Whitetail Rock Capital Management, LLC (“WRCM”), founded in 2011, is a SEC- registered investment adviser with its principal place of business located in Nebraska. Our principal owner is Nelnet, Inc., a publicly-traded company. Our Chief Compliance Officer is Matt Brinkman, who can be reached at matt.brinkman@whitetailrock.com or 402.458.2243. WRCM provides asset management for clients based on the individual needs of each client. Our clients are primarily large institutional investors and corporations, high net worth individuals, and private funds. Under these arrangements, client accounts will be regularly monitored for performance and adherence to the client's stated objectives for the funds they have asked us to manage. Through personal discussions with clients we establish risk, return, liquidity, and tax-related objectives and constraints based on each client's particular circumstances. From those discussions we develop a custom investment policy and manage a portfolio based on that policy. A written investment management agreement, which often contains reference to client investment objectives or restrictions, is signed with every client. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), restrictions on approved investments (if any), as well as tax considerations. As of December 31, 2023, WRCM had total assets under management of $3.274 billion based on market value, all discretionary in nature. We manage no client assets on a non-discretionary basis. Clients may impose

in writing reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Once the client's portfolio has been established, we review the portfolio periodically, and if necessary, rebalance, based on the client's individual needs. By assets outstanding, most clients have hired us to follow a strict mandate to manage portfolios of asset-backed securities, predominantly those backed by student loans, a unique asset class in which we have considerable experience performing quantitative and structural investment analysis. We take a long-term, value-oriented approach to such portfolios. We manage four private funds which invest in student-loan backed floating rate asset- backed securities. The funds sell their interests and shares in private transactions solely to accredited investors, qualified clients, or qualified purchasers. While we do highlight our expertise in asset-backed securities, and those portfolios represent the vast majority of our assets under management, the portfolios we manage may also from time to time include: - Corporate debt securities (other than commercial paper) - Municipal securities - Other asset-backed securities - Publicly-traded equity securities - Exchange-traded and mutual funds - United States governmental securities Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. We neither receive nor pay fees (or any other form of compensation) in exchange for referrals. Because some types of investments involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability.