Firm Description Gator Capital Management, LLC (herein “GCM”, “Gator”, or the “Firm”) is an independent, employee-owned firm offering advisory services and investment solutions to a variety of clients. Gator was founded as a Delaware limited liability company in 2008 and is an SEC-registered investment adviser. Gator’s main office is located in Tampa, Florida. There is one principal shareholder owning more than 25% of our Firm. The shareholder is:  Derek Pilecki, Managing Member. As used in this brochure, the words “we,” “our” and “us” refer to Gator Capital Management, LLC and the words “you”, “your” and “client” refer to you as either a client or prospective client of our Firm. 1. Investment Advisory Services General. Gator primarily provides investment management services using strategies consisting of individual stocks. GCM provides investment management services to institutional clients, individual clients, charitable organizations, a registered investment company, private funds, and other pooled investment vehicles. GCM offers strategies that focus on the Financials sector as well as broad-based portfolios. GCM also may provide custom portfolios at the client’s request. A more detailed list of customer types we work with can be found in Item 7 of this brochure. Separate Account Management Services. GCM manages individual client accounts pursuant to a written investment management agreement setting forth the terms and conditions of our engagement. You will then deposit cash and/or securities in an account with a qualified custodian. Your account balance may be altered by you from time to time by investment, reinvestment, additional deposits, expense distributions, and withdrawals. Separate Accounts may be established using a number of different investment strategies and approaches including, but not limited to:
• Portfolio Strategies. Depending on your specific investment objectives, your account may be invested on the basis of one or more of our Financials sector trading strategies.
• Customized Arrangements. In certain instances, and subject to the terms of the applicable investment management agreement, we may provide portfolio advisory services that are not necessarily managed according to one of our model trading strategies. In such cases, our investment authority may be subject to specific investment objectives, guidelines and/or conditions imposed by you in writing. Generally, we manage all portfolios on a discretionary basis. This allows us to buy and sell various investments under a limited power of attorney in keeping with your investment directives without your prior approval. You may revoke this discretionary authority at any time. To ensure our initial determination of an appropriate trading strategy and/or portfolio remains suitable and the account continues to be managed in a manner consistent with your financial circumstances, you must contact us if there have been any changes in your financial situation or investment objectives, and/or you wish to impose investment restrictions or modify existing restrictions. We will be reasonably available to consult with you. GCM does not act as a qualified custodian of client assets. Private Investment Vehicles. GCM acts as General Partner and Adviser to several private investment partnerships: (i) Gator Financial Partners, LLC, a

Delaware limited liability company; and (ii) Gator Financial Partners Offshore, Ltd., a Cayman Islands Exempted Company (collectively, the “GCM Private Funds”). Mutual Funds. GCM also provides investment advisory services to a proprietary mutual fund. GCM acts as investment adviser for the Caldwell & Orkin – Gator Capital Long/Short Fund. Separate Account Client Use of Affiliated Products. From time to time, GCM may recommend or introduce potential or existing separate account clients to one or more of the GCM Private Funds or mutual fund(s) (collectively, the “GCM Advised Funds”), depending on the nature and size of the relationship or potential relationship, and the client’s investment objectives. Similarly, investors in one or more of the GCM Advised Funds may contact GCM about separate account management. Either of these cases may result in a GCM Advised Fund’s investor also being a GCM separate account client. However, to address potential conflicts of interest and avoid double charging clients, GCM does not charge any fee on that portion of any separate account assets invested in any GCM Advised Funds. 2. Investment Strategies and Types of Investments The descriptions set forth in this brochure of specific advisory services that GCM offers to clients, and investment strategies utilized and subsequent investments made by GCM on behalf of its clients, should not be understood to limit in any way GCM’s investment activities. GCM may offer any advisory services, engage in any investment strategies, and make any investment, including any not described in this brochure, that GCM considers appropriate for its clients, and for which it is qualified, subject to each client’s investment objectives and guidelines. The investment strategies GCM pursues are speculative and entail substantial risks. Clients should be prepared to bear a partial or complete loss of invested capital. There can be no assurance that the investment objectives of any client will be achieved. Gator Financials Strategy Based on the background and experience of the Managing Member of the Firm, Gator offers several products in a strategy that focuses on the Financials sector. Within the Financials Strategy, Gator manages several private funds as well as a registered open-end mutual fund. Gator Advisory Accounts Advisory accounts are customized investment plans developed based on specific client objectives, guidelines, and conditions. In certain instances, and subject to the terms of the applicable investment management agreement, we may provide portfolio advisory services that are not necessarily managed according to one of our model trading strategies. Assets Under Management As of 03/31/2024, GCM managed approximately $244.3 million in regulatory assets. Approximately $244.3 million is managed on a discretionary basis, and $0 is managed on a non- discretionary basis. Termination of Agreement A Client may terminate any investment management agreement at any time by notifying Gator in writing. If the client pays its fees at the beginning of a period and the agreement is terminated, Gator will refund any pro-rata unearned portion of the advance payment less any pro-rata fee earned by GCM. Gator may terminate any investment management agreement at any time by providing (30) thirty days’ prior written notice to the client.