1940, and the interests in the Opportunity Funds have been privately offered pursuant to Regulation D under the Securities Act of 1933. The Firm tailors its management services with respect to the Opportunity Funds in accordance with its stated investment objectives. All relevant information about the Opportunity Funds is set forth in the limited liability company operating Agreement for each fund which each investor is required to execute prior to being accepted as an investor. The Opportunity Group is wholly owned by WRCM partners and employees. The Opportunity Series, LLCs are invested in various opportunities outside of WRCM’s area of expertise and so, these types of investments are not offered to outside clients. Page 6 © MarketCounsel 2024